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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

December 2014: 

Grant Program Consolidations: 

Lessons Learned and Implications for Congressional Oversight: 

GAO-15-125: 

GAO Highlights: 

Highlights of GAO-15-125, a report to congressional requesters. 

Why GAO Did This Study: 

GAO has previously reported that consolidations may help increase the 
effectiveness and efficiency of government programs. 

GAO was asked to review grant program consolidations in regard to 
reducing overlap and duplication. This report: (1) describes 
approaches taken to grant programs that have been consolidated from 
fiscal year 1990 through 2012, (2) examines federal, state and local 
actions taken to administer the programs, and (3) analyzes lessons 
learned for future consideration of grant program consolidations. 

GAO reviewed literature on grant program consolidations. For this 
review GAO selected three case study grant program consolidations, the 
TA and CoC programs, and the National Environmental Performance 
Partnership System. GAO conducted interviews with state and local 
officials in Colorado, Delaware, Florida, and Massachusetts. GAO 
selected these states and localities based on several selection 
criteria, such as state participation and funding. The selected 
locations and grant program consolidations are not generalizable, but 
they provided important insights about grant consolidations. 

What GAO Found: 

Consolidations from fiscal years 1990 through 2012. There is no 
authoritative, accurate tally of enacted grant program consolidations. 
In addition, there is no commonly accepted definition of what 
constitutes a grant program consolidation. From a variety of sources, 
GAO identified 15 grant program consolidations during this period. 
Most of these consolidations either combined a number of grant 
programs used for specific activities (such as Shelter Plus Care), 
known as categorical grants, into a broader categorical grant, such as 
the Continuum of Care (CoC) program or established a Performance 
Partnership, which offers additional flexibility in using funds across 
multiple programs but maintains accountability for meeting certain 
performance measures. Block grant approaches to consolidation prior to 
1990 combined programs for broad purposes, such as work assistance. 
The more recent approaches, referred to as hybrid, often combine 
categorical grant programs and emphasize strong performance standards 
and accountability. Hybrid approaches can improve the efficiency of 
grant administration and may reduce fragmentation, overlap, and 
duplication. 

State and local government actions. State and local officials in the 
three case study consolidations GAO selected for review relied on 
existing grant management structures and established relationships to 
facilitate implementation of the grant program consolidations. In the 
Transportation Alternatives (TA) program the impact of the 
consolidation was delayed by states and local officials' reliance on 
carryover funds from predecessor grant programs while these funds were 
still available. Officials reported both benefits and challenges 
ranging from administrative flexibility such as lack of central 
oversight by states, lack of or inaccurate performance data, and 
conflicting reporting requirements. 

Lessons to consider. The key to any grant program consolidation 
initiative is identifying and agreeing on goals—-such as improved 
grant administration and changed programmatic outcomes-—and to design 
and plan for successful implementation, according to findings from the 
case studies and prior GAO reports. Grant consolidations offer the 
opportunity to improve grant administration by expanding the 
opportunities of narrowly targeted grants and by reducing 
fragmentation, overlap, and duplication. Consolidation initiatives 
that answer key questions can provide a data-driven consolidation 
rationale and show stakeholders that a range of alternatives has been 
considered. These evaluations should include responses to key 
questions such as the following: What are the goals of the 
consolidation? What opportunities will be addressed through the 
consolidation and what problems will be solved? 

GAO's prior work found that few executive branch agencies regularly 
conduct in-depth program evaluations to assess their programs' impact. 
The Office of Management and Budget (OMB), as the focal point for 
overall management in the executive branch, plays a key role in 
improving the performance of federal grant programs and has developed 
or contributed many tools to encourage improvements to federal grants 
and program performance. Agencies, the Congress—as well as grantees—
can benefit from guidance, which currently does not exist, to assist 
with identifying consolidation opportunities, particularly those 
requiring statutory changes, and developing consolidation proposals. 

What GAO Recommends: 

GAO recommends OMB develop guidance on identifying grant program 
consolidation opportunities and the analysis to improve their 
outcomes. GAO incorporated technical comments from the Environmental 
Protection Agency, Departments of Housing and Urban Development and 
Transportation, and OMB. 

View [hyperlink, http://www.gao.gov/products/GAO-15-125]. For more 
information, contact Susan J. Irving at (202) 512-6806 or 
irvings@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

While Few Grants Have Been Consolidated Since 1990, Hybrid Approaches 
Are Being Pursued: 

Consolidation Design Influenced State and Local Implementation and 
Dictated Impact on Any Existing Fragmentation, Overlap, or Duplication: 

Lessons Learned Can Inform Both the Design and Review of Grant Program 
Consolidations: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Summary of Grant Program Consolidations, Fiscal Year 1990 
through 2012 (Text for Interactive figure 3): 

Appendix II: Objectives, Scope, and Methodology: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Related GAO Products: 

Tables: 

Table 1: Government-wide and Program-Specific Grant Requirements: 

Table 2: Comparison of Eligible Applicants of the Predecessor Homeless 
Grant Programs and the Continuum of Care Program: 

