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but Most Funds Were Committed to Buying Media Time and Space' which was 
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Report to the Subcommittee on Transportation, Treasury, the Judiciary, 
Housing and Urban Development, and Related Agencies, Committee on 
Appropriations, U.S. Senate:

United States Government Accountability Office:

GAO:

March 2005:

Anti-Drug Media Campaign:

An Array of Services Was Provided, but Most Funds Were Committed to 
Buying Media Time and Space:

GAO-05-175:

GAO Highlights:

Highlights of GAO-05-175, a report to the Chairman and Ranking Member, 
Subcommittee on Transportation, Treasury, the Judiciary, Housing and 
Urban Development, and Related Agencies, Committee on Appropriations, 
U.S. Senate: 

Why GAO Did This Study:

The Office of National Drug Control Policy (ONDCP) was required by the 
Drug Free Media Campaign Act of 1998 (21 U.S.C. 1801 et seq.) to 
conduct a national media campaign to reduce and prevent drug use among 
America’s youth. Since 1998, Congress has appropriated over $1 billion 
for the media campaign. However, a 2003 report by the Senate Committee 
on Appropriations expressed some concerns about the media campaign, 
including concern that a large portion of the campaign’s budget had 
been used for consulting services rather than the direct purchase of 
media time and space. The report, therefore, directed GAO to review the 
use of consultants to support the media campaign. 

This report describes the services provided by consultants (defined by 
GAO as the prime contractors and their subcontractors) in support of 
the media campaign, along with the estimated award amounts for these 
services. 

What GAO Found:

Our analysis of contracts covering ONDCP’s National Youth Anti-Drug 
Media Campaign from fiscal years 2002 through 2004 revealed that four 
contractors provided many of the services required to execute the 
campaign. These four prime contractors provided an array of services 
that fell within three broad categories: (1) advertising, (2) public 
communications and outreach, and (3) evaluation services to gauge the 
campaign’s effectiveness. The prime contractors also acquired 
additional specialized expertise from 102 subcontractors.  Some of the 
specific tasks performed by the contractors and their subcontractors 
included conducting qualitative and quantitative research for 
advertising creation, working with the entertainment industry to 
portray the negative consequences of drug use in television and movies, 
and conducting an evaluation intended to measure the effectiveness of 
the media campaign. Based on our analysis of contracts covering fiscal 
years 2002 through 2004, we estimated that $520 million was awarded to 
the four prime contractors, of which an estimated $373 million—72 
percent—was committed to purchasing media time and space for campaign 
advertisements. The remaining $147 million—28 percent—was for the 
services provided by the prime contractors. Contractors, in turn, 
awarded $14 million of that amount to their subcontractors. 

Estimated Award Amounts for Contractor Services and Purchase of Media 
Time and Space (fiscal years 2002-2004): 

[See PDF for image]

Note: Percentages may not add up to 100 percent due to rounding. 

[End of figure]

www.gao.gov/cgi-bin/getrpt?GAO-05-175. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Laurie Ekstrand at (202) 
512-8777 or ekstrandl@gao.gov. 

[End of section]

Contents:

Letter:

Results in Brief:

Background:

Prime Contractors and Their Subcontractors Provided Three Broad 
Categories of Services, but Most of the Estimated Award Dollars Were 
Committed to Purchasing Media Time and Space:

ONDCP's Comments and Our Evaluation:

Appendix I: Scope and Methodology:

Appendix II: Three Phases of Advertising Development:

Appendix III: Ogilvy & Mather's Subcontractor Services and Associated 
Estimated Award Amounts:

Appendix IV: Fleishman-Hillard Subcontractor Services and Associated 
Estimated Award Amounts:

Appendix V: Comments from the Office of National Drug Control Policy:

Appendix VI: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Staff Acknowledgments:

Tables:

Table 1: Estimated Award Amounts to Subcontractors during Fiscal Years 
2002-2004:

Table 2: Services Provided by the 102 Subcontractors in Support of the 
Media Campaign during Fiscal Years 2002 through 2004:

Table 3: Estimated Contract Award Amounts to Groups of Fleishman- 
Hillard Subcontractors by Fiscal Year (2002-2004):

Figures:

Figure 1: Media Campaign's Advertising Development/Research Process:

Figure 2: Estimated Award Amounts for Contractor Services and Purchase 
of Media Time and Space during Fiscal Years 2002-2004:

Figure 3: Example of Award-Based Data Calculation:

Figure 4: Example of Rate-Based Data Calculation:

Abbreviations:

BCEP: Behavioral Change Expert Panel:

DCI: data collection instrument:

FCEP: Formative Creative Evaluation Panel:

MAM: Madison Advertising Management, LTD. 

NIDA: National Institute on Drug Abuse:

ONDCP: Office of National Drug Control Policy:

PDFA: The Partnership for a Drug-Free America:

SADD: Students Against Destructive Decisions, Inc. 

VNR: video news release:

United States Government Accountability Office:

Washington, DC 20548:

March 31, 2005:

The Honorable Christopher Bond: 
Chairman: 
The Honorable Patty Murray: 
Ranking Member: 
Subcommittee on Transportation, Treasury, the Judiciary, Housing and 
Urban Development, and Related Agencies: 
Committee on Appropriations: 
United States Senate:

The Office of National Drug Control Policy (ONDCP) is charged with 
reducing illicit drug use, manufacturing and trafficking, drug-related 
crime and violence, and drug-related health consequences. To achieve 
these goals, the office formulates a National Drug Control Strategy 
that includes multipronged approaches to combating national drug use. 
Among these approaches is an effort to reduce and prevent drug use 
among America's youth by conducting educational and community action 
programs, including a National Youth Anti-Drug Media Campaign. The 
campaign combines paid and donated advertising with public 
communications outreach in an effort to change teen and parental 
beliefs and behaviors regarding drug use. 

Congress first authorized funding for the media campaign in fiscal year 
1998, with the expectation that demonstrable changes in youth drug 
behaviors would be apparent within 3 years. Since then, over $1 billion 
has been appropriated for the media campaign. In a committee report for 
the fiscal year 2004 appropriations cycle, the Senate Appropriations 
Committee asserted that drug use was increasing in spite of the 
campaign and that some observers had concluded that the campaign was 
having no noticeable impact.[Footnote 1] In addition, the report 
asserted that a large portion of the campaign's budget pays for outside 
media and advertising consultants. As such, the report expressed 
concern about the amount of resources consumed by consultants and the 
extent to which funds were spent for consulting services rather than 
media time and space for advertisements. Given these issues, the 
committee report directed us to review how consultants were used in 
support of the media campaign.[Footnote 2] This report focuses on the 
following question: What services did contractors and their 
subcontractors provide in support of ONDCP's media campaign and what 
were the estimated award amounts for these services for fiscal years 
2002 through 2004? We are currently conducting a separate review 
examining the design and execution of ONDCP's primary effort to 
evaluate the media campaign's effectiveness. 

To respond to the question for this report, we met with and obtained 
documentation from officials at ONDCP headquarters and contractor and 
subcontractor officials in Washington, D.C., and New York City that 
supported the media campaign. We analyzed the contracts of the prime 
contractors and their subcontractors to determine the services they 
provided and the associated estimated award amounts. We used estimated 
award data because at the time of our review actual expenditure 
information was not complete. We conducted our work from March 2004 
through February 2005 in accordance with generally accepted government 
auditing standards. Appendix I provides more detailed information about 
the scope and methodology of our work. 

Results in Brief:

During fiscal years 2002 through 2004, the four prime contractors we 
reviewed and their 102 subcontractors provided a variety of services 
that fell within three broad categories: (1) advertising, (2) public 
communications and outreach, and (3) evaluation services. Some of the 
specific tasks they performed included conducting qualitative and 
quantitative research for advertising creation, working with the 
entertainment industry to portray the negative consequences of drug use 
in television and movies, and evaluating the campaign's effectiveness. 
Based on our analysis of contracts awarded for fiscal years 2002 
through 2004, we estimated that $520 million was awarded to the four 
prime contractors. However, of this $520 million, an estimated $373 
million--72 percent--was committed to purchasing media time and space 
for advertisements. The remaining $147 million--28 percent--was for the 
services provided by the prime contractors. Of that amount, $14 million 
was awarded to the subcontractors by the prime contractors. 

In commenting on a draft of this report, the Director of the Office of 
National Drug Control Policy generally agreed with our findings. ONDCP 
provided technical comments that have been incorporated into this 
report where appropriate. 

