Recommendation: During the next reauthorization for surface transportation programs, Congress should consider including language in the reauthorization bill that would require DOT to develop and implement transparency measures for DOT's review and selection process for discretionary grants. Such measures should, at a minimum, help to ensure that the evaluation process is clearly communicated, that applications are consistently evaluated, and that the rationale for DOT's decisions are clearly documented. Such measures should be developed in line with Office of Management and Budget guidance, federal internal control standards, and recommended practices for evaluating and selecting discretionary grant awards (Matter for Consideration 1)

Agency: Congress
Status: Open

Comments: As of November 2019, Congress has not enacted a reauthorization measure for surface transportation programs. The current authorization expires on September 30, 2020.

Recommendation: The Secretary of Transportation should ensure that DOT, in its notice of funding opportunity and evaluation plan for each remaining INFRA-funding cycle, clarify the circumstances under which DOT may select applicants to receive requests for additional information. (Recommendation 1)

Agency: Department of Transportation
Status: Open

Comments: As of November 2019, DOT told us that, for the fiscal year 2020 INFRA awards, it plans to provide information in the Notice of Funding Opportunity and evaluation plan explaining under the circumstances under which additional information may be sought from applicants. DOT stated that it plans to complete these actions by March 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should develop procedures for each remaining INFRA-funding cycle to ensure that when additional information is requested from an applicant, the specific rationale behind the request is documented (for example, to promote geographic diversity among projects), as well as to ensure that DOT documents the rationale if similar projects were not afforded an opportunity to provide additional information. (Recommendation 2)

Agency: Department of Transportation
Status: Open

Comments: As of November 2019, DOT told us it will document the basis for seeking additional information from applicants and describe the procedures for doing so in the evaluation plan for the FY 2020 INFRA awards, which it expects to conclude by September 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should ensure that DOT provides information to applicants in its notice of funding opportunity for each remaining INFRA-funding cycle regarding: (1) how scores on merit criteria are used, if at all, to determine whether projects advance to the Secretary for selection, and (2) how, if at all, DOT plans to use merit scores to determine which projects should receive an award. (Recommendation 3)

Agency: Department of Transportation
Status: Open

Comments: As of November 2019, DOT told us that, for the fiscal year 2020 INFRA awards, it plans to provide information in the Notice of Funding Opportunity that will more clearly state (1) that projects are advanced to the Secretary based on how they are evaluated against the selection criteria and (2) how evaluations against the selection criteria are used to determine which projects should receive awards. DOT stated that it plans to issue the Notice of Funding Opportunity by March 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should clarify in the SCASDP evaluation plan how reviewers should assess a grant application's alignment with the priority and secondary selection criteria and assign the application rating categories. (Recommendation 1)

Agency: Department of Transportation
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Labor should direct its subagencies, other than ETA, to design and implement a process to manage and administer grantees' compliance with the Stevens Amendment, including determining to what extent to provide guidance to grantees on calculations. (Recommendation 1)

Agency: Department of Labor
Status: Open

Comments: In responding to the report, DOL stated that it concurs with the recommendation. DOL's subagency, OSHA, provided written comments and stated that it generally agreed with GAO's recommendation. On March 3, 2020, DOL staff said the agency will provide an update to its response to this recommendation, along with responses to open recommendations from other GAO reports, in several months.

Recommendation: The Secretary of Education should design and implement a process to manage and administer grantees' compliance with the Stevens Amendment, including determining to what extent to provide guidance to grantees on calculations. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: In a subsequent response to the report, Education stated that it concurred with GAO's recommendation and is considering enhancing its current approach to overseeing compliance with the Stevens Amendment through post-award monitoring activities. On March 9, 2020, an Education Department Official stated that the planned date that work is due to be completed by the applicable program office is 9/30/2020. According to the official, the work will promote consistency across applicable grant programs and enhance their monitoring efforts. The official further stated that Education will develop general monitoring guidance to further check on compliance with the Stevens Amendment for implementation across Education's grantmaking Principal Offices. As a part of monitoring, program offices will be expected to review the Stevens Amendment statutory requirements with grantees and plans to reiterate that grantees are required to disclose for their grant project the percent of the costs financed with federal funds, the federal dollar amount, and the percentage and dollar amount financed by nongovernmental funds when issuing statements, press releases, bid solicitations, and other documents describing their grant project. Education also plans to remind grantees that they must document how the dollar amounts and percentages were calculated in the disclosures and maintain this documentation with their grant file. We will update the action taken in response to this recommendation when further action is confirmed.