Table 3: Performance Accountability Challenges Identified by State, 
Local and Federal Officials: 

Table 4: List of Consolidated Grant Programs and Selected 
Characteristics: 

Table 5: Summary of Selected States and Entities: 

Figures: 

Figure 1: Total Federal Outlays for Grants to State and Local 
Governments and Medicaid (in constant 2013 dollars), Fiscal Years 1980-
2013: 

Figure 2: Definitions of Fragmentation, Overlap, and Duplication: 

Figure 3: Summary of Grant Program Consolidations, Fiscal Years 1990 
through 2012: 

Abbreviations: 

ACIR: U.S. Advisory Commission on Intergovernmental Relations: 

AGA: Association of Government Accountants: 

CCDBG: Child Care and Development Block Grant: 

CCDBGA: Child Care and Development Block Grant Amendments: 

CFDA: Catalog of Federal Domestic Assistance: 

CoC: Continuum of Care Program: 

DOJ: Department of Justice: 

DOT: Department of Transportation: 

EPA: Environmental Protection Agency: 

ESG: Emergency Solutions Grant: 

FHWA: Federal Highway Administration: 

FFFIS: Federal Funds Information for States: 

HEARTH: Homeless Emergency Assistance and Rapid Transition to Housing 
Act: 

HUD: Department of Housing and Urban Development: 

MAP-21: Moving Ahead for Progress in the 21st Century Act: 

MPO: Metropolitan Planning Organization: 

NEPPS: National Environmental Performance Partnership System: 

NHS: National Highway System: 

OMB: Office of Management and Budget: 

OBRA: Omnibus Budget Reconciliation Act of 1981: 

PPA: Performance Partnership Agreement: 

PPG: Performance Partnership Grant: 

RTP: Recreational Trails Program: 

SAFETEA-LU: Safe, Accountable, Flexible, Efficient Transportation 
Equity Act: A Legacy for Users: 

SRTS: Safe Routes to School: 

STP: Surface Transportation Program: 

TA: Transportation Alternatives Program: 

TANF: Temporary Assistance to Needy Families: 

TE: Transportation Enhancement: 

[End of section] 

United States Government Accountability Office: 
GAO:
441 G St. N.W. 
Washington, DC 20548: 

December 12, 2014: 

The Honorable Thomas R. Carper: 
Chairman: 
The Honorable Tom Coburn, M.D. 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Claire McCaskill: 
Chairman: 
Subcommittee on Financial and Contracting Oversight: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

Grants play a significant role in implementing and funding federal 
programs: through such programs the federal government's network of 
grantors and grantees provides many services critical to the nation's 
interest. Grant programs help build and maintain our nation's 
infrastructure by funding highways, bridges, and mass transit systems. 
They also help care for the sick and economically disadvantaged by 
funding medical services, nutrition programs, and housing assistance. 
[Footnote 1] By leveraging the funds and expertise of entities within 
a granting network--which can involve federal, state, and local 
governments, as well as non-profits--these services can be delivered 
more efficiently. However, while the federal government and grant 
recipients often share common purposes, they have different 
perspectives. Although both are interested in efficiency and 
effectiveness, recipients' interest also includes seeking flexibility 
to be nimble and responsive to state and local priorities while 
minimizing grant-related administrative burden. For this reason, 
grants from the federal government must strike a balance between 
federal interests and priorities of the grant recipients. 

The federal government's use of grants to achieve national objectives 
has grown significantly in the last three decades. For example, from 
fiscal years 1980 to 2013, federal grant outlays to state and local 
governments increased from about $91 billion (about $224 billion in 
2013 constant dollars) to about $546 billion.[Footnote 2] In addition, 
governments at all levels--federal, state, and local--face long-term 
fiscal challenges which could affect both federal funding of 
intergovernmental programs and the potential capacity of state and 
local governments to help fund and implement these programs.[Footnote 
3] As the United States continues to experience federal budgetary 
constraints, there is increasing attention being paid to ensure that 
government resources--including those awarded through grants--are 
appropriately targeted. 

Since the early 1980s, various forms of grant program consolidations 
have been enacted and since that time there has also been substantial 
variation in how grant funding is structured as well as growth in both 
the level of funding and number of grant programs created. As a result 
of the growing diversity and complexity of grant funding and 
administration, policymakers have looked to grant program 
consolidation as a way to reduce complexity while assuring that the 
funds are used for the intended national purpose. 

We have previously reported that grant program consolidation can 
create opportunities to reassess federal programs in which the balance 
between costs and benefits received either do not (or no longer) 
justify federal spending.[Footnote 4] We have also reported that such 
program consolidations may reduce fragmentation, overlap, and 
duplication--which can lead to increased efficiency and to 
improvements in performance that significantly benefit taxpayers and 
beneficiaries alike.[Footnote 5] However, the extent to which 
consolidated grants have led to more streamlined operations or to 
gains in efficiency is not clear: we have previously identified the 
management of grant programs as a performance and accountability 
challenge.[Footnote 6] 

You asked us to identify what federal grant programs have been 
consolidated in the past, to examine whether duplication and overlap 
can be reduced by consolidating selected federal grant programs, and 
to assess what outcomes have occurred from prior consolidations in 
terms of savings or improved performance. This report (1) describes 
approaches taken to grant programs that have been consolidated from 
fiscal year 1990 through fiscal year 2012, (2) examines federal, 
state, and local actions taken to administer the selected case study 
consolidated grant programs, and (3) analyzes lessons learned for 
future consideration of grant program consolidations. 