Background:

Congressional Authorization and Funding of the Media Campaign:

The Drug-Free Media Campaign Act of 1998, 21 U.S.C. 1801 et seq., 
required the Office of National Drug Control Policy to conduct a 
national media campaign to reduce and prevent drug abuse among 
America's youth. The act specified certain uses of funds provided for 
the media campaign to include (1) the purchase of media time and space; 
(2) out-of-pocket advertising production costs; (3) testing and 
evaluation of advertising; (4) evaluation of effectiveness; (5) 
partnerships with community, civic, and professional groups and with 
government organizations; (6) collaboration with the entertainment 
industry to incorporate anti-drug messages in movies, television, 
Internet media projects, and public information; (7) news media 
outreach; and (8) corporate sponsorship and participation, among other 
uses. The act also mandated a matching requirement. To implement this 
requirement, ONDCP developed a pro bono match program requiring media 
vendors who sell advertising time or space to the media campaign to 
provide (1) an equivalent amount of free public service time or space 
or (2) an equivalent in-kind contribution. 

Congress has appropriated over $1 billion for ONDCP's media campaign 
since it was initiated in 1998. However, the media campaign's annual 
appropriations have declined since Congress initially funded the 
program. ONDCP's 2005 appropriation provides $120 million for the media 
campaign, which represents a $25 million decline from the 2004 
appropriation and a $75 million decline from the first-year funding in 
1998. 

Media Campaign's Advertising Development and Research Process:

The media campaign employs an iterative three-phase advertising 
development and research process. The first phase, the exploratory 
research phase, occurs before advertisements are created. For example, 
before developing the "Monitoring/Love" advertisement series--a message 
targeting parents, promoting awareness of their children's whereabouts--
extensive research was conducted to help ad creators understand methods 
of communicating effectively with parents of teens.[Footnote 3] The 
second phase consists of creating advertisements and subjecting them to 
research and expert review. For example, in the "Monitoring/Love" 
series, focus groups were used to assess parents' reactions to a set of 
advertising concepts. The concepts were subsequently revised in 
response to the feedback. Once the concepts were approved by ONDCP, the 
actual advertisements were produced and tested for effectiveness. The 
third and final phase begins after the advertisements have been 
determined to meet ONDCP's effectiveness standards and involves the 
strategic placement of the advertisements in television, radio, and 
print media. For example, the "Monitoring/Love" series advertisements 
were aired during television shows and radio programs most popular with 
the target audience, the parents of teens. This phase also involves 
measuring the effectiveness of specific advertisements over time within 
target audiences. See figure 1 for a depiction of the three-stage 
process. Appendix II provides a more detailed description of the 
campaign's advertising development and research process. 

Figure 1: Media Campaign's Advertising Development/Research Process:

[See PDF for image]

[End of figure]

Contractor Services in Support of the Media Campaign:

ONDCP uses advertising contractors to supplement its in-house 
capabilities regarding the development, production, and placement of 
paid advertisements on television, radio, print, and the Internet. The 
media campaign also used a contractor to provide assistance with public 
communications and outreach for the campaign, for example, encouraging 
the entertainment industry to portray the negative consequences of drug 
use in movies and television. In addition to developing advertisements 
and conducting public outreach, ONDCP is required to assess whether the 
media campaign's efforts have been effective in changing American 
youths' behavior regarding drug use. During fiscal years 2002 through 
2004, ONDCP used four prime contractors with varying responsibilities 
to carry out the campaign's requisite tasks: Ogilvy & Mather, The 
Advertising Council, Inc. (The Ad Council), Fleishman-Hillard, Inc. 
(Fleishman-Hillard), and Westat, Inc. (Westat).[Footnote 4] These 
contractors used funds from their contracts to secure additional 
specialized expertise from subcontractors.[Footnote 5]

Prime Contractors and Their Subcontractors Provided Three Broad 
Categories of Services, but Most of the Estimated Award Dollars Were 
Committed to Purchasing Media Time and Space:

During fiscal years 2002 through 2004, the four major prime contractors 
were responsible for a variety of services that generally fall into 
three broad categories--advertising, public communications and 
outreach, and evaluation. According to our analysis, an estimated $520 
million was awarded to the prime contractors, of which an estimated 
$373 million--72 percent--was committed to purchasing media time and 
space for advertisements. The remaining $147 million--28 percent--was 
for the services provided by the prime contractors. 

Figure 2: Estimated Award Amounts for Contractor Services and Purchase 
of Media Time and Space during Fiscal Years 2002-2004:

[See PDF for image]

Note: Percentages may not add up to 100 percent due to rounding. 

[End of figure]

Tasks associated with advertising and advertisement development were 
performed by prime contractors Ogilvy & Mather and the Ad Council. 
Ogilvy & Mather was responsible for managing the creative development 
and production of advertising that is targeted toward changing drug 
beliefs and behaviors among America's youth and parents. More 
specifically, Ogilvy & Mather's tasks included (1) media planning, 
placement, and purchase; (2) qualitative and quantitative research for 
advertising creation; and (3) advertising assessment and review. The 
total estimated amount awarded to Ogilvy & Mather for these services 
was about $97 million.[Footnote 6]

The Ad Council was responsible for implementing several specific 
aspects of the advertising component of the media campaign, including 
(1) overseeing the use of media match space and time for public service 
announcements that are not part of the media campaign, (2) creating and 
managing a community-based anti-drug strategy advertising campaign, and 
(3) administering reviews of media campaign advertisement production 
costs. The total estimated amount awarded to the Ad Council for these 
services was about $5 million. 

The purpose of public communications and outreach, which was 
implemented by Fleishman-Hillard, was to extend the reach and influence 
of the campaign through nonadvertising forms of marketing 
communications. To achieve this end, Fleishman-Hillard's tasks included 
(1) conducting media outreach--for example, submitting articles 
relating to key campaign messages such as effective parenting or the 
effects of marijuana on teen health to newspapers and magazines; (2) 
building partnerships and alliances--for example, coordinating positive 
activities for teens with local school and community groups; (3) 
creating Web sites and exploring other alternative media approaches--
for example, designing and hosting message-oriented Web sites such as 
theantidrug.com; and (4) entertainment industry outreach-
-for example, encouraging the entertainment industry to portray the 
negative consequences of drug use in movies and television. The total 
estimated amount awarded to Fleishman-Hillard for these services was 
about $27 million. 

To evaluate the effects of the campaign, ONDCP entered into an 
interagency agreement with the National Institute on Drug Abuse (NIDA). 
NIDA, in turn, contracted with Westat to design, develop, and implement 
an evaluation of the outcome and impact of the media campaign in 
reducing illegal drug use among youth.[Footnote 7] To accomplish this, 
Westat designed a multiphase study to measure the attitudes and 
behavior of critical target audiences--preteens, teenagers, and 
parents. The total estimated amount awarded to Westat for these 
services was about $18 million. 

To fulfill their responsibilities, the prime contractors retained the 
expertise and services of 102 subcontractors for approximately $14 
million. Table 1 shows the estimated award amounts for subcontractors 
during fiscal years 2002 through 2004. 

Table 1: Estimated Award Amounts to Subcontractors during Fiscal Years 
2002-2004:

Dollars in thousands. 

Ogilvy & Mather; 
Number of subcontractors: 20; 
2002: $1,059; 
2003: $1,926; 
2004: $1,880; 
Total: $4,865. 

Ad Council; 
Number of subcontractors: 1; 
2002: $280; 
2003: $210; 
2004: $146; 
Total: $636. 

Fleishman-Hillard; 
Number of subcontractors: 80; 
2002: $4,165; 
2003: $2,910; 
2004: $834; 
Total: $7,909. 

Westat; 
Number of subcontractors: 1; 
2002: $218; 
2003: $224; 
2004: $343; 
Total: $785. 

Total; 
Number of subcontractors: 102; 
2002: $5,722; 
2003: $5,270; 
2004: $3,203; 
Total: $14,195. 

Source: GAO analysis of media campaign contracts. 