Recommendation: The Director of OMB, working with CFOC, should (1) collect data metrics regularly on the Career Roadmap Builder online tool and Grants Training 101 to determine how widely the resources are being used, and (2) obtain periodic feedback from federal agencies on the usefulness of these tools and any needed improvements. (Recommendation 2)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: OMB staff provided us with oral comments stating that the agency partially concurred with our recommendations. For our second recommendation, OMB agreed that user feedback data regarding the Career Roadmap Builder and Grants Training 101 is useful. However, OMB stated that while it will continue to collect data on the number of users, it believes that federal agencies should be responsible for collecting specific, detailed user data if they are using those resources. We continue to believe that OMB and CFOC would benefit from collecting specific, detailed user data on these tools, which they devoted time and multiple resources to developing. Collecting detailed data metrics that go beyond the number of users can help OMB and CFOC to better evaluate the effectiveness of these grants training tools. Additionally, OMB stated the agency is committed to working with CFOC to review the Grants Training 101 module to determine how useful it is and if any improvements or adjustments are needed. In May 2019, OMB staff said that no action had been taken to date in response to this recommendation. In January 2020, OMB responded in writing to this recommendation stating that it was continuing to collect data on usage for both training tools on the CFO.gov site. OMB specified, however, that the usage data was for the number of visitors on the two sites and on users by agency. OMB went on to say that each agency is responsible for the professional development of its own workforce, and that Federal agencies can, at their discretion, collect user data if the Roadmap and Grant Training 101 are part of their official training program. In addition, OMB stated it had made the Grants Training 101 available publicly for federal and non-federal personnel on CFO.Gov, and that collecting specific user data is not considered by them to be beneficial to demonstrate the usefulness of the materials. Based on this response, we will continue to inquire as to the availability and use of metrics and effectiveness measures for the Career Roadmap and the Grants Training 101 modules.

Recommendation: The Secretary of HHS should establish a process to monitor and evaluate HHS's grants training at the central office level. This process should include (1) a method for identifying all employees working on grants across the agency, and (2) oversight procedures to evaluate the sufficiency of sub-agencies' grants training efforts including the incorporation of leading practices related to assessing competencies, training approaches, accountability, and training results. (Recommendation 3)

Agency: Department of Health and Human Services
Status: Open

Comments: HHS concurred with our findings and recommendation. In its comment letter, HHS stated that its Office of Grants Policy, Oversight, and Evaluation, within the Office of Grants and Acquisition Policy and Accountability, Division of Grants, in conjunction with the HHS ReInvent Grants Initiative would be developing and implementing a department-wide financial assistance training and certification program to improve the functional effectiveness of the financial assistance management workforce in the areas of internal controls and risk mitigation. The program is designed to support the professional development of the HHS grants management workforce through both instructor-led and online courses. HHS' ReInvent Grants Management (RGM) staff and GAO held a conference call on November 30th, 2018 to discuss how RGM intended to address the recommendation in GAO-18-491 by developing a generalized framework for the Grants Management Training and Certification (GMTC) program for HHS. An HHS official reported that at its December 2019 quarterly meeting, the HHS Division of Workforce Development (DWD) reported they had in the past quarter: briefed the HHS Executive Committee on Grants Administration Policy (ECGAP) on the DWD mission and goals for training the grants workforce; developed briefing documents and presentations based on a RGM developed framework to develop competencies and outline curriculum of the GMTC program; continued to review and refine the program framework to incorporate DWD mission and goals; drafted the initial policy to further inform the structure and procedures of the GMTC program (e.g. certification levels, required coursework, career development requirements), which should be issued by HHS Office of Grants within Federal Fiscal Year 2020; and collaborated with the HHS Grants Closeout Business Process Reengineering Team to discuss current grants closeout status and how DWD can support grant staff and grant recipient closeout training efforts. Given the ongoing nature of HHS efforts, GAO will continue to monitor progress on a quarterly basis.

