Since the program’s inception in 1997, ONDCP has delegated certain grant  administration activities to other agencies through inter-agency  agreements. In fiscal year 2005, ONDCP administered the program with  SAMHSA. Furthermore,  ONDCP instituted procedures for screening grant applications that did not  ensure that all renewal grantees met statutory eligibility requirements. Because ONDCP did not conduct ongoing  monitoring, the agency increased its risk that it could not provide  reasonable assurance that SAMHSA was conducting grant activities, such  as eligibility screening, according to ONDCP’s expectations. Documentary evidence was missing from 47 of the 66 grant files (71  percent) we reviewed. Specifically, our review of an example of eligibility screening sheets used  for fiscal years 2005 and 2006, and our file review of 19 initial grantee  applications for fiscal year 2005 where eligibility screening sheets were  present, found that the eligibility criteria delineated in the screening sheets  used by ONDCP and SAMHSA officials to determine whether an applicant  was an eligible coalition omitted some of the statutory eligibility criteria. ONDCP  implemented a separate screening process, not described in the funding  announcement, for initial and renewal grant applicants 1 month before the  fiscal year 2005 grant awards were to be announced, including the  introduction of a criterion that grant applicants could not propose to use  over a certain percentage of grant funds for direct services. Lack of fully defined roles and responsibilities and  documented procedures to follow for eligibility screening hampered the  efforts of ONDCP and SAMHSA to effectively manage the grant-making  process. However, the inter-agency  agreement for fiscal year 2005 did not fully articulate roles and  responsibilities for ONDCP’s management of SAMHSA, such as the role of  SAMHSA in screening renewal grant applicants for eligibility, and for the  grant program overall. ONDCP Has Taken Steps to Better Manage the Grant- Making Process, but These Efforts Can Be Strengthened

Since fiscal year 2006, ONDCP has taken steps to strengthen its  management of the grant-making process by establishing senior-level  management groups to address collaboration and monitoring issues,  eliminating its use of the direct services eligibility criterion in response to  reauthorizing legislation, and clarifying grant program roles and  responsibilities. However, as  of fiscal year 2007, ONDCP had not yet put in place mechanisms to ensure  that documentation of eligibility screening were included in grant files, as  called for by internal control standards. Without doing so, confusion  over managing the program could continue to occur. Conclusions

For fiscal years 2005 and 2006, ONDCP and SAMHSA did not adhere to key  federal internal controls standards in the federal government and did not  meet all statutory requirements in administering the Drug-Free  Communities Support grant program. Develop and document its approach to monitoring and overseeing  SAMHSA and the program as a whole. 2. 3. We  continue to believe that this recommendation remains valid because,  without defined oversight activities for ensuring successful completion of  the work across all activities, ONDCP increases its risk that it cannot  provide reasonable assurance that required tasks are being performed in  accordance with its directives. Concerning our second recommendation that ONDCP ensure that the  coalitions receiving an initial grant or a renewal grant satisfy all of the  statutory eligibility criteria for each fiscal year and that these decisions are  fully documented, the ONDCP Director noted that they have taken steps to  ensure that all renewal applicants are screened for eligibility, consistent  with our recommendation, and documentation related to screening  applicants is maintained in grant files. Key contributors to this report are listed in appendix V.

Appendix I: Scope and Methodology

To examine the extent to which Office of National Drug Control Policy  (ONDCP) and the Substance Abuse and Mental Health Services  Administration (SAMHSA) conducted its screening and grant-related  activities for the Drug-Free Communities Support Program in accordance  with standards for internal control in the federal government, established  laws, and leading practices for collaborating agencies, we reviewed  available program documents, including, but not limited to, the Request  for Applications funding announcements; the inter-agency agreements  between ONDCP and SAMHSA, and the documented outcomes of specific  review activities and recommendations for grant funding decisions. Internal controls and the definition of  internal control in OMB Circular A-123 are based on GAO’s Standards for  Internal Control in the Federal Government.
Why GAO Did This Study

Twenty-five percent of American students ages 13-17 reported using illicit drugs in 2007. The Drug-Free Communities Support Program provides grants to community coalitions involved in reducing youth substance abuse. The Office of National Drug Control Policy (ONDCP) administers the program. ONDCP selected the Substance Abuse and Mental Health Services Administration (SAMHSA) to operate the grant program in fiscal year 2005. In 2005, ONDCP did not award grants to some coalitions who had previously received grant funds (renewal grantees). GAO was asked to assess (1) the extent to which ONDCP and SAMHSA administered grant-related activities for fiscal years 2005 and 2006 consistent with federal internal control standards, statutory requirements, and other guidance and (2) the steps ONDCP has taken since 2006 regarding its administration of grant-related activities. GAO analyzed and compared program documents and grant activities to established guidance, such as federal internal control standards and statutory requirements, and interviewed key program management officials.

What GAO Found

In fiscal years 2005 and 2006, ONDCP and SAMHSA did not always adhere to applicable federal internal control standards, statutory requirements, and other guidance during the grant-making process. Standards for internal control in the federal government call for agencies to conduct ongoing monitoring of a program's performance, but ONDCP did not conduct such monitoring of SAMHSA or the program overall. Thus, ONDCP increased its risk of not providing reasonable assurance that SAMHSA conducted grant activities, such as eligibility screening. Internal control standards also require that agencies maintain documentation that grant applicants met eligibility requirements each fiscal year. While SAMHSA officials said that they screened all renewal grantees for eligibility in 2005 and ONDCP officials said they screened all initial grantees in 2006, documentation indicating that such screening had occurred was missing from 47 of the 66 grantee files GAO reviewed. ONDCP also lacked a process to ensure that all renewal applicants met statutory eligibility requirements. For example, ONDCP used a separate screening process in fiscal year 2005 that included a criterion that grantees limit funding for direct services, such as enrolling individuals in a drug prevention program. Only renewal grant applicants that met this or one of two other criteria underwent further screening for statutory eligibility. As a result, ONDCP funded about 86 percent of renewal grantees in 2005 without ensuring that they met the statutory eligibility criteria. Leading practices for collaborating agencies call for strategies to ensure common outcomes. However, the inter-agency agreement between ONDCP and SAMHSA did not fully define roles and responsibilities and lacked specific guidance to SAMHSA on eligibility screening. As a result, confusion occurred over issues, such as the eligibility criteria to apply, hampering the two agencies in their efforts to effectively manage the grant-making process. Since 2006, ONDCP has addressed some of the issues described above, by (1) clarifying its role for the program in its 2007 agreement with SAMHSA, (2) establishing management groups to address monitoring issues, and (3) eliminating its use of the direct services eligibility criterion. However, some internal control and other challenges remain. For example, ONDCP has not yet put a mechanism in place to ensure that documentation confirming eligibility is maintained in the grant files. ONDCP also has not documented its approach to overseeing SAMHSA and the program. Without defined oversight activities for ensuring completion of the work, ONDCP lacks reasonable assurance that required tasks are being performed in accordance with management's directives. Also, roles and responsibilities for key elements of grant administration remain largely undefined in that the agencies have not clarified certain services SAMHSA is to provide related to awarding grants or the role of the program Administrator. Without defining these roles, confusion on the steps to follow in managing the program could continue to occur. Finally, as in 2006, ONDCP officials told GAO that they did not screen renewal grant applicants for eligibility in 2007 because the screening that applicants undergo when they first receive a grant is sufficient.