[End of table]

Ogilvy & Mather retained 20 subcontractors for nearly $5 million to 
provide two types of services: (1) multicultural media planning and 
buying agencies and (2) substance use behavioral change experts, who 
constituted the Behavioral Change Expert Panel (BCEP). The 
multicultural subcontractors received more than $4 million (about 90 
percent of the nearly $5 million awarded by Ogilvy & Mather to 
subcontractors) for providing marketing services and strategies with 
regard to specific minority audiences. For example, one subcontractor, 
Bromley Communications, was responsible for strategically purchasing 
media time and space for advertisements targeting Hispanic parents and 
youth. Bromley Communications also provided advice on how to develop 
effective advertising for Hispanic audiences. 

The BCEP received less than $500,000 (about 10 percent of the $5 
million awarded by Ogilvy & Mather to subcontractors) for applying 
behavioral science expertise to several aspects of the campaign. For 
example, one behavioral change expert provided consulting services 
related to developing drug use prevention messages targeted to parents 
by reviewing advertising concepts and recommending revisions to enhance 
effectiveness. See appendix III for a more comprehensive description of 
these services. 

The Ad Council retained one subcontractor, Madison Advertising 
Management, LTD., (MAM), to provide advertising production cost review 
services for about $636,000. MAM was responsible for tracking, 
analyzing, and managing estimates and invoices detailing the production 
costs for media campaign advertisements to ensure that production costs 
were reasonable and adhered to ONDCP guidelines. MAM's goals were to 
work with the pro bono advertising agencies, their production 
companies, ONDCP, The Partnership for a Drug-Free America (PDFA), and 
the Ad Council to minimize production costs without infringing on the 
creative process and to maximize the cost efficiency of the media 
campaign.[Footnote 8]

Fleishman-Hillard awarded about $8 million of its total contract award 
to 80 subcontractors for public communications and outreach services. 
These subcontractors provided a wide range of services, including 
photography and video services, research services, Internet technology 
services, and an assortment of speaker and panelist services. See 
appendix IV for a complete description of all services provided by 
Fleishman-Hillard subcontractors and the associated award amounts for 
these services. 

Of the estimated $8 million awarded by Fleishman-Hillard to 
subcontractors, the vast majority--89 percent--went to 14 
subcontractors that provided campaign message promotion services. These 
services were designed to extend the reach and influence of the media 
campaign beyond the paid advertisements by using a variety of marketing 
techniques to publicize the media campaign's anti-drug messages. For 
example, Rogers & Associates was responsible for promoting the 
campaign's message by encouraging the entertainment industry to 
incorporate specific media campaign messages--such as the negative 
consequences of drug use--into television show and movie plots. Another 
campaign message promotion subcontractor, Campbell & Company, was 
responsible for using its social marketing and public health experience 
to conduct public outreach to the African American community--for 
example, developing partnerships with school and community 
organizations to lend credibility to and extend the reach of the media 
campaign. 

Westat retained one subcontractor--the Annenberg School of 
Communication at the University of Pennsylvania (Annenberg)--for an 
estimated $785,000. Although Annenberg was responsible for providing 
overall support to Westat with respect to the entire scope of work 
detailed in the prime contract, it was specifically directed to provide 
particular support for the following six tasks: (1) project management, 
(2) development of the campaign evaluation plan, (3) instrument 
development, (4) data analysis and report generation, (5) preparation 
of contract reports, and (6) modification of the campaign evaluation 
plan. 

To determine the full range of subcontractor services, we reviewed the 
agreements between the prime contractors and their 102 subcontractors. 
From our analysis, we identified 16 distinct categories of services. 
Table 2 contains definitions and examples for each category. 

Table 2: Services Provided by the 102 Subcontractors in Support of the 
Media Campaign during Fiscal Years 2002 through 2004:

Service category: Administrative reporting; 
Subcontract tasks: 
1. Project status reporting; 
2. Meeting and coordinating with other campaign partners, contributors, 
and prime contractors; 
3. Budget management and reporting; 
Examples: Providing monthly summaries of spending on television, radio, 
and print time and space to air the media campaign advertisements. 

Service category: Application of behavioral science expertise; 
Subcontract tasks: Participation in the Behavioral Change Expert Panel. 
Specifically, the application of specialized expertise to: 
4. development of a Behavioral Brief[A]; 
5. review and revision of ad concepts during the preliminary phase of 
the message creation process; 
6. evaluation of ad effectiveness in the post production and the post 
distribution phases of the campaign; 
Examples: Summarizing the major findings of behavioral science research 
that are relevant to drug use behavior change in youth and presenting 
this information to the pro bono advertising agencies responsible for 
developing and producing the media campaign advertisements. 

Service category: Developing partnerships; 
Subcontract tasks: Initiating relationships and coordinating ONDCP's 
anti-drug activities with professional, civic, and community 
associations; businesses; community anti-drug coalitions; and 
government organizations; 
Examples: Identifying and building coalitions with school and community 
groups and using their support to extend the reach and strengthen the 
influence of the media campaign. 

Service category: Entertainment industry outreach; 
Subcontract tasks: Influencing popular culture by promoting campaign 
messages about drug abuse and addiction issues through the 
entertainment industry, including television, movies, music, and other 
forms of popular entertainment; 
Examples: Encouraging television shows popular among youth to 
incorporate specific media campaign messages--such as the negative 
consequences of drug use--into their plots. 

Service category: Meeting and event planning; 
Subcontract tasks: Retaining experts as panelists or speakers to the 
public in support of ONDCP's campaign, planning special events to 
highlight the campaign messages, or generating event attendance through 
promotional work; 
Examples: Participating in media campaign roundtables--such as the 
Marijuana & Kids Media Briefings, which included discussions about the 
latest science on marijuana's neurological, health, and developmental 
effects, particularly on young people. 

Service category: Internet marketing; 
Subcontract tasks: Web site development and maintenance or design and 
production of banner ads; 
Examples: Answering "Ask the Expert" questions that are submitted 
through and posted on theantidrug.com Web site. 

Service category: Management of pro bono match activity; 
Subcontract tasks: Participation in "Pro Bono Match," which refers to 
the media campaign program addressing Congress' requirement that for 
every dollar of advertising that ONDCP spends, an equal dollar of match 
activity in time, space, or other in-kind contributions must be 
obtained. Management of pro bono match activity includes the 
negotiation, documentation, and tracking of all required match 
activity; 
Examples: Ensuring that media vendors (such as television stations, 
radio stations, or newspapers) donate free time and space to air media 
campaign ads in amounts equal to the time and space purchased from them 
with media campaign money. 

Service category: Materials development and distribution; 
Subcontract tasks: Development and dissemination of materials such as 
brochures, fact sheets, and posters to support ONDCP's campaign 
messages; 
Examples: Distributing instructional brochures for parents on "Keeping 
Your Kids Drug Free". 

Service category: Media outreach; 
Subcontract tasks: Promoting campaign messages through broadcast media 
(radio, television); print media (magazines, newspapers); and display 
media (posters, signs), with the goal of educating the media and the 
public about youth drug use. This does not include buying advertising 
time; 
Examples: Researching and writing feature articles on themes such as 
the influence of popular culture on youth drug use or substance abuse 
and related public health issues for submission to magazines and 
newspapers. 

Service category: Media planning and buying; 
Subcontract tasks: Development and execution of a strategy to buy and 
monitor media advertising time and space designed to deliver maximum 
reach, frequency, and effectiveness of the campaign at the lowest cost; 
Examples: Purchasing advertising media time and space strategically to 
target specific media campaign audiences, such as American Indian 
parents and youth. 

Service category: Multicultural community outreach; 
Subcontract tasks: Anti-drug activities designed to ensure that ONDCP's 
campaign reaches targeted multicultural populations; 
Examples: Establishing connections within target multicultural 
communities for the purpose of ensuring that media campaign messages 
reach their intended audiences. 

Service category: Qualitative research; 
Subcontract tasks: Small-group methods such as focus groups, case 
studies, and the development of background information on a defined 
issue or problem; 
Examples: Researching and reporting on the potential for using humor to 
address drug prevention goals. 

Service category: Quantitative research; 
Subcontract tasks: Surveys, content analysis, and other statistical 
analysis of data; 
Examples: Conducting a study on the prevalence and context of substance 
use and abuse in 150 music videos most popular among youth for the 
purposes of determining both the negative and positive substance-
related messages to youth audiences. 

Service category: Stakeholder communications; 
Subcontract tasks: Communications designed to keep stakeholders (i.e., 
ONDCP, PDFA, the prime contractors, and other campaign partners) 
abreast of developments in the campaign and to generate further 
involvement and support; 
Examples: Producing a bimonthly "Campaign Update" newsletter to be 
distributed to all campaign partners. 