Recommendation: The Secretary of Education should establish timeframes for providing states with additional information on allowable expenditures of funds reserved for pre-employment transition services. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation and stated that it would establish projected timeframes for providing states with additional information on allowable expenditures for the provision of preemployment transition services. Education also stated that it intends to provide states with additional information in at least two forums before the end of calendar year 2018 and to review and analyze previous guidance provided to states on allowable expenditures.

Recommendation: The Secretary of Education should take additional steps to provide states assistance on updating and finalizing their interagency agreements with state educational agencies to include pre-employment transition services. These steps could include, for example, accelerating their efforts to discuss the benefits of finalizing interagency agreements, and reminding states of existing technical assistance resources pertaining to updating and finalizing interagency agreements. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation, in large part, because there is no statutory provision authorizing the agency to identify such states. Nevertheless, Education stated that it is taking some steps as part of its ongoing monitoring of the VR program to provide assistance to states that have not updated their interagency agreements. This is consistent with the intention of our recommendation but we believe more could be done. The agency also noted that it would continue to offer and provide technical assistance if it becomes known through the onsite monitoring of the VR program or through other means that states have not updated their interagency agreements between VR agencies and state educational agencies. In addition, its Rehabilitation Services Administration (RSA) and Office of Special Education Programs will provide information related to sources of technical assistance, as appropriate, to VR agencies and state educational agencies. While these steps may be helpful, given the number of states that have not updated and finalized their agreements and the length of time Education officials say they will take to complete this round of monitoring where Education asks state VR agencies about these agreements, additional action by Education may be needed to help states more efficiently and effectively coordinate services to students with disabilities.

Recommendation: The Secretary of Education should develop a written plan with specific timeframes and activities for identifying and disseminating best practices that address, as appropriate, implementation challenges for pre-employment transition services, such as those identified in this report. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation believing it is premature to develop a timeline for the dissemination of best practices. The agency stated that the identification of "best" practices, meaning those that are clearly supported by a body of evidence derived from valid and reliable research findings, is still emerging as states implement the requirements. Education stated that as RSA identifies best practices through its monitoring and technical assistance activities, it will, in collaboration with its Office of Special Education Programs, consider when and how best to disseminate this information to state VR and educational agencies. With regard to including specific timeframes and activities in a written plan, by detailing the specific steps Education is taking and plans to take along with the amount of time it expects them to take, Education would be better positioned to complete those steps in a timely manner and meet the statutory requirement that Education highlight best state practices and support state agencies.

Recommendation: The Assistant Secretary for Mental Health and Substance Use should establish procedures to better ensure that mid-performance changes to program priority goals, objectives, and targets are examined across multiple years. (Recommendation 1)

Agency: Department of Health and Human Services: Public Health Service: Substance Abuse and Mental Health Services Administration
Status: Open

Comments: As of October 2019, HHS reported that the Substance Abuse and Mental Health Services Administration (SAMHSA) would add new additional features to its web-based system for overseeing the mental health protection and advocacy programs, with an implementation target date of October 2020. The agency described one new feature as a tracking tool to monitor program requests to revise priority goals, objectives, and targets over multiple years. In the meantime, SAMHSA has developed a manual tracking tool for its project officers to use until the electronic tool is in place. Another new feature is a workflow that will allow project officers, team leaders, and branch chiefs to review and approve changes made by the programs. However, SAMHSA has not yet provided documentation of the latter feature to demonstrate that it has developed procedures for project officers to review the changes over multiple years. Therefore, the agency lacks assurances that its project officers will consistently examine whether a particular program is regularly making changes to benchmarks that may be indicative of a potential performance problem. We will review the web-based tracking tool when available and continue to monitor SAMHSA's efforts to develop procedures for examining changes to benchmarks over multiple years.