For the first objective, we conducted an extensive literature review 
to identify a list of previously consolidated grant programs. From 
that review we developed a list that represents our best efforts to 
comprehensively identify all grants consolidated from fiscal year 1990 
through fiscal year 2012 (see figure 3)[Footnote 7] and we interviewed 
Office of Management and Budget (OMB) agency staff to discuss the 
multiple approaches by which some of these were consolidated. We 
selected 1990 because federal, state, and local officials working in 
these program areas may be more aware of the consolidations than 
consolidations that happened at or after this time than before 1990. 
For our second and third objectives, we conducted a case study review 
in four states (Colorado, Delaware, Florida, and Massachusetts) of 
three of the consolidated grant programs that we identified--the 
Transportation Alternatives program, Continuum of Care program, and 
National Environmental Performance Partnership System (NEPPS). We 
selected the Transportation Alternatives and Continuum of Care 
programs in part because they had been created from predecessor 
programs within the past six years; NEPPS was selected because the 
approach used to consolidate it was different than the other 
approaches. In each state we interviewed state and local program 
officials and reviewed relevant documents.[Footnote 8] To select the 
states, we reviewed agency documents and data for each program--such 
as state specific participation and funding--and considered other 
factors, such as states we have conducted prior grant work. We used a 
similar method to select localities in each state. The selected 
locations and grant program consolidations are not generalizable, but 
they provided us with important insights about grant consolidations. 
Appendix II contains further information about our objectives, scope, 
and methodology. 

We conducted this performance audit from September 2013 to December 
2014 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. 

Background: 

Grants constitute a form of federal assistance consisting of payments 
in cash or in kind for a specified purpose, allocated to a state or 
local government or to a nongovernmental recipient.[Footnote 9] By 
providing funding to state and local governments, grants are an 
important tool used by the federal government to achieve national 
objectives. When taken as a whole, federal grant programs are 
extremely diverse and complex. They vary widely in numerous ways, 
including size, the nature of the recipients, and the types of 
programs they fund. For example, grants range from relatively small 
dollar amounts, such as a research grant from the National Science 
Foundation for less than a couple of thousand dollars, to much larger 
dollar amounts, such as Medicaid grants to individual states, with 
outlays of about $265 billion in fiscal year 2013. Grant programs also 
vary in two important dimensions: (1) the amount of discretion given 
the recipient in determining how the funds will be used, and (2) the 
way they are allocated (or awarded). 

Grants generally are described as either block grants or categorical 
grants. Block grants are less restrictive and permit the use of funds 
for broader categories of activities, such as community development or 
public health. Block grants generally give greater discretion to 
recipients in identifying problems and designing programs to address 
those problems using grant funds. In contrast, categorical grants are 
the most restrictive, permitting funds to be used only for specific 
activities related to their purpose, such as for nutrition for the 
elderly. 

While the distinction between "block" and "categorical" grants is 
useful, it is important to recognize that in practice, the labels 
represent the ends of a continuum: in the middle range, the two types 
overlap considerably.[Footnote 10] The degree of discretion 
represented by the identified types of grants enables a different 
balance to be struck between the interests of the federal government --
that funds be used efficiently and effectively to meet specified 
national objectives--and the ability of grant recipients to use funds 
for those (approved) activities that best fit local priorities while 
also minimizing administrative burdens associated with accepting the 
grant. 

Grants Play a Significant Role in Funding and Advancing Federal 
Priorities: 

Over time, grant program funding has increased steadily, as Congress 
and federal grant-making agencies have created greater diversity and 
complexity in federal grants management. According to OMB, federal 
outlays for grants to state and local governments increased from $91.4 
billion in fiscal year 1980 (about $224 billion in 2013 constant 
dollars) to about $546 billion in fiscal year 2013, (see figure 1). 
[Footnote 11] 

Figure 1: Total Federal Outlays for Grants to State and Local 
Governments and Medicaid (in Constant 2013 Dollars), Fiscal Years 1980-
2013: 

[Refer to PDF for image: multiple line graph] 

Fiscal year: 1980; 
Nominal value: $223.7 billion; 
Adjusted for inflation (in 2013 dollars): $91.4 billion. 

Fiscal year: 1981; 
Nominal value: $211.1 billion; 
Adjusted for inflation (in 2013 dollars): $94.7 billion. 

Fiscal year: 1982; 
Nominal value: $183.9 billion; 
Adjusted for inflation (in 2013 dollars): $88.1 billion. 

Fiscal year: 1983; 
Nominal value: $184.8 billion; 
Adjusted for inflation (in 2013 dollars): $92.4 billion. 