Service category: Strategic input; 
Subcontract tasks: General consultation and services given in support 
of the media campaign on an as-needed basis; 
Examples: Providing advice on how to market to target audiences, such 
as how to create culturally sensitive advertising that appeals to 
Hispanic parents. 

Service category: Trafficking of advertising; 
Subcontract tasks: Physical formatting of advertising and distribution 
to media vendors; 
Examples: Ensuring that the correct advertisements (i.e., the actual 
film) are distributed to the television stations that are airing them. 

Source: GAO analysis of subcontracts. 

[A] The Behavioral Brief is a background document that describes the 
major insights of research and literature that should be taken into 
account when developing advertising intended to reach youth audiences. 

[End of table]

ONDCP's Comments and Our Evaluation:

We provided a draft of this report to the Director of the Office of 
National Drug Control Policy for comment. In a March 14, 2005, letter, 
the Director commented on the draft. His written response is presented 
in its entirety in appendix V. In its comments, ONDCP generally agreed 
with our report's findings, and we incorporated its technical comments 
where appropriate. At the same time, ONDCP expressed some concerns 
about our definition of consulting services as it had done throughout 
our review. Specifically, ONDCP argued that the "common use of the 
term" defines consultants as providing advice only, not services. As 
discussed with ONDCP officials throughout this review, we defined 
"consultants" as the prime contractors and their subcontractors that 
provided services, including expert advice, to implement the media 
campaign. Although the senate committee report that mandated our review 
did not define the term "consultants," through our consultations and 
its previous hearings, the committee expressed concerns about the use 
of contractors and their subcontractors for the media campaign. We used 
our definition of consultants to comprehensively account for how 
campaign funds were being used to supplement ONDCP's in-house 
capabilities regarding the advertising, public communications and 
outreach, and evaluation aspects of the media campaign. 

ONDCP also commented on a footnote in appendix IV of this report, which 
cites a GAO appropriations law decision holding that ONDCP violated 
publicity or propaganda prohibitions and the Anti-Deficiency Act when 
it is used appropriated funds to produce several prepackaged news 
stories which failed to disclose that ONDCP produced them for video 
news releases (VNRs) used in the media campaign. ONDCP commented that 
it has not produced a VNR since well before May 19, 2004, when GAO 
issued its first decision, B-302710, on VNRs and prepackaged news 
stories. ONDCP also said that it has no further plans to produce any 
VNRs, stating that GAO's guidance on prepackaged news stories provided 
in our Circular Letter, B-304272, February 17, 2005, is "inherently 
incompatible with contemporary news gathering methods, thus rendering 
VNRs impracticable." However, the guidance in the Circular Letter 
addresses the lack of attribution in prepackaged news stories, which 
are only one part of VNRs. The Circular Letter advises agencies that 
prepackaged news stories can be utilized without violating the law, so 
long as there is clear disclosure to the television viewing audience 
that this material was prepared by or in cooperation with the 
government department or agency. 

We are sending copies of this report to the Director, Office of 
National Drug Control Policy, appropriate congressional committees, and 
other interested parties. In addition, the report will be available at 
no charge on GAO's Web site at http://www.gao.gov. If you or your staff 
have any questions on this report, please call Glenn Davis on (202) 512-
4301 or me on (202) 512-8777. 

Signed by: 

Laurie E. Ekstrand, 
Director: 
Homeland Security and Justice:

[End of section]

Appendix I: Scope and Methodology:

Our review of contractor services and contract award amounts associated 
with the Office of National Drug Control Policy's (ONDCP) National 
Youth Anti-Drug Media Campaign covered fiscal years 2002 through 2004. 
To develop background critical to describing and evaluating key aspects 
of the campaign, we conducted our work at the headquarters of ONDCP, 
The Partnership for a Drug Free America (PDFA), and media campaign 
prime contractors in Washington, D.C., and New York City. We reviewed 
the legislation authorizing the campaign--The Drug-Free Media Campaign 
Act of 1998--and subsequently enacted campaign legislation, as well as 
reports, testimony, interagency agreements, contracts, subcontracts, 
invoices, and vouchers. In addition, to obtain information on the media 
campaign process, we interviewed officials from ONDCP and PDFA. We also 
interviewed officials from the four prime contractors: Ogilvy & Mather, 
Fleishman-Hillard, the Ad Council, and Westat. To supplement our 
understanding of some of the kinds of services provided by 
subcontractors, we also interviewed officials from three of the 
subcontractors. In addition, we reviewed guidelines, reports, and other 
background documents relevant to the media campaign process provided by 
the officials we interviewed. Finally, we reviewed the contracts 
between the prime contractors and ONDCP, which laid out the objectives, 
strategies, and processes of the campaign, as well as the subcontracts 
issued under those prime contracts. While we reviewed the contract and 
subcontract documents, we did not review any of the products resulting 
from those contracts or subcontracts to determine whether they complied 
with any applicable laws. 

To describe the services provided by contractors and their 
subcontractors in support of the media campaign, we analyzed the 
contracts of the four prime contractors and the subcontracts of the 102 
subcontractors. We obtained information about the roles and 
responsibilities of each of the four prime contractors from the 
background, scope of work, and task description sections of their 
respective contracts. Additionally, to describe services provided by 
the 102 subcontractors, we developed a data collection instrument (DCI) 
to allow us to analyze these services uniformly by capturing the 
following information: (1) the subcontract agreement date(s), (2) the 
prime contractor issuing the subcontract(s), and (3) what task 
categories captured the tasks listed in the subcontract 
agreement(s).[Footnote 9] We supplemented our analysis of the prime 
contracts and subcontracts with information from interviews with 
officials from ONDCP and PDFA and representatives from several prime 
contractors and subcontractors. 

We estimated the amounts awarded to each of the four prime contractors 
based on the award data contained in their contracts and any subsequent 
modifications to these contracts related to awards. Each of the four 
prime contracts was a "cost plus fixed fee" contract, meaning that with 
the exception of a fixed fee, payments were disbursed in the form of 
reimbursements for invoiced costs. Therefore, the award amounts listed 
in the contract agreements were estimates of the amounts the 
contractors would actually receive in reimbursements. Because these 
estimates were constantly revised based on the status of campaign 
projects or other information, contract modifications were used to 
update the contract award data. For the purposes of this review, we 
used the latest contract modifications to estimate the prime 
contractors' awards as they contained the most recent information. Each 
of these contracts covered multiple years. Awards for each year of the 
contract were estimated at the beginning of the contract, and those 
yearly estimates were modified throughout the life of the contract. The 
year time frames established by the contracts (with the exception of 
the Westat contract) did not correspond to government fiscal years and 
differed with each contractor. For example, Ogilvy & Mather's contract 
year was from January to January and Fleishman-Hillard's contract year 
was from December to December. In order to estimate the prime 
contractors' award amounts by fiscal year, it was necessary to prorate 
the award data listed in the contracts and modifications. By prorating 
the award data, we obtained estimated award data for each month and 
were then able to calculate estimated award amounts by fiscal year. An 
example of this type of calculation appears below. 

Figure 3: Example of Award-Based Data Calculation:

[See PDF for image]

Note: Numbers may not add due to rounding. 

[End of figure]

The major limitation of this method of analysis is that it assumes an 
equal distribution of the total estimated award over the term of the 
contract, which may not reflect the actual schedule of reimbursements 
to the contractor. Another limitation of our analysis is that it relies 
on estimates of the actual costs (i.e., estimated award amounts). We 
decided to use estimated award data instead of the expenditure data 
provided by ONDCP because the expenditure data were not complete. 

We estimated the amounts awarded to each of the 102 subcontractors 
based on the award data contained in their subcontracts and 
modifications to these subcontracts. In 18 cases where subcontract 
award data were insufficient, we used invoices and vouchers provided by 
the prime contractors to estimate expenditure data. Subcontract award 
data were determined to be insufficient if (1) the subcontract did not 
contain any estimated award data or (2) the subcontract listed a rate 
of compensation for services but did not specify a maximum term or 
compensation. 

We classified the award data contained in the subcontracts of the 102 
subcontractors into five types: (1) cost-reimbursable, (2) cost plus 
fixed fee, (3) indefinite quantity/indefinite delivery, (4) firm fixed 
price, and (5) rate-based. We analyzed each type of award data 
differently to produce estimated award data for the 102 subcontractors 
for fiscal years 2002 through 2004. We analyzed the subcontracts 
containing cost-reimbursable, cost plus fixed fee, and indefinite 
quantity/indefinite delivery award data using the same method used to 
analyze the prime contractor award data. 

We analyzed the subcontracts containing firm fixed price award data 
using the prorating method described above only if the term of the 
subcontract covered multiple fiscal years. Many of these subcontracts 
had terms that fell completely within a single fiscal year, in which 
case we assigned the total award amount listed in the subcontract to 
the appropriate fiscal year. Firm fixed price subcontracts are 
agreements in which the subcontractor receives a fixed amount for the 
services it provides. Regardless of the time the subcontractor requires 
to complete its assigned tasks or whether the subcontractor incurs 
additional unexpected costs in the completion of its assigned tasks, it 
will not receive any additional funds without a subsequent modification 
to the subcontract. Consequently, the award data contained in the firm 
fixed price subcontracts represents the actual amount the subcontractor 
should have received.[Footnote 10]

We analyzed subcontracts containing rate-based awards in a two-step 
process to produce estimated awards by fiscal year. Subcontracts 
containing rate-based data contain (1) a rate of compensation for the 
subcontractor (for example, $200 per hour), (2) a maximum term (such as 
10 hours) or maximum compensation (such as $2,000), and (3) a term or 
period of performance (i.e. the period of time during which the 
subcontractor will provide its service, such as between June 1, 2002, 
and June 30, 2002). We calculated the maximum possible award by 
multiplying the rate of compensation by the maximum term (unless the 
subcontract specified a maximum compensation). We considered this 
calculation of maximum possible awards as the total estimated award 
amounts for all rate-based subcontracts. If the term (period of 
performance) of the subcontract fell within a single fiscal year, then 
the total estimated award of the contract was assigned to the 
appropriate fiscal year. If the term (period of performance) of the 
subcontract covered multiple fiscal years, then the total estimated 
award was prorated as previously described, and total estimated awards 
for each fiscal year were calculated. An example of this type of 
analysis appears below. 

Figure 4: Example of Rate-Based Data Calculation:

[See PDF for image]

[End of figure]

In the 18 cases where we used invoices and vouchers to estimate 
expenditure data because subcontract award data were insufficient, we 
grouped the invoices and vouchers of each subcontractor by fiscal year 
and totaled the invoice/voucher amounts for each fiscal year. 

The methods of analysis used to produce estimated award data for 
subcontractors for fiscal years 2002 through 2004 have many of the same 
limitations as the method used to analyze the prime contract award data 
(i.e., much of the subcontract award data had to be prorated and some 
of the subcontract award data represented estimated reimbursements). In 
addition, we had to substitute expenditure data in the case of 18 
subcontracts that did not contain sufficient award data. Consequently, 
we based some of our calculations related to total subcontractor 
estimates on different types of data (expenditure or award). We decided 
to use estimated award data whenever possible to ensure data 
consistency (i.e., to avoid comparing contractor awards based on 
estimated award data with subcontractor awards that were based on 
expenditure data). 

We conducted our work from March 2004 through February 2005 in 
accordance with generally accepted government auditing standards. 

[End of section]

Appendix II: Three Phases of Advertising Development:

To develop anti-drug television, print, Internet, and radio ads, the 
media campaign employs a three-phase advertising development and 
research process. The three phases of the advertising development and 
research process are (1) the exploratory research phase (pre-ad 
creation); (2) the qualitative and quantitative research and expert 
review phase (during ad creation); and (3) the media planning, 
placement, and tracking phase (post-ad creation). 

The initial exploratory phase consists of extensive research to 
understand the subject matter and covers many sources of information, 
including (1) consumer insights, (2) national studies, (3) behavioral 
change experts, and (4) subject matter experts. PDFA is a major source 
for this background research. In addition, the Behavioral Change Expert 
Panel (BCEP), assembled by Ogilvy & Mather, is composed of a number of 
individuals possessing specialized expertise relevant to specific 
aspects of the media campaign, such as the sociology of behavior change 
in youth or communicating with minority audiences. The BCEP is 
responsible for developing a Behavioral Brief, which is a background 
document that describes the major insights of research and literature 
to consider when developing advertising intended to reach youth 
audiences. The final goal of the exploratory research phase is for 
Ogilvy & Mather and PDFA to produce a Creative Brief for each 
advertising series.[Footnote 11] The Creative Brief is a compilation of 
information provided by subject matter experts, including (1) 
information relevant to the specific messages of the campaign and (2) 
relevant portions of the qualitative research provided by PDFA 
regarding consumer insights and national studies. The pro bono agencies 
responsible for the creative development of a given advertising series 
use the Creative Brief and the Behavioral Brief to inform their 
efforts. 

The second phase involves ad creation and qualitative and quantitative 
research. PDFA is responsible for soliciting pro bono advertising 
agencies that create the advertising concepts using the Creative and 
Behavioral Briefs. The media campaign uses multiple pro bono 
advertising agencies to develop advertisements. One example of a media 
campaign advertising series is the "Monitoring/Love" series of 
advertisements--a message targeting parents, promoting awareness of 
their children's activities. A single pro bono ad agency developed all 
of the advertisements within this series. After initial advertising 
concepts are developed, the Formative Creative Evaluation Panel (FCEP) 
and the BCEP review these initial concepts.[Footnote 12] Next, feedback 
from FCEP and BCEP is used to revise the advertising concepts. Any 
recommendations or observations that may be relevant to future campaign 
efforts are to be kept for possible applications to new Creative Briefs 
during the initial exploratory research phase (i.e., the feedback loop 
in this iterative process). 

Once the advertising concepts have been reviewed and revised, 
production estimates are calculated and reviewed for maximum cost 
efficiency. Once this process is completed, ONDCP is responsible for 
reviewing the ad concepts and approving funding for production of the 
advertisements. After advertisements are produced, they are submitted 
for copytesting, a process used to determine whether advertisements 
meet effectiveness standards for distribution. In the copytesting 
process, large sample audiences (usually consisting of 300 youths and 
150 parents per copytest session) view the ads and are surveyed 
regarding their responses to the advertisement, drug attitudes, 
beliefs, and behaviors. Copytesting relies on a comparison of exposed 
audiences and nonexposed control audiences to determine effectiveness 
of advertisements. According to Ogilvy & Mather (the contractor 
responsible for implementing copytesting), the audience is split evenly 
across ethnic, gender, and age categories. One-half of the audience is 
exposed to the advertisement and the other half is not. Copytesting 
researchers then survey and compare the drug beliefs and intentions of 
each group to determine the effectiveness of the advertisement. If an 
advertisement does not meet effectiveness standards set by ONDCP, the 
advertisement is not aired. To successfully pass the copytesting 
process, an advertisement must significantly strengthen anti-drug 
beliefs or weaken intentions to use marijuana without creating any 
adverse effects. Copytesting questions are designed so that the 
information provided by the responses can be used to revise 
advertisements that fail to meet effectiveness standards. 

Media planning (determining where, when, and for how long to air or 
print the advertisements) occurs concurrently with the advertising 
development and assessment process. The media plan is finalized and 
executed (the advertisements are distributed to media vendors) once the 
advertisements have successfully completed the copytesting phase and 
the advertisements have undergone a final review by ONDCP. After the 
advertisements air, audience reactions are to be tracked through an 
evaluative process that measures the effectiveness of specific ads over 
time within specific audience populations.[Footnote 13]

[End of section]

Appendix III Ogilvy & Mather's Subcontractor Services and Associated 
Estimated Award Amounts:

During fiscal years 2002 through 2004, Ogilvy & Mather retained the 
services of two groups of subcontractors: (1) multicultural media 
planning and buying agencies and (2) substance use behavioral change 
experts--the Behavioral Change Expert Panel. Ogilvy & Mather awarded 
nearly $5 million to its 20 subcontractors. 

Multicultural Subcontractors Services and Estimated Awards:

Six multicultural subcontractors provided services in support of Ogilvy 
& Mather's media planning, placement, and purchase responsibilities. 
Each multicultural subcontractor provided marketing services and 
strategies with regard to a specific minority audience. Each 
multicultural subcontractor was responsible for planning and buying 
media advertising time and space targeting its minority audience, 
managing the pro bono match activity that accompanied its media 
purchases, and trafficking advertising to media vendors. The 
multicultural subcontractors also assisted Ogilvy & Mather with its 
advertising creation and assessment responsibilities by providing 
strategic input with regard to marketing to minority audiences, 
particularly at the preliminary qualitative research and initial ad 
concept review phases. 

