U.S. Department of Justice
Office of the Inspector General
MANAGEMENT AND ADMINISTRATION OF
THE COMMUNITY ORIENTED POLICING
SERVICES GRANT PROGRAM
Michael R. Bromwich
* * * * *
TABLE OF CONTENTS
FINDINGS AND RECOMMENDATIONS
Redeployment Under MORE Grants
Retention of Officer Positions After Grants Expire
Supplanting of Local Funds
Program Management By COPS
Financial Management By OJP
STATEMENT ON MANAGEMENT CONTROLS
STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS
APPENDIX I - OBJECTIVES, SCOPE AND METHODOLOGY
APPENDIX II - SCHEDULE OF DOLLAR-RELATED FINDINGS
APPENDIX III - COPS REPORT FINDINGS BY LOCATION - Large
Medium Grantees (Cont'd)
Small Grantees (Cont'd) and Indian Tribes
APPENDIX IV - PRIOR REPORTS
APPENDIX V COPS
AND OJPS RESPONSE TO DRAFT REPORT
Hyperlink to Response to Recommendations
Hyperlink to COPS/OJP Comments to OIG's Summary Report
Issued in April 1999
APPENDIX VI OIGS ANALYSIS AND SUMMARY OF ACTIONS NECESSARY TO CLOSE REPORT
APPENDIX VII OIGS ANALYSIS OF COPS/OJP COMMENTS TO OIGS SUMMARY REPORT ISSUED IN APRIL 1999
This program audit reviewed the Department of Justice's Office of Community Oriented Policing Services' (COPS) and Office of Justice Programs' (OJP) administration of the $8.8 billion community policing grant programs. After presenting background about the COPS program, we summarize our findings and recommendations in three major areas: (1) COPS' ability to meet the President's goal to put 100,000 additional police officers on the street by FY 2000, (2) COPS' and OJP's monitoring of grantees, and (3) the quality of guidance provided to grantees to assist them in implementing essential grant requirements.
In 1994, the President pledged to put 100,000 additional police officers on America's streets to promote community participation in the fight against crime. He subsequently signed the Violent Crime Control and Law Enforcement Act of 1994 (Crime Act), authorizing the Attorney General to implement over six years an $8.8 billion grant program for state and local law enforcement agencies to hire or redeploy 100,000 additional officers to perform community policing.
The Attorney General established the COPS Office to administer the grant programs and to advance community policing across the country. Management of the COPS grants entails both program and financial management. The COPS Office is responsible for: (1) developing and announcing grant programs, (2) receiving and reviewing applications, (3) deciding which grants to award, and (4) monitoring programmatic issues related to grants. OJP is responsible for financial management of the COPS program and is charged with: (1) reviewing pre-award and post-award financial activity, (2) reviewing and approving grant budgets, (3) providing financial management assistance after COPS has made an award, (4) disbursing federal funds to grantees, and (5) financial monitoring of COPS awards.
In order to meet the President's goal of putting 100,000 additional police officers on the street, COPS developed six primary hiring and redeployment grant programs for state and local law enforcement agencies. Hiring grants fund the hiring of additional police officers and generally last for three years. Redeployment grants are generally one-year grants and fund the costs of equipment and technology, and support resources (including civilian personnel) to redeploy existing officers from administrative duties to the streets. At the end of the grant periods, the state or local entity is expected to continue funding the new positions, or continue the redeployment of officers into community policing that resulted from grant funded equipment and technology purchases.
According to COPS, as of February 1999, COPS and OJP had awarded approximately $5 billion in grants under the six programs to fund the hiring or redeployment of more than 92,300 officers, of which 50,139 officers had been hired and deployed to the streets. COPS obtains its "on the street" officer count by periodically contacting grantees by telephone.
In April 1999, we issued a report summarizing the results of 149 audits of COPS grantees that we performed during fiscal years 1997-98 (See "Police Hiring and Redeployment Grants: Summary of Audit Findings and Recommendations, October 1996 - September 1998 (No. 99-14)). A response by the COPS Office and OJP to the OIGs summary report was included as Appendix V. At the time the summary report was released, the OIG was in the final stage of completing this program audit of the COPS Offices management of the $8.8 billion COPS grant program. Findings from the 149 individual grantee audits contributed to several of our findings and recommendations in this program audit.