Recommendation: The Secretary of the Interior should ensure that the Director of the Office of Insular Affairs, as Chairman of the FSM compact trust fund committee, works with other members of the committee to develop a distribution policy for the FSM compact trust fund, as required by the compact trust fund agreement, that takes into account potential strategies that could address risks to the fund's ability to provide a source of income after fiscal year 2023. (Recommendation 1)

Agency: Department of the Interior
Status: Open

Comments: Upon the report's publication, Interior concurred with our report's recommendations and set a target date for implementation of October 1, 2023. In July 2018, Interior stated that the trust fund committees were in discussions related to identifying the parameters and principles for a distribution policy and formula(s) to calculate the distribution prior to preparing the text of a distribution policy, and that representatives from Interior and the State Department would discuss our recommendations with the trust fund committees. According to the Trust Fund Administrator and Interior, the distribution policy was discussed at subsequent trust fund committee meetings, and trust fund representatives met with FSM representatives in January 2019 to discuss the status of the trust fund and future scenarios for its management. GAO observed the FSM trust fund committee's September 2019 meeting. At the meeting, the trust fund adviser presented a presentation to the committee that discussed issues associated with the distribution policy, fiscal procedures, and timing of the calculation of amounts available for disbursement. However, the FSM compact trust fund committee did not make any decisions regarding steps to address our recommendations. At the meeting, an FSM representative on the FSM compact trust fund committee stated that the FSM's Joint Compact Review and Planning Committee (JCRP) had appointed a chief negotiator and, in light of this appointment, the FSM compact trust fund members would not be taking a position on a distribution policy on behalf of the FSM. The FSM's position is that the distribution policy and other future compact trust fund-related issues should be discussed as part of future negotiations between the FSM and the United States. The December 2019 trust fund committee meeting again included post-2023 issues on the agenda, but the committee did not take actions at that time.

Recommendation: The Secretary of the Interior should ensure that the Director of the Office of Insular Affairs, as Chairman of the FSM compact trust fund committee and of the FSM Joint Economic Management Committee, works with other members of the committees to develop the fiscal procedures required by the compact trust fund agreement. (Recommendation 2)

Agency: Department of the Interior
Status: Open

Comments: Upon the report's publication, Interior concurred with our report's recommendations and stated that discussions to address them are ongoing within the trust fund committees. In July 2018, Interior stated that discussions among the trust fund committees and others were ongoing and the fiscal procedures applicable to the trust fund disbursements will be determined prior to October 1, 2023. In February 2019, Interior stated that discussions about policies and controls were frequent and ongoing among Committee members and staffers along with the trust fund manager and investment advisers. GAO observed the FSM trust fund committee's September 2019 meeting. At the meeting, the trust fund adviser presented a presentation to the committee that discussed issues associated with the distribution policy, fiscal procedures, and timing of the calculation of amounts available for disbursement. However, the FSM compact trust fund committee did not make any decisions regarding steps to address our recommendations. At the meeting, an FSM representative on the FSM compact trust fund committee stated that the FSM's position is that future compact trust fund-related issues should be discussed as part of future negotiations between the FSM and the United States. The December 2019 trust fund committee meeting again included post-2023 issues on the agenda, but the committee did not take actions at that time.

Recommendation: The Secretary of the Interior should ensure that the Director of the Office of Insular Affairs, as Chairman of the FSM compact trust fund committee, works with other members of the committee to address the timing of the calculation of compact trust fund disbursements. (Recommendation 3)

Agency: Department of the Interior
Status: Open

Comments: Upon the report's publication, Interior concurred with our report's recommendations and stated that discussions to address them are ongoing within the trust fund committees. In July 2018, Interior stated that the trust fund committees have been discussing options for ensuring that the timing of the calculation of compact trust fund disbursements align with the budget process of the FSM and that, of the options reviewed thus far, using a multi-year rolling average was the favored option. Interior added that the final determination on the timing of the calculation of the trust fund disbursements will be addressed in the distribution policy. Interior set a target date for implementation of the recommendation to develop a distribution policy of October 1, 2023. In February 2019, Interior stated that discussions about policies and controls were frequent and ongoing among Committee members and staffers along with the trust fund manager and investment advisers. GAO observed the FSM trust fund committee's September 2019 meeting. At the meeting, the trust fund adviser presented a presentation to the committee that discussed issues associated with the distribution policy, fiscal procedures, and timing of the calculation of amounts available for disbursement. However, the FSM compact trust fund committee did not make any decisions regarding steps to address our recommendations. At the meeting, an FSM representative on the FSM compact trust fund committee stated that the FSM's position is that future compact trust fund-related issues should be discussed as part of future negotiations between the FSM and the United States. The December 2019 trust fund committee meeting again included post-2023 issues on the agenda, but the committee did not take actions at that time.