Ogilvy & Mather awarded more than $4 million to the multicultural 
subcontractors, constituting about 90 percent of the nearly $5 million 
amount awarded by Ogilvy & Mather to subcontractors during fiscal years 
2002 through 2004. The awards received by multicultural subcontractors 
covered only the cost of labor, overheard, and fees and did not include 
any funding specifically designated for the purchase of media 
advertising time and space. 

Behavior Change Expert Panel Subcontractors Services and Associated 
Estimated Award Amounts:

BCEP subcontractors mainly applied their specialized expertise to three 
aspects of the advertising development and research process: (1) the 
development of the Behavioral Brief,[Footnote 14] (2) the review and 
revision of initial advertising concepts, and (3) the evaluation of ad 
effectiveness in the postproduction and postdistribution phases of the 
campaign. During the initial exploratory research phase, the BCEP 
developed the Behavioral Brief and contributed to the development of 
the Creative Brief.[Footnote 15] The pro bono advertising agencies 
engaged by PDFA used the Behavioral and Creative Briefs to develop 
initial advertising concepts and preliminary ads. During the 
qualitative research and expert review portion of the ad creation 
phase, the BCEP reviewed the initial advertising concepts and 
preliminary ads and contributed to the qualitative research process by 
recommending improvements and revisions to the ads to foster behavior 
changes in the target audiences. After the final production of the ads, 
the BCEP worked with PDFA and Ogilvy & Mather to develop the questions 
used during the copytesting and postdistribution evaluation processes 
to determine the nature and extent of the effect of the ads on audience 
beliefs and intentions. At any point during the advertising development 
and research process, BCEP subcontractors were to provide strategic 
input and advice to any media campaign partner on an as-needed basis. 

Ogilvy & Mather awarded less than $500,000 to the BCEP subcontractors, 
constituting about 10 percent of the nearly $5 million awarded by 
Ogilvy & Mather to all of its subcontractors during fiscal years 2002 
through 2004. 

[End of section]

Appendix IV Fleishman-Hillard Subcontractor Services and Associated 
Estimated Award Amounts:

To support its public communications and outreach efforts, Fleishman- 
Hillard retained the services of 80 subcontractors, which we 
categorized in the following 10 groups: (1) campaign message promotion, 
(2) photography and video production, (3) campaign message development, 
(4) contracting management, (5) research, (6) internet technology, (7) 
Marijuana & Kids Briefings panelists and speakers, (8) Library Working 
Group experts, (9) Asian American and Pacific Islander Marijuana Media 
Roundtable panelists and speakers, and (10) Teen Advisor Program 
experts. Fleishman-Hillard awarded about $8 million to its 80 
subcontractors. 

Approximately 89 percent of the estimated $8 million dollars that 
Fleishman-Hillard awarded was provided to a single category of 
subcontractor--those responsible for campaign message promotion. Table 
3 depicts award amounts within the remaining 11 percent (about 
$900,000), which was awarded to nine categories of subcontractors. 

Table 3: Estimated Contract Award Amounts to Groups of Fleishman- 
Hillard Subcontractors by Fiscal Year (2002-2004):

Group: Photography and video production; Number of subcontractors: 11; 
2002: $28,875; 2003: $281,199; 2004: $34,665; Aggregated totals: 
$344,739. 

Group: Campaign message development; Number of subcontractors: 14; 
2002: $82,777; 2003: $108,466; 2004: $22,313; Aggregated totals: 
$213,556. 

Group: Contract management; Number of subcontractors: 1; 2002: $61,376; 
2003: $98,972; 2004: $13,931; Aggregated totals: $174,279. 

Group: Research; Number of subcontractors: 5; 2002: $35,840; 2003: 
$45,198; 2004: $1,563; Aggregated totals: $82,601. 

Group: Internet technology; Number of subcontractors: 4; 2002: $2,680; 
2003: $25,800; 2004: $6,400; Aggregated totals: $34,880. 

Group: Marijuana & Kids briefings; Number of subcontractors: 12; 2002: 
$2,300; 2003: $12,700; 2004: 0; Aggregated totals: $15,000. 

Group: Library Working Group meeting; Number of subcontractors: 5; 
2002: $5,000; 2003: 0; 2004: 0; Aggregated totals: $5,000. 

Group: Asian-American and Pacific Islander Marijuana Media Roundtable; 
Number of subcontractors: 10; 2002: 0; 2003: $5,000; 2004: 0; 
Aggregated totals: $5,000. 

Group: Teen advisor program; Number of subcontractors: 4; 2002: 0; 
2003: 0; 2004: $800; Aggregated totals: $800. 

Group: Aggregated total; Number of subcontractors: [Empty]; 2002: 
[Empty]; 2003: [Empty]; 2004: [Empty]; Aggregated totals: $875,855. 

[End of table]

Source: GAO analysis of estimated subcontractor award amounts. 

Photography and Video Production:

Eleven photography and video production subcontractors provided a wide 
array of services, including photographing media campaign promotional 
events and creating audiovisual materials promoting media campaign 
messages.[Footnote 16] For example, one photography subcontractor was 
responsible for photographing the media campaign's Boston Parent Wake- 
Up Rally and processing the photographs for Web display and digital 
reproductions. Gourvitz Communications, Inc. was responsible for 
producing a number of videos for the media campaign, including the 
Marijuana Initiative Video News Release and the Marijuana Community 
Coalition Video. 

Fleishman-Hillard awarded an estimated total of nearly $345,000 to 
photography and video production subcontractors during fiscal years 
2002 through 2004. Within this group, the two largest awards went to 
video production subcontractor Gourvitz Communications, Inc. (an 
estimated $262,000) and to Court TV (an estimated $77,000). The 
remaining nine awards were each for an estimated $1,500 or less. 

Campaign Message Development:

Fourteen campaign message development subcontractors provided a wide 
array of services, including planning and implementing promotional 
events and researching and drafting feature articles for submission to 
print and online media venues. For example, one campaign message 
development subcontractor, Students Against Destructive Decisions, Inc. 
(SADD), was responsible for raising public awareness of the risks of 
marijuana use by planning and executing five guerrilla "Wake-Up" 
student rallies in which students, dressed in distinctive clothing 
designed by ONDCP and SADD, distributed media campaign materials in 
highly public urban sites during rush hour. Another campaign message 
development subcontractor answered "Ask the Expert" questions submitted 
through the media campaign's "theantidrug.com" Web site and researched 
and wrote feature articles on media campaign key messages that were 
placed on the Web site and submitted to print media venues. 

Fleishman-Hillard awarded an estimated $214,000 to campaign message- 
development subcontractors during fiscal years 2002 through 2004. 
Within this group, the four largest awards went to SADD (an estimated 
$44,000), to Pride Youth Programs (an estimated $30,000), and to two 
individual experts (estimated amounts of $54,000 and $25,500). The 
remaining 10 awards were each for an estimated $14,000 or less. 

Contract Management:

The sole subcontractor providing contract management services was a 
temporary placement agency. This subcontractor provided temporary 
personnel staff to Fleishman-Hillard to assist with the preparation of 
invoices to be submitted to ONDCP regarding Fleishman-Hillard projects. 
Fleishman-Hillard awarded an estimated $174,000 to this subcontractor 
during fiscal years 2002 through 2004. 

Research:

Five research subcontractors provided a wide array of services, 
including analyzing media campaign marketing strategies and reporting 
on the kinds of drug-related messages currently influencing America's 
youth. For example, one research contractor, MarketBridge was 
responsible for demonstrating and quantifying the value of corporate 
partnerships to the media campaign. Another research subcontractor, 
Mediascope, was responsible for conducting a study on the prevalence 
and context of substance use and abuse in the 150 most popular music 
videos for the purposes of identifying the negative and positive 
substance-related messages targeting youth audiences. 

Fleishman-Hillard awarded an estimated $83,000 to research 
subcontractors during fiscal years 2002 through 2004. Within this 
group, the largest award, an estimated $56,000, went to MarketBridge. 
The remaining four awards were each for an estimated $10,000 or less. 

Internet Technology:

Four Internet technology subcontractors provided a wide range of 
services including e-mail distribution and Web site development. For 
example, an Internet technology subcontractor, Experian eMarketing 
Services, was responsible for creating and sending e-mail messages to 
recipient lists created by Fleishman-Hillard, using content provided by 
Fleishman-Hillard. Another Internet technology subcontractor, TestPros, 
assessed the usability of two media campaign Web sites. 

Fleishman-Hillard awarded an estimated $35,000 to Internet technology 
subcontractors during fiscal years 2002 through 2004. Within this 
group, the largest award, an estimated $17,500, went to Experian 
eMarketing Services. The remaining three awards were each for an 
estimated $11,000 or less. 

Marijuana & Kids Briefings:

Twelve Marijuana & Kids Briefings subcontractors served as panelists 
and speakers in roundtable discussions addressing the latest science on 
marijuana's neurological, health, and developmental effects on youth. 

Fleishman-Hillard awarded an estimated $15,000 to these subcontractors 
during fiscal years 2002 through 2004 to panelists and speakers for its 
Marijuana and Kids Briefings. All of the Marijuana & Kids Briefings' 
subcontractors were individual experts, rather than firms. Most of 
these subcontractors were paid at a daily rate of $500, with a maximum 
term of service of 1 day. Within this group, the largest award went to 
an individual expert for an estimated $9,000. The remaining 11 awards 
were each for an estimated $1,000 or less. 

Library Working Group:

The purpose of the Library Working Group was to explore how librarians 
and other adults can help kids find accurate, high-quality information 
about drugs on the Internet. Five Library Working Group subcontractors 
provided a range of services including advising on common library and 
Internet issues; assisting in the development of instructional products 
about cyberliteracy and illicit drugs; and recommending strategies, 
vehicles, and partnerships to accomplish program goals. 

Fleishman-Hillard awarded an estimated $5,000 to Library Working Group 
subcontractors during fiscal years 2002 through 2004. All of the 
Library Working Group subcontractors were individual expert, rather 
than firms. Each of the five subcontractors received a total estimated 
award of $1,000. 

Asian American and Pacific Islander Marijuana Media Roundtables:

Ten Asian American and Pacific Islander Marijuana Media Roundtable 
subcontractors served as panelists and speakers in roundtable 
discussions to address the latest scientific findings on marijuana's 
neurological, health, and developmental effects on youth. 

Fleishman-Hillard awarded an estimated $5,000 to Asian American and 
Pacific Islander Marijuana Media Roundtable subcontractors during 
fiscal years 2002 through 2004. All of the Asian American and Pacific 
Islander Marijuana Media Roundtable subcontractors were individual 
experts, rather than firms. Each of these subcontractors received a 
total estimated award of $500. 

Teen Advisor Program:

Four Teen Advisor Program subcontractors were responsible for providing 
insight and feedback on the campaign's youth-oriented strategies in 
order to guide the development of teen programs, events, and Web site 
content. 

Fleishman-Hillard awarded an estimated $800 to Teen Advisor Program 
subcontractors during fiscal years 2002 through 2004. All of the Teen 
Advisor Program subcontractors were individual experts, rather than 
firms. Each of the four subcontractors received a total estimated award 
of $200. 

[End of section]

Appendix V: Comments from the Office of National Drug Control Policy: 

EXECUTIVE OFFICE OF THE PRESIDENT: 
OFFICE OF NATIONAL DRUG CONTROL POLICY: 
Washington, D.C. 20503:

March 14, 2005:

Ms. Laurie E. Ekstrand:
U.S. Government Accountability Office: 
441 G. Street, NW:
Washington, D.C. 20548:

Dear Ms. Ekstrand:

The Office of National Drug Control Policy (ONDCP) has reviewed the 
draft GAO report entitled, "Anti-Drug Media Campaign: An Array of 
Services Was Provided, but Most Funds Were Committed to Buying Media 
Time and Space." In general, ONDCP believes that the report is accurate 
in its description of the complexities of the contracting, 
subcontracting and consulting issues. However, ONDCP believes there are 
several instances in which we find it necessary to respond to or 
clarify comments.

GAO has had difficulties attempting to develop a bright line 
distinction between contractors, subcontractors, and consultants, and 
we remain perplexed by the GAO's definition of "consulting services" to 
include all Media Campaign contracts (please see page 2). GAO asserts 
that the concern by Congress was that "...a large portion of the 
Campaign's budget pays for outside media and advertising consultants" 
and that "...the committee report directed us to review how consultants 
were used in support of the Media Campaign." Yet in the common use of 
the term, a fundamental distinction is that consultants provide 
opinions whereas contractors provide services. Nevertheless, we are 
confident that the Media Campaign's actual use of consulting services 
over the period of review demonstrates good judgment and stewardship of 
Campaign resources, and are used when necessary to access expert 
opinion so that this very sophisticated Campaign can be planned and 
implemented wisely.

As noted on page 3, this report does not reflect the fact that of the 
funds "awarded" to Ogilvy (noted here as $97.0 million over the 
surveyed period), a significant amount (the estimate is approximately 
41 percent, or $40 million) were monies approved by ONDCP for payment 
out to PDFA-chosen advertising agencies and production companies for 
making of commercials/ads, as well as for research, measurement, 
tracking and monitoring of that advertising (CMR, FCEPs, Millward 
Brown, etc.). While the recipients of these funds were not identified 
as consultants or subcontractors under the GAO definitions, the funds 
were paid to these vendors as part of Media Campaign implementation and 
not retained by Ogilvy.

We do not concur with GAO's view that the Westat evaluation contract 
with NIDA should be treated as "...a prime contractor of the Media 
Campaign..." (This is noted on page 6 footnotes). While indeed ONDCP 
has statutory responsibility for evaluating the Campaign, this 
interpretation puts NIDA, the nation's premier scientific organization 
focusing on the drug issue, in the position of being merely a check- 
writing organization and not serving the purpose that ONDCP intended 
and NIDA agreed to and carried out. NIDA's research expertise has been 
engaged since day one of the agreement and is a critical function. Had 
ONDCP treated NIDA as merely a pass-through organization then ONDCP 
would have been violating the spirit of the congressional mandate to 
carry out an independent evaluation. Further, it has been NIDA's 
ongoing responsibility to monitor the performance of the contractor and 
remedy any potential shortcomings by way of evaluation design, 
execution, or interpretation of findings.

Further, the agreements with HHS and NIJ to carry out clearinghouse 
services also should not be treated as prime contracts. Although review 
of these agreements is not included in the GAO report for appropriate 
reasons, it should be clear that interagency agreements, whether for 
purposes of carrying out the evaluation or providing clearinghouse 
services, involves the expertise of the recipient Federal agency and is 
not merely a pass-through.

Fleishman Hillard (FH) and its subcontractors are not tasked with 
placing anti-drug messages through the purchase of time or space. More 
accurately, Fleishman Hillard's task is described as promoting the anti-
drug messages and information to the news and entertainment media and 
to appropriate organizations such as community coalitions, schools, 
employers and corporations. For references, note pages 9, 13, and 27.

In the description of services provided by FH on page 8, the report 
describes media outreach and gives the example of submitting articles 
to newspapers and magazines. However, a more accurate description of 
FH's media outreach would be their effort to secure accurate news 
coverage on marijuana harms to youth through media events and briefings 
for reporters with scientific experts. Moreover, in the table on page 
9, the description Entertainment industry outreach subcontract task as 
"placement of campaign messages" would be more appropriately described 
as "promotion of campaign messages." Neither FH nor its subcontractors 
have the power or resources to actually "place" campaign messages in 
popular entertainment venues. The example given is accurate.

In the media outreach category on page 13, the word "placement of 
campaign messages" again overstates the resources and abilities of the 
Campaign's subcontractors in this category. The phrase "promotion of 
campaign messages" is a more accurate description. Similarly, the 
example given should describe the activity as articles that are 
"submitted" to magazines and newspapers, rather than "placed." Further, 
in Appendix IV on page 26, GAO has grouped a set of 14 subcontractors 
under the heading "Campaign Message Development." The activities of 
these subcontractors/consultants is better described as "Anti-drug 
Message Dissemination " as their tasks are generally to plan and 
implement events and activities that further disseminate campaign 
messages.

Although the nature of these fourteen subcontractors is generally well 
detailed on page 27, this description twice references "placement of 
messages", as opposed to the more appropriate description - submission 
of articles. Again, these subcontractors do not have the responsibility 
for placement of messages through purchase of media time or space.

To clarify the reference to NIDA on page 21, NIDA does not provide 
qualitative research to the Campaign. However, NIDA does provide review 
and clearance of all campaign messages, to assure that message content 
is scientifically accurate.

The observation is made on page 21 that the Campaign "...deliberately 
uses many pro bono agencies to develop advertisements to ensure variety 
and fresh perspectives." While that viewpoint is consistently 
expressed, the reality is that such potential benefits are sometimes 
outweighed by the challenge of working with many different ad agencies, 
few of whom have any background or history with preparing anti-drug 
ads. Given the sensitivity of the subject matter and the fact that 
today's teens are the most marketed to generation ever, the special 
expertise that theoretically is derived over time with both topic and 
audience is rarely achieved.

On page 22, we would like to clarify that FCEPs are not panels of 
experts in either drug issues or the target audiences, but rather are 
actual groups of target audience individuals (teens or parents) who are 
carefully recruited and convened to review advertising concepts. This 
is a critical first stage of target audience exposure to prototype 
messages.

ONDCP notes the referenced GAO finding on VNRs (page 27 footnote), and 
suggests that it be clarified to point out that the ONDCP Media 
Campaign has not produced a VNR since well before the GAO ruling on the 
HHS VNRs on May 19, 2004. Further, ONDCP believes that the GAO guidance 
on "prepackaged news stories" issued to federal agencies on February 
17, 2005 sets forth a requirement for viewer notification which is 
inherently incompatible with contemporary news gathering methods, thus 
rendering VNRs impracticable. In any event, ONDCP has no plans to 
produce any further VNRs.

ONDCP appreciates this opportunity to review the draft report and to 
provide formal comment. Should you have any questions, please contact 
Christine Morden in the Office of Legislative Affairs at the Office of 
National Drug Control Policy.

Sincerely,

John P. Walters: 
Director: 

[End of section]

Appendix VI: GAO Contacts and Staff Acknowledgments:

GAO Contacts:

Laurie E. Ekstrand (202) 512-8777: 
Glenn G. Davis (202) 512-4301:

Staff Acknowledgments:

In addition to those named above, the following individuals contributed 
to this report: David Alexander, Leo Barbour, R. Rochelle Burns, 
Christine Davis, Wendy C. Johnson, Weldon McPhail, Jean McSween, Brenda 
Rabinowitz, Tami Weerasingha, Bill Woods, and Kathryn Young. 

FOOTNOTES

[1] Senate Report No. 108-146, at 143 (2003) accompanied the media 
campaign's proposed 2004 appropriation in the Transportation, Treasury 
& General Government Appropriations Bill, 2004, S. 1589, 108th Cong. 
The media campaign's 2004 appropriation was ultimately enacted as part 
of the Consolidated Appropriations Act, 2004, P.L. 108-199, 118 Stat. 
325 (2004). 

[2] The senate committee report that mandated our review did not define 
the term "consultants." But given the concern expressed by the 
committee, we focused our review on the prime contractors and their 
subcontractors used by ONDCP to implement the media campaign. During 
the period of our review, ONDCP obtained acquisition services to award 
the contracts in support of its media campaign from the U.S. Navy Fleet 
Industrial Supply Center (FISC) and GovWorks (a service-for-fee federal 
acquisition center, operating under the U.S. Department of the 
Interior's Franchise Fund). Acquisition services included planning, 
soliciting, awarding, administering, terminating, and closing out all 
contracts for ONDCP's media campaign. ONDCP's contract management 
responsibilities included, among other things, developing statements of 
work and tracking and reporting on contractors' performance. Although 
the contracts were awarded and managed by FISC and GovWorks on behalf 
of ONDCP, because ONDCP provided the funding for these contracts, we 
refer to ONDCP as having used these contractors to implement the media 
campaign. 

[3] An advertising series is a set of three or four advertisements with 
a common theme. 

[4] In its comments on our report, ONDCP disagreed that Westat is a 
prime contractor of the media campaign because Westat's contract is 
with the National Institute on Drug Abuse (NIDA), not with ONDCP. 
Although we are aware that NIDA awarded the evaluation contract to 
Westat, we considered Westat as a prime contractor of the media 
campaign for purposes of this report. We did so because ONDCP has 
statutory responsibility for evaluating the media campaign's 
effectiveness, see P.L. 105-61, 111 Stat. 1295 (1997), and it entered 
into an interagency agreement with NIDA for NIDA to award a contract to 
evaluate ONDCP's media campaign. The interagency agreement provided 
that ONDCP would fund the evaluation contract through media campaign 
appropriations and would work with NIDA to ensure that the evaluation 
met ONDCP program and policy objectives of measuring the campaign's 
impact. 

[5] Two additional prime contractors, the National Clearinghouse of 
Alcohol and Drug Use Information and the National Institute of Justice, 
provided clearinghouse services in support of the media campaign. We 
did not include these contractors in our review because the focus of 
our review was to examine the services provided by advertising, public 
communications and outreach, and evaluation contractors. 

[6] This estimated award amount does not include the approximate $373 
million included in Ogilvy & Mather's contract that was committed to 
purchasing media time and space for advertisements. The approximate sum 
of $373 million was to cover the cost of the media time and space only 
and does not include the cost of Ogilvy & Mather's labor associated 
with negotiating and executing media purchases. 

[7] Because Westat's contract with NIDA implements ONDCP's statutory 
requirement of evaluating the media campaign's effectiveness, and 
because ONDCP funded the Westat contract through media campaign 
appropriations, we treated Westat as a prime contractor of the media 
campaign throughout the course of this review. 

[8] In partnership with ONDCP and the advertising contractors, The 
Partnership for a Drug-Free America engaged pro bono advertising 
agencies to create and develop the advertising concepts of the media 
campaign. Production companies selected by the pro bono agencies 
produced the actual advertisements. These production companies 
developed production estimates (i.e., estimates of the cost of 
producing the advertisement) and submitted them to MAM for review. 
Production of the advertisements occurred only after MAM recommended 
the production estimates to ONDCP for approval (and ONDCP granted 
approval). After producing the advertisements, the production companies 
submitted their invoices and cost reimbursement totals to MAM. After 
MAM approved the reimbursement request, Ogilvy & Mather reimbursed the 
production companies for the cost of producing the advertisements. 

[9] Two coders independently reviewed the subcontracts. If the coders 
disagreed with the coding of a particular task, they reconciled their 
responses before finalizing the DCI for the subcontract. 

[10] Because this review is not a contract audit, and we focused on the 
estimated awards amounts for contractors and subcontractors, we did not 
verify that contractors received the exact amounts listed in their firm 
fixed price contracts. 

[11] An advertising series consists of three or four similarly themed 
advertisements. 

[12] FCEPs are evaluative discussion panels (i.e., focus groups), 
consisting of target audience individuals (teens or parents) who are 
carefully recruited and convened to review advertising concepts. 

[13] This evaluative process for the individual advertisements is 
separate from the evaluation of the effectiveness of the media campaign 
as a whole (the Westat study). 

[14] The Behavioral Brief is a background document that describes the 
major insights of research and literature that pro bono ad agencies 
should be aware of when developing advertisements intended to reach 
youth audiences. 

[15] Creative Briefs are constructed by Ogilvy & Mather and PDFA for 
specific campaign messages. BCEP subcontractors are responsible for 
ensuring that the points listed in Creative Briefs are accurate and 
consistent with Behavioral Briefs. 

[16] A July 2004 congressional request asked us to examine several 
video news releases (VNRs) produced for the media campaign. Those 
releases included, among other things, several prepackaged news 
stories. Because those news stories did not disclose to the targeted 
television viewing audiences that they had been prepared at the 
government's behest, we determined in B-303495, Jan. 4, 2005, Office of 
National Drug Control Policy--Video News Release, and in B-303495.2, 
Feb. 15, 2005, Reconsideration of B-303495--Office of National Drug 
Control Policy Prepackaged News Stories, that ONDCP violated the 
publicity or propaganda prohibitions and the Anti-Deficiency Act when 
it used appropriated funds to produce those stories. GAO subsequently 
issued a Circular Letter, B-304272, Feb. 17, 2005, advising agencies 
that prepackaged news stories can be utilized without violating the 
law, so long as there is clear disclosure to the television viewing 
audience that this material was prepared by or in cooperation with the 
government department or agency. ONDCP commented that it ceased 
producing VNRs well before May 2004, and has no plans to produce any 
further VNRs. 

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