The COPS Office strongly disagrees with our reliance on individual grantee audit reports and our interpretation of these findings in this program audit. Specifically, the COPS Office asserts that we misinterpreted and/or misapplied the COPS Offices compliance standards in the areas of supplanting, retention, community policing, and redeployment. We dispute the COPS Offices disagreements with our audit findings and this dispute is now the subject of an ongoing audit resolution process chaired by the Deputy Attorney General.
II. Summary of Findings
A. Progress Towards Goal of 100,000 New Police Officers
The first objective of our audit was to assess COPS' progress in achieving its stated goal. We found that COPS has not been consistent with respect to when the 100,000 additional officers funded by the Crime Act will be "on the street." During the course of this audit, COPS officials informed us that their goal is to fund i.e., to have approved grant applications for 100,000 new officers by the end of FY 2000. COPS disclaimed a goal of having the 100,000 new officers hired and actually deployed to the streets by the end of FY 2000, even though this goal has been stated by COPS Office publications and Department reports, and in speeches by Administration officials.1
Clearly, the COPS grants will not result in 100,000 additional officers on the streets by the end of FY 2000. Based on projections by the COPS Office, only 59,765 of the additional officers will be deployed by the end of FY 2000.
We are also not certain that the COPS Office will be able to "fund" 100,000 officers by the end of FY 2000 as that term is commonly understood. COPS counts an officer as funded when it approves the grantees' application for award of the grant, instead of when the grantee actually accepts the grant. While COPS projects in its FY 2000 budget that it will fund 107,019 additional officers by that time, our audit findings raise serious questions about whether several thousands of these "funded" officers that are currently counted toward COPS' goal will ever materialize.
According to COPS, there are considerable delays between the time grants are awarded by COPS and when new officers are hired and deployed by grantees. In our judgment, improvements are needed in program management to ensure that 100,000 additional officers are funded and eventually deployed. We reached our conclusion because:
B. Controls Over Monitoring of Grantees
A variety of regulations require recipients of federal funds be monitored to ensure proper use of the funds. To this end, the COPS Office and OJP require each grantee to periodically file various progress reports that are important to help monitor compliance with grant conditions.3
We determined that many grantees did not submit the required monitoring reports to
COPS. In a review of grant files for a randomly selected sample of 200 grantees, we found
that the following progress reports were not submitted to COPS or OJP at the time of our
PROGRESS REPORT ANALYSIS
|ANNUAL DEPARTMENT||159||62||39 %|
|OFFICER PROGRESS||159||64||40 %|
|MORE PROGRESS||38||16||42 %|
|PHS PROGRESS||3||0||0 %|
These reports are critical for COPS to monitor key grant conditions such as supplanting and retention of officers. Given the significant number of grantees that had not submitted the required reports, COPS needs to increase its monitoring efforts to ensure that reports are submitted.
The COPS Office has increased its efforts to monitor grantees by creating a Grant Monitoring Division that conducts site visit reviews of selected grantees. While we encourage such proactive efforts, we found that the reviews did not consistently cover all grant conditions and were not adequately followed up to ensure that all identified deficiencies were corrected. During the audit, the COPS Office revised its site visit protocol, which should address the shortcomings identified in our audit and hired a Financial Officer to improve the financial controls over the grants.
With respect to financial controls, we found that many grantees either did not submit the required financial reports to OJP or submitted them late. We reviewed the grant files and OJP's financial tracking system records for 200 randomly selected grants. For the 200 grants, 2,074 quarterly financial reports should have been submitted to OJP from the beginning of the grants to the quarter ending December 31, 1997.4 However, the grantees had not submitted 649 (31 percent) of the required reports. Moreover, the grantees submitted 493 (35 percent) of the remaining 1,425 reports late.