Fiscal year: 1984; 
Nominal value: $188.3 billion; 
Adjusted for inflation (in 2013 dollars): $97.6 billion. 

Fiscal year: 1985; 
Nominal value: $197.8 billion; 
Adjusted for inflation (in 2013 dollars): $105.9 billion. 

Fiscal year: 1986; 
Nominal value: $205.2 billion; 
Adjusted for inflation (in 2013 dollars): $112.3 billion. 

Fiscal year: 1987; 
Nominal value: $193.7 billion; 
Adjusted for inflation (in 2013 dollars): $108.4 billion. 

Fiscal year: 1988; 
Nominal value: $199.6 billion; 
Adjusted for inflation (in 2013 dollars): $115.3 billion. 

Fiscal year: 1989; 
Nominal value: $203.0 billion; 
Adjusted for inflation (in 2013 dollars): $121.9 billion. 

Fiscal year: 1990; 
Nominal value: $217.4 billion; 
Adjusted for inflation (in 2013 dollars): $135.3 billion. 

Fiscal year: 1991; 
Nominal value: $239.7 billion; 
Adjusted for inflation (in 2013 dollars): $154.5 billion. 

Fiscal year: 1992; 
Nominal value: $269.6 billion; 
Adjusted for inflation (in 2013 dollars): $178.1 billion. 

Fiscal year: 1993; 
Nominal value: $28.6 billion; 
Adjusted for inflation (in 2013 dollars): $193.6 billion. 

Fiscal year: 1994; 
Nominal value: $304.9 billion; 
Adjusted for inflation (in 2013 dollars): $210.6 billion. 

Fiscal year: 1995; 
Nominal value: $319.0 billion; 
Adjusted for inflation (in 2013 dollars): $225.0 billion. 

Fiscal year: 1996; 
Nominal value: $317.0 billion; 
Adjusted for inflation (in 2013 dollars): $227.8 billion. 

Fiscal year: 1997; 
Nominal value: $320.2 billion; 
Adjusted for inflation (in 2013 dollars): $234.2 billion. 

Fiscal year: 1998; 
Nominal value: $332.5 billion; 
Adjusted for inflation (in 2013 dollars): $246.1 billion. 

Fiscal year: 1999; 
Nominal value: $357.3 billion; 
Adjusted for inflation (in 2013 dollars): $267.9 billion. 

Fiscal year: 2000; 
Nominal value: $373.6 billion; 
Adjusted for inflation (in 2013 dollars): $285.9 billion. 

Fiscal year: 2001; 
Nominal value: $406.5 billion; 
Adjusted for inflation (in 2013 dollars): $318.5 billion. 

Fiscal year: 2002; 
Nominal value: $443.2 billion; 
Adjusted for inflation (in 2013 dollars): $352.9 billion. 

Fiscal year: 2003; 
Nominal value: $478.8 billion; 
Adjusted for inflation (in 2013 dollars): $388.5 billion. 

Fiscal year: 2004; 
Nominal value: $490.1 billion; 
Adjusted for inflation (in 2013 dollars): $407.5 billion. 

Fiscal year: 2005; 
Nominal value: $499.0 billion; 
Adjusted for inflation (in 2013 dollars): $428.0 billion. 

Fiscal year: 2006; 
Nominal value: $490.2 billion; 
Adjusted for inflation (in 2013 dollars): $434.1 billion. 

Fiscal year: 2007; 
Nominal value: $487.9 billion; 
Adjusted for inflation (in 2013 dollars): $443.8 billion. 

Fiscal year: 2008; 
Nominal value: $496.8 billion; 
Adjusted for inflation (in 2013 dollars): $461.3 billion. 

Fiscal year: 2009; 
Nominal value: $572.7 billion; 
Adjusted for inflation (in 2013 dollars): $538.0 billion. 

Fiscal year: 2010; 
Nominal value: $642.0 billion; 
Adjusted for inflation (in 2013 dollars): $608.4 billion. 

Fiscal year: 2011; 
Nominal value: $627.6 billion; 
Adjusted for inflation (in 2013 dollars): $606.8 billion. 

Fiscal year: 2012; 
Nominal value: $553.2 billion; 
Adjusted for inflation (in 2013 dollars): $544.6 billion. 

Fiscal year: 2013; 
Nominal value: $546.2 billion; 
Adjusted for inflation (in 2013 dollars): $546.2 billion. 

Source: GAO analysis of OMB data. GAO-15-125. 

[End of figure] 

Overview of the Federal Process for Grant Program Consolidations: 

Consolidation rationale: Prior research by the former U.S. Advisory 
Commission on Intergovernmental Relations (ACIR) [Footnote 12] 
indicated that there are two instances where it may be suitable to 
consolidate categorical grant programs: 

* when categorical programs are too small to have much impact or to be 
worth the cost of administration; and: 

* when multiple programs exist in functional areas (including health, 
education, and social services) that have a large number of programs, 
or are in functional areas (including justice, natural resources, and 
occupational health and safety) where there is fragmentation. 

The proliferation of grant programs can increase problems related to 
fragmentation, overlap, and duplication (see figure 2 for our 
definition of these terms, based on our related framework). As we have 
previously reported, program consolidations may help address these 
problems.[Footnote 13] Consolidations also have the potential to 
improve the effectiveness and performance of federal assistance 
programs by simplifying grant administration and facilitating 
coordination among grant recipients. 

Figure 2: Definitions of Fragmentation, Overlap, and Duplication: 

[Refer to PDF for image: illustration] 

Fragmentation: 
Fragmentation refers to those circumstances in which more than one 
federal agency (or more than one organization within an agency) is 
involved in the same broad area of national need and opportunities 
exist to improve service delivery. 

Overlap: 
Overlap occurs when multiple agencies or programs have similar goals, 
engage in similar activities or strategies to achieve them, or target 
similar beneficiaries. 

Duplication: 
Duplication occurs when two or more agencies or programs are engaged 
in the same activities or provide the same services to the same 
beneficiaries. 

Source: GAO. GAO-15-125. 

[End of figure] 

Approaches for consolidation: For purposes of this report we 
classified consolidations as employing either a block grant approach 
or a hybrid approach. 

* A block grant approach is generally broad in scope. It is intended 
to increase state and local flexibility and generally give recipients 
greater discretion to identify problems or to design programs 
addressing those problems using funding from the grant. Block grants 
funds are provided through less restrictive, broader categories of 
activities, such as community development or public health. 

* Hybrid approaches can consolidate a number of narrower categorical 
programs while retaining strong standards and accountability for 
discrete federal performance goals. Hybrid approaches may also include 
Performance Partnerships, offer additional flexibility in using funds 
across multiple programs but are held accountable for meeting certain 
performance measures. They do so by giving grantees the flexibility to 
pool discretionary funds across multiple federal programs (or 
agencies) serving similar populations and communities, in exchange for 
greater accountability for results. The pooling of discretionary funds 
is also referred to as "blended" funding.[Footnote 14] 

Legislative authority: These grant program consolidations require 
legislative authorization. Federal agencies do not have inherent 
authority to consolidate grant programs or to enter into grant 
agreements without affirmative legislative authorization. In 
authorizing grant programs, federal laws identify the types of 
activities that can be funded and the purposes to be accomplished 
through the funding. Frequently, legislation establishing a grant 
program will define the program objectives and leave the administering 
agency to fill in the details by regulation. Grant programs are 
typically subject to a wide range of accountability requirements under 
their authorizing legislation or appropriation and implementing 
regulations: this is done so that funding is spent for its intended 
purpose.[Footnote 15] In addition, grant programs are subject to cross-
cutting requirements applicable to most assistance programs (see table 
1 for more information). 

Table 1: Government-wide and Program-Specific Grant Requirements: 

Specific to individual grant programs: 
Grant-making agency: 
Grant program's authorizing statute; 
Appropriation act providing funding for grant program; 
Grant recipient: 
Grant program regulations issued by grant-making agency; 
Grant agreement (terms and conditions). 

Applicable to all grant programs: 
Grant-making agency: 
Government-wide funding requirements; 
Executive orders and Office of Management and Budget guidance on 
grants management; 
Grant recipient: Government-wide grant regulations: 
(1) Administrative requirements ("common rule"); 
(2) Cost principles; 
(3) Drug-free workplace; 
(4) Suspension and debarment; 
(5) Anti-lobbying requirements; 
(6) Audit and reporting requirements. 

Source: GAO. GAO-15-125. 

[End of table] 

Characteristics and Lessons From the 1980s Grant Program 
Consolidations: 

The Omnibus Budget Reconciliation Act of 1981 (OBRA)[Footnote 16] 
consolidated several dozen categorical grant programs (and three 
existing block grants) into nine block grants covering health and 
human services, education, community services and development, and 
energy assistance.[Footnote 17] These block grants from the 1980s were 
designed to be more detailed in their reporting and auditing 
provisions but had fewer kinds of planning and spending restrictions 
than earlier block grants. For example, OBRA provisions of general 
applicability impose reporting and auditing requirements, and require 
states to conduct public hearings as a prerequisite to receiving funds 
in any fiscal year.[Footnote 18] In addition, several of the OBRA 
programs include such items as limitations on allowable administrative 
expenses,[Footnote 19] prohibitions on the use of funds to purchase 
land or construct buildings, "maintenance of effort" provisions, and 
anti-discrimination provisions. Applicable restrictions are not 
limited to those contained in the program statute itself--other 
federal statutes applicable to the use of grant funds must also be 
followed. In turn, these additional restrictions may impose legal 
responsibilities on grantees. Thus, the block grant mechanism does not 
totally remove federal involvement, nor does it permit the 
circumvention of federal laws applicable to the use of grant funds. In 
this latter respect, a block grant is legally no different from a 
categorical grant. 

As a result of the 1981 block grants, the states' role in grants 
administration changed in a number of ways. As we previously reported, 
four themes capture these actions (see text box). 

Text box: 

Lessons Learned from States' Experience of 1981 Block Grants: 

Fiscal strategies. States used block grants to adopt fiscal strategies 
in response to federal funding changes. These strategies included the 
ability to continue using prior categorical grant funds, to transfer 
funds among certain block grants, and to use their state funds to help 
offset federal cuts. 

Programmatic discretion. Block grants reduced the federal role in 
several domestic assistance areas and gave states discretion to 
determine needs, set priorities, and fund activities within broadly 
defined areas. Prior involvement in the categorical grant programs 
provided an administrative framework for absorbing the new 
responsibilities. 

Managerial improvements. An objective of block grants was to promote 
management improvements by reducing federal requirements. Many 
management improvements were reported, including reduced time and 
effort preparing applications and reports, changed or standardized 
administrative procedures, improved planning and budgeting practices, 
and better use of staff. 

Accountability considerations. Monitoring the expenditure of block 
grant funds to achieve stated national objectives--a theme throughout 
the block grant reports--has been (and is) a central federal 
accountability function under past and present block grant 
legislation. Tracking federally supported activities, recipients, and 
dollars is a major evaluation function. Whether federal funds support 
activities that advance national objectives is historically of central 
interest to Congress. 

[End of text box] 

Description of Consolidated Programs Selected for Studies: 

Transportation Alternatives Program: 

The Moving Ahead for Progress in the 21st Century Act (MAP-21) 
[Footnote 20] restructured existing highway programs by eliminating or 
consolidating numerous programs and establishing a revised, core 
formula program structure. As part of this major restructuring, a new 
program-the Transportation Alternatives (TA) program[Footnote 21]-was 
authorized under MAP-21 in 2012; in fiscal years 2013 and 2014 the TA 
program had authorizations of $809 million and $820 million, 
respectively.[Footnote 22] TA program provides a single source of 
funding generally replacing separate funding for individual programs, 
including the former Transportation Enhancement (TE) activities 
(renamed the Transportation Alternatives activities),[Footnote 23] the 
Safe Routes to School (SRTS) Program,[Footnote 24] and the 
Recreational Trails Program (RTP).[Footnote 25] However, RTP continues 
to be separately funded through a set-aside requirement under the TA 
program. Not all formerly eligible activities may be funded through 
the TA program, though, as MAP-21 also eliminated some eligible 
activities formerly included under TE activities. Funds for the TA 
program--like funds for other federal-aid to highway programs--are 
annually apportioned to the states through a formula.[Footnote 26] 
States have certain flexibilities regarding how they administer the 
programs: for example, each state develops its own process to solicit 
and select projects for funding. The TA program funds are awarded at 
the state or metropolitan planning organization (MPO) level through a 
competitive process, but the authorization does not establish specific 
standards or procedures for how this should be done. The TA program 
added new requirements that did not previously exist: for example, 50 
percent of a state's apportionment must be suballocated based on 
population; states and MPOs must solicit and select projects through 
competitive processes and only eligible entities may sponsor projects, 
MPOs, and nonprofit entities are not eligible entities. 

Continuum of Care Program: 

Two of the grant programs the Department of Housing and Urban 
Development (HUD) uses to address homelessness are the Continuum of 
Care (CoC) program and Emergency Solutions Grants (ESG) program. 
[Footnote 27] In addition to reauthorizing the McKinney-Vento Homeless 
Assistance Act, the Homeless Emergency Assistance and Rapid Transition 
to Housing (HEARTH) Act[Footnote 28] consolidated three homeless 
assistance programs-Supportive Housing, Shelter Plus Care, and Single 
Room Occupancy--into a single program called the CoC program.[Footnote 
29] The HUD supports the nationwide commitment to ending homelessness 
by providing funding opportunities through the CoC program to 
nonprofit organizations and state and local governments that use those 
funds to quickly rehouse homeless individuals and families. 

The McKinney-Vento Homeless Assistance Act, originally passed in 1987, 
[Footnote 30] was the first major federal legislative response to 
homelessness. In 2009, Congress passed the HEARTH Act, which 
significantly amended Title IV of the McKinney-Vento Act. The 
amendments are intended to increase the efficiency and effectiveness 
of coordinated, community-based systems that provide housing and 
services to the homeless.[Footnote 31] Under the CoC program, most of 
the program components and eligible costs continue to be the same as 
those funded under the predecessor programs. However, they are 
consolidated so that applicants only need to apply for CoC program 
funds, rather than for one of three programs based on the type of 
assistance provided. Applications for CoC program funds are made by a 
collaborative applicant, which is an organization that has been 
designated by the Continuum of Care to submit a joint grant 
application to apply for CoC program funds on behalf of all applicants 
for funding in a community. 

CoC program grants are awarded competitively and HUD awarded nearly 
$1.7 billion to projects in fiscal year 2012. Grant recipients are 
nonprofit organizations, states, local governments, and state and 
local government instrumentalities (such as public housing agencies) 
that are designated by the local Continuum of Care to apply for HUD's 
competitive CoC program grant funding.[Footnote 32] Continuum of Cares 
are local groups of providers and key stakeholders in a geographic 
area that join together to design the housing and service system that 
will prevent and end homelessness within their geographic area. 

National Environmental Performance Partnership System: 

The National Environmental Performance Partnership System (NEPPS) is a 
performance-based system of environmental protection designed to 
improve the efficiency and effectiveness of the partnership between 
states and the U.S. Environmental Protection Agency (EPA), as both 
share responsibility for protecting human health and the environment. 
According to EPA documents and state officials, NEPPS is designed to 
direct scarce public resources toward improving environmental results, 
allow states greater flexibility to achieve those results, and enhance 
accountability to the public and taxpayers. 

We have previously reported that EPA has had long-standing 
difficulties in establishing effective partnerships with the states, 
which generally have the lead responsibility in implementing 
environmental grant programs. To address these problems and to improve 
the effectiveness of program implementation, a state may receive funds 
in individual environmental program categorical grants; alternatively, 
a state (or interstate agency) may choose to combine funds from two or 
more environmental program grants into a single grant--a Performance 
Partnership Grant (PPG).[Footnote 33] PPG funds can be used for any 
activity that is eligible under at least one of nineteen environmental 
programs.[Footnote 34] PPGs streamline administrative requirements, 
give states greater flexibility to direct resources to their most 
pressing environmental problems, and make it easier to fund efforts 
that cut across program boundaries. Closely affiliated with PPGs, 
Performance Partnership Agreements (PPA) are designed to complement 
PPGs, with states free to negotiate agreements (or grants) or to 
decline participation in NEPPS altogether. 

While Few Grants Have Been Consolidated Since 1990, Hybrid Approaches 
Are Being Pursued: 

The Number of Federal Grant Program Consolidations Is Difficult to 
Identify and Approaches for Consolidation Have Shifted: 

Our research identified few grant program consolidations over the last 
two decades. We identified a total of 15 consolidations from fiscal 
year 1990 through 2012, (see figure 3 and appendix I). Most of these 
consolidations either combined a number of grant programs used for 
specific activities (such as Shelter Plus Care), known as categorical 
grants, into a broader categorical grant, such as the CoC program, or 
established a Performance Partnership, which offers additional 
flexibility in using funds across multiple programs but is held 
accountable for meeting certain performance measures. 

Figure 3: Summary of Grant Program Consolidations, Fiscal Years 1990 
through 2012: 

[Refer to PDF for image: Interactive graphic] 

Directions: Roll over each grant consolidation program for more 
details. 

Source: GAO analysis of public laws. GAO-15-125. 

Notes: For more information about several of the identified 
consolidated grants, see appendix I. 

[End of figure] 

The grants we identified in figure 3 are likely not an exhaustive list 
and determining a definitive number of grant program consolidations is 
difficult for two reasons. First, our research did not identify an 
authoritative, government-wide compendium or source that provides an 
accurate tally of enacted grant program consolidations. The inability 
to identify an authoritative comprehensive source is consistent with 
prior work reporting on difficulties associated with determining a 
definitive number of federal grant programs. Efforts to accurately 
identify grant program consolidations are further complicated by the 
fact that different entities have counted grant programs differently 
for decades, rendering it difficult to get a count of the number of 
grant programs, let alone consolidations.[Footnote 35] Second, there 
is no commonly accepted definition of what constitutes a grant program 
consolidation. 

While we were not able to identify a definitive number of grant 
consolidations, we were able to generally identify two different 
approaches by which these grants were consolidated. The consolidations 
from 1990 to 2012 shifted more to hybrid approaches from the earlier 
block grant approach. 

Block grant approaches: Previously, Congress showed a strong interest 
in consolidating narrowly defined categorical grant programs intended 
for specific purposes into broader purpose block grants. Consolidating 
closely related categorical programs into these broader purpose grants 
was intended to improve grant administration, which involves the 
federal government awarding a grant to a state or local government. 
While block grants generally delegate primary responsibility for 
monitoring and overseeing the planning, management, and implementation 
of activities financed with federal funds to state and local 
governments, they also can create--and have been designed to 
facilitate--some accountability for national goals and objectives. One 
such program--Temporary Assistance for Needy Families--consolidated a 
number of social service programs which provide families with 
assistance and related support services. 

Hybrid approaches: In more recent years, we have noted a rise in 
hybrid approaches--possibly the result of concluding that the 
traditional devolution of responsibility found in a block grant may 
not be the most appropriate approach. Hybrid approaches can provide 
state and local governments with greater flexibility in using federal 
funds, in exchange for more rigorous accountability for results. 
Hybrid approaches vary in the degree to which programmatic flexibility 
is enabled--in order to balance between or among programs--and in the 
degree to which grant administration, reporting, and accountability 
requirements are changed. One grant program consolidation enacted in 
2009-HUD's CoC program--was created by consolidating multiple 
categorical grant programs. EPA's Performance Partnership System takes 
a slightly different approach. It provides states the opportunity to 
voluntarily enter into agreements with EPA to use funds from two or 
more environmental categorical grant programs in a more flexible and 
streamlined manner, while enabling states to delineate which 
environmental priorities (such as air, water, or waste) are most 
important to their needs. 

Each of these hybrid approaches can strike a different balance between 
the interests of the federal grant-making agency--that funds be used 
efficiently and effectively to meet national objectives and the 
interests of the recipient--that funds meet local priorities and that 
the administrative burdens associated with accepting the grant are 
minimized. 

Hybrid Approaches May Increase Opportunities to Achieve Program 
Outcomes, but Challenges Exist: 

Grants consolidated through hybrid approaches can provide 
opportunities to achieve improved program outcomes for both 
categorical and block grants. While block grant approaches to 
consolidation combine programs for broad purposes, hybrid approaches 
allow for consolidation by combining programs that have a narrower 
scope and may provide flexibilities. Hybrid approaches can improve the 
efficiency of grant administration and may reduce fragmentation, 
overlap, and duplication. For example, in 2012 we reported on 
Department of Justice (DOJ) grants that provided a range of program 
areas that were consolidated using several different hybrid methods. 
[Footnote 36] These grants provided a range of program areas such as 
crime prevention, law enforcement, and crime victim services. At the 
time, DOJ officials told us that the most comprehensive way to reduce 
overlap is by consolidating two programs with similar purposes into 
one and by creating unified management. 

The use of hybrid approaches to consolidate grants continues to 
evolve. The Departments of Labor, Health and Human Services and 
Education and Related Agencies Appropriations Act for fiscal year 2014 
provided authority for those entities receiving funds under the act to 
establish up to 10 Performance Partnership pilots designed to improve 
outcomes for disconnected youth.[Footnote 37] Under the pilot 
authority, a state, local, or tribal government may enter into a 
Performance Partnership agreement with a lead federal agency, which 
will allow the pooling of grant funds received under multiple federal 
programs as well as the additional waiver of requirements associated 
with the federal programs contributing funds. This pilot is a model 
and is designed to promote better education, employment, and other key 
outcomes for disconnected youth and to ease administrative burden. The 
legislation directs OMB to designate the lead federal agency that will 
enter into and administer the Performance Partnership agreement on 
behalf of that agency and the other participating federal agencies. 
OMB is coordinating across multiple federal agencies to facilitate the 
design and planning of the Disconnected Youth Performance Partnership 
pilot. 

Consolidating grants using hybrid approaches brings with it new 
opportunities; however, it also presents challenges. Since 2011, OMB 
has issued multiple memorandums to help federal agencies focus on 
improving program outcomes and reforming overall approaches to grant-
making using hybrid approaches.[Footnote 38] Among the challenges are 
the following: 

Collaborating across multiple federal agencies and programs: OMB staff 
identified two collaboration challenges: establishing the alignment 
needed across federal agencies and establishing the right incentives 
to encourage innovation and participation. Organizational culture 
[Footnote 39] and an organization's ability to perform a joint 
activity (one intended to produce greater public value than could be 
produced acting alone), can significantly affect interagency 
collaboration efforts.[Footnote 40] In addition, resources and the 
structure of an organization's decision-making process affect the 
design and implementation of hybrid consolidation initiatives. OMB 
also noted the significant amount of effort needed from multiple 
stakeholders across different levels of government. In addition, our 
prior grant work concluded that administering similar programs in 
different agencies can create an environment in which programs may not 
serve the grant recipients as efficiently and effectively as possible. 
[Footnote 41] 

Measuring and tracking outcomes: The use of Performance Partnerships, 
such as the pilot previously discussed, involves multiple funding 
streams across federal programs and agencies. Agencies, recipients, 
and subrecipients lose the ability to track program performance for 
individual categorical grants when multiple funding streams are 
combined in a Performance Partnership. Performance Partnership 
initiatives may put additional requirements on agencies to measure and 
track outcomes. For example, before states can enter into a 
Performance Partnership grant, they must first negotiate a work plan 
with EPA that includes expected outputs and outcomes. When designing 
hybrid consolidations, agencies can mitigate certain challenges 
because they provide an opportunity to consider new performance 
measures aligned with the intended consolidation outcome. We 
previously concluded that establishing measurements across agency and 
federal programs may be difficult to accomplish due to challenges 
associated with coordination and agencies reaching agreement on a 
common outcome and as a result, this may be a challenge in 
implementing the Disconnected Youth Performance Partnership pilot. 
[Footnote 42] 

Managing administrative challenges: When DOJ used several hybrid 
approaches to consolidate grants in 2012, officials told us that the 
statutory creation of grant programs with similar purposes can create 
administrative challenges. They said that in many cases, DOJ must seek 
statutory authorization to discontinue or consolidate enacted programs 
that it believes may be overlapping. In addition, EPA officials told 
us for the NEPPS, categorical grant programs within a partnership have 
their own statutory and regulatory requirements, which may create an 
administrative challenge when states try and focus on achieving 
program results. 

Consolidation Design Influenced State and Local Implementation and 
Dictated Impact on Any Existing Fragmentation, Overlap, or Duplication: 

State and Local Governments' Consolidation Implementation is Similar 