Recommendation: The Secretary of the Interior should ensure that the Director of the Office of Insular Affairs, as Chairman of the RMI compact trust fund committee, works with other members of the committee to develop a distribution policy for the RMI compact trust fund, as required by the compact trust fund agreement, that takes into account potential strategies that could address risks to the fund's ability to provide a source of income after fiscal year 2023. (Recommendation 4)

Agency: Department of the Interior
Status: Open

Comments: Upon the report's publication, Interior concurred with our report's recommendations and set a target date for implementation of October 1, 2023. In July 2018, Interior stated that the trust fund committees were in discussions related to identifying the parameters and principles for a distribution policy and formula(s) to calculate the distribution prior to preparing the text of a distribution policy, and that representatives from Interior and the State Department would discuss our recommendations with the trust fund committees. According to the Trust Fund Administrator and Interior, the distribution policy was discussed at subsequent trust fund committee meetings, and trust fund representatives met with RMI representatives in January 2019 to discuss the status of the trust fund and future scenarios for its management. GAO observed the RMI trust fund committee's September 2019 meeting. At the meeting, the committee received written information from the trust fund adviser that discussed issues associated with the distribution policy, fiscal procedures, and timing of the calculation of amounts available for disbursement, but the scheduled adviser presentation did not occur. At the meeting, an RMI representative on the RMI compact trust fund committee stated that the RMI government has determined that using the original distribution structure, with disbursements in the amount of annual grant assistance and full adjustment for inflation, remains the RMI's position. In addition, any adjustments to the distribution policy and trust fund structure will be made as a result of government to government negotiation. The December 2019 trust fund committee meeting again included post-2023 issues on the agenda, but the committee did not take actions at that time.

Recommendation: The Secretary of the Interior should ensure that the Director of the Office of Insular Affairs, as Chairman of the RMI compact trust fund committee and of the RMI Joint Economic Management and Financial Accountability Committee, works with other members of the committees to develop the fiscal procedures required by the compact trust fund agreement. (Recommendation 5)

Agency: Department of the Interior
Status: Open

Comments: Upon the report's publication, Interior concurred with our report's recommendations and stated that discussions to address them are ongoing within the trust fund committees. In July 2018, Interior stated that discussions among the trust fund committees and others were ongoing and the fiscal procedures applicable to the trust fund disbursements will be determined prior to October 1, 2023. In February 2019, Interior stated that discussions about policies and controls were frequent and ongoing among Committee members and staffers along with the trust fund manager and investment advisers. GAO observed the RMI trust fund committee's September 2019 meeting. At the meeting, the committee received written information from the trust fund adviser that discussed issues associated with the distribution policy, fiscal procedures, and timing of the calculation of amounts available for disbursement, but the scheduled adviser presentation did not occur. At the meeting, an RMI representative on the RMI compact trust fund committee stated that any adjustments to the distribution policy and trust fund structure will be made as a result of government to government negotiation. The December 2019 trust fund committee meeting again included post-2023 issues on the agenda, but the committee did not take actions at that time.

Recommendation: The Secretary of the Interior should ensure that the Director of the Office of Insular Affairs, as Chairman of the RMI compact trust fund committee, works with other members of the committee to address the timing of the calculation of compact trust fund disbursements. (Recommendation 6)

Agency: Department of the Interior
Status: Open

Comments: Upon the report's publication, Interior concurred with our report's recommendations and stated that discussions to address them are ongoing within the trust fund committees. In July 2018, Interior stated that the trust fund committees have been discussing options for ensuring that the timing of the calculation of compact trust fund disbursements align with the budget process of the RMI and that, of the options reviewed thus far, using a multi-year rolling average was the favored option. Interior added that the final determination on the timing of the calculation of the trust fund disbursements will be addressed in the distribution policy. Interior set a target date for implementation of the recommendation to develop a distribution policy of October 1, 2023. In February 2019, Interior stated that discussions about policies and controls were frequent and ongoing among Committee members and staffers along with the trust fund manager and investment advisers. GAO observed the RMI trust fund committee's September 2019 meeting. At the meeting, the committee received written information from the trust fund adviser that discussed issues associated with the distribution policy, fiscal procedures, and timing of the calculation of amounts available for disbursement, but the scheduled adviser presentation did not occur. At the meeting, an RMI representative on the RMI compact trust fund committee stated that any adjustments to the distribution policy and trust fund structure will be made as a result of government to government negotiation. The December 2019 trust fund committee meeting again included post-2023 issues on the agenda, but the committee did not take actions at that time.

Recommendation: The Secretary of Transportation should develop an evaluation plan for the Infrastructure for Rebuilding America (INFRA) program in advance of issuing the notice of funding opportunity and ensure the program's evaluation plan clearly defines how all review teams should apply criteria, assess applications, and assign ratings to ensure that all applications are consistently reviewed. (Recommendation 1)

Agency: Department of Transportation
Status: Open

Comments: In 2019, we found that DOT's evaluation plan for the INFRA 2017-2018 round of funding was not finalized prior to DOT's issuance of the notice of funding opportunity. In addition, we raised concerns with a lack of documentation outlining why members of the INFRA senior review team followed up with some applicants over others. DOT told us that, for the fiscal year 2020 INFRA awards, it plans to provide information in the Notice of Funding Opportunity and evaluation plan explaining under the circumstances under which additional information may be sought from applicants. DOT stated that it plans to complete these actions by March 2020. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Transportation should ensure all program applicants be notified in writing of the outcomes of the application selection process. For unsuccessful applicants, the notification should include a brief explanation of the decision. (Recommendation 2)

Agency: Department of Transportation
Status: Open

Comments: DOT officials told us that they formally notified unsuccessful INFRA applicants of selection decisions via email and offered applicants the chance to schedule a debriefing with DOT officials. As of January 2020, we are assessing DOT's actions.

Recommendation: The Secretary of Transportation should require INFRA program teams document their decision-making rationale throughout all levels of review in the application selection process. (Recommendation 3)

Agency: Department of Transportation
Status: Open

Comments: In 2019, we again raised concerns with the lack of documentation outlining DOT's rationale for its INFRA award decisions, as well as a lack of documentation regarding why members of the senior review team followed-up with some applicants over others. DOT stated that it would work to address these issues by updating its internal guidance. We will continue to monitor DOT's actions.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to expand its performance measures for the 21st Century program to address all program objectives. Specifically, Education should establish performance measures related to key behavioral, including student attendance and disciplinary incidents, and socio-emotional outcomes.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with our recommendations; rather, it generally noted that it will keep our recommendations in mind as it continues to implement changes in the program as a result of ESSA. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to conduct federal-level data checks on the accuracy of 21st Century program data submitted by states. Such checks could test for logical relationships between fields. Education should also publicly disclose and address any data limitations it identifies, as appropriate.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but stated that it was taking some actions to enhance program data. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to provide written, non-regulatory guidance to states on developing and conducting high-quality 21st Century state evaluations to help address the difficulties states face in measuring program performance and effectiveness.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but identified steps it plans to take to implement it. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to use the information it collects from its monitoring visits and ongoing interactions with states to share effective practices across states for sustaining their 21st Century programs once program funding ends. This information could be shared using existing mechanisms such as Education's meetings with 21st Century state coordinators.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but identified steps it plans to take to implement it. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should ensure that CNCS completes its efforts to benchmark its assessment criteria and scoring process to further develop a risk-based approach to grant monitoring and that information from this effort is used to (a) score the indicators so that the riskiest grants get the highest scores; (b) revise the assessment indicators to meaningfully cover all identifiable risks, including fraud and improper payments; and (c) document decisions on how indicators are selected and weighted.

Agency: Corporation for National and Community Service
Status: Open

Comments: CNCS has been working since September 2018 to review and update its risk assessment process. The CNCS Office of Research and Evaluation has developed a methodology to determine the appropriate score and weight for the assessment indicators. It plans to fully implement the new risk assessment process in fiscal year 2020. To close this recommendation, CNCS will need to show documentation for how it selected and weighted revised indicators to cover identifiable risks, and how the revised scoring system identifies the riskiest grants.

Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should review monitoring protocols, including the level of information collected for oversight of subrecipients' activities such as criminal history checks, and enhance protocols, as appropriate.

Agency: Corporation for National and Community Service
Status: Open

Comments: As of July 2019, CNCS stated that revisions to the agency-wide risk assessment instrument include indicators to address prime grantee monitoring and oversight of subrecipients. CNCS established a new Office of Monitoring in 2019, which will be responsible for reviewing and improving monitoring protocols, including those related to subrecipient activities. Enhanced monitoring protocols will be implemented as part of its fiscal year 2020 monitoring plan. To help close this recommendation, CNCS will need to show how it has expanded information it collects pertaining to subrecipients, and how its monitoring efforts reflect this.

Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should establish activities to systematically evaluate grant monitoring results.

Agency: Corporation for National and Community Service
Status: Open

Comments: In July 2019, CNCS reported that the new Office of Monitoring supports the agency's May 2018 Transformation and Sustainability Plan goals related to monitoring and evaluating results. This office is developing a monitoring strategy to align with the agency's IT system improvements, and will allow for reporting and data to support a systematic evaluation of grant monitoring results. To help close this recommendation, CNCS will need to show how the agency has used outcomes and findings from its grant monitoring activities to help guide improvements to these activities.

Recommendation: To improve CNCS's efforts to move toward a risk-based process for monitoring grants and to improve its capacity for monitoring grantee compliance, the Chief Executive Officer of the Corporation for National and Community Service should, as part of CNCS's efforts to develop an employee development program, update critical competencies for grant monitoring, and establish a training planning process linked with agency goals and these competencies.

Agency: Corporation for National and Community Service
Status: Open

Comments: As of July 2019, CNCS is in the process of realigning its grant management and monitoring functions. The agency plans to document critical competencies for grant management and monitoring roles and establish a training program to strengthen its grant monitoring performance. By December 2019, CNCS plans to implement a comprehensive orientation curriculum and a more effective onboarding procedure, updated staff support training materials, among other changes to its training efforts. To close this recommendation, CNCS will need to determine which competencies are critical for grant monitoring, and show how the competencies are linked with the agency's training planning processes and agency goals.

Recommendation: Given DOT's new discretionary grant programs and similar challenges we have found with previous DOT programs, the Secretary of Transportation should issue a directive that governs department-wide and modal administration discretionary grant programs. Such a directive should include requirements to: (1) develop a plan for evaluating project proposals in advance of issuing a notice of funding availability that defines the stages of the process, including how the process will be overseen to ensure a consistent review of applications; (2) document key decisions, including the reason for any rating changes and the officials responsible for those changes, and how high-level concerns raised during the process were addressed; and (3) align stated program purpose and policy priorities with the evaluation and selection process.

Agency: Department of Transportation
Status: Open
Priority recommendation

Comments: DOT concurred with this recommendation and, in March 2019, issued a memo directing secretarial offices and operating administrations involved in awarding discretionary grants to implement our recommendations and to include them in their policies and procedures. In June 2019, we reported that, due to a number of issues, it is unclear how this action will address our recommendation. For example, we found that the memo was essentially limited to a repetition of our recommendation and that DOT did not take steps to ensure that the various affected offices consistently interpret and implement the recommendation. DOT officials told us they wanted to provide the affected offices flexibility to implement the recommendation, but that the Department would assess the need for additional guidance based on revisions to its Financial Assistance Guidance Manual. DOT completed these revisions effective January 2020, and all affected offices are expected to complete developing their policies and procedures by May 2020. We will continue to monitor the Department's actions and assess the extent to which they address our recommendation.