C. Guidance to Grantees
From October 1996 through September 1998, we conducted 149 audits of individual COPS grantees. Our findings suggest that, in addition to better monitoring by both the COPS Office and OJP, COPS guidance to grantees could be improved to ensure that critical grant requirements are understood and met. Specifically, COPS needs to better define its requirements for non-supplanting, allowable and unallowable costs, redeployment, officer retention, community policing, and progress reporting. The COPS Office has recognized these weaknesses and has hired a contractor to develop better guidance to grantees about these critical issues.
In response to the issues raised during the audit, the COPS Office has taken essential first steps to address identified weaknesses in grant program management and administration. COPS has not accepted our recommendation to discontinue counting officers as funded before the grantees accept the grants. However, as noted in the report, the COPS Office is taking action to follow up on unaccepted grants and to ensure more timely deobligation of grant funds when agencies do not accept grant awards. The COPS Office also has: (1) developed clearer guidance for grantees in critical areas of compliance; (2) increased the level of its monitoring efforts by creating a Grant Monitoring Division, which conducts site visits to monitor grantee compliance with critical grant requirements; and (3) hired a Financial Officer to improve its financial controls.
Finally, the COPS Office may have a continuing grant-making role beyond its goal of deploying 100,000 new officers by 2000. In his FY 2000 budget request, the President proposed a "21st Century Crime Bill" that includes $1.3 billion for Fiscal Year 2000 and $6.375 billion over the next five years "to help communities build on their successful efforts begun under the COPS program" by adding an additional 50,000 officers by 2005. The 21st Century Policing Initiative is intended to help communities hire, redeploy, and retain officers; give law enforcement access to the latest crime fighting technology; and engage the entire community in preventing and fighting crime.
Whether or not the 21st Century Policing Initiative is approved, a considerable amount of funds may be left over from the 1994 Crime Act authorization. Of the $8.8 billion authorized by the Crime Act, COPS estimated that $7.345 billion would be required to award grants to hire 97,920 officers for an average of $75,000 per officer. OJP's $150 million Police Hiring Supplement Program was to fund 2,080 officers toward the goal of 100,000 officers. As of February 1999, COPS and OJP had awarded about $5 billion in grants to hire or redeploy 92,324 officers at an average cost of $54,256 per officer. If the lower cost per officer trend continues, the total cost required to fund the 107,019 officers through FY 2000 would be about $5.8 billion. As such, almost $1.7 billion authorized under the Crime Act may not be needed, and could be used to help fund the 21st Century Community Policing Initiative if approved by Congress.
1 For example, the Attorney General's 1994 Annual Report states that "By 2000, all 100,000 [officers] will be hired and serving on the streets of America." In a July 9, 1998, COPS press release, the COPS Office described new grants for 473 officers as "the latest wave under the Clinton Administration initiative to put 100,000 additional officers on the beat in the year 2000." In addition, a White House press release issued December 14, 1998, quoted the President as saying, "We have achieved almost 90 percent of our pledge to put 100,000 additional cops on the street in community policing activities..." Finally, highlights from the President's FY 1999 budget state that "the final budget includes funds for 17,000 additional Community Oriented Police Services (COPS) Program police officers toward the President's goal of 100,000 cops on the beat by 2000."
2 As previously stated, we issued 149 audit reports of individual COPS grantees from October 1996 through September 1998. Because about two-thirds of our audits were referred to us by COPS or OJP as potential problem grantees, they may not be representative of the universe of grantees. See "Police Hiring and Redeployment Grants: Summary of Audit Findings and Recommendations, October 1996 September 1998 (No. 99-14)," which is available on our internet site: http://www.usdoj.gov/oig. Also, see Finding III of this report for additional details.
3 COPS requires grantees to file: (1) a Department Initial Report, (2) annual Officer Progress Reports, (3) a MORE Progress Report (if applicable), and (4) a Department Annual Report. OJP requires grantees to submit quarterly Financial Status Reports detailing information on grant obligations and expenditures.
4 OJP's policy is to withhold payment to grantees if the grantee is delinquent in submitting financial reports at the time the payment is requested. For the 200 randomly selected grants that we reviewed during this audit, we found no indication that OJP released funds to grantees during periods in which the grantees were delinquent in submitting financial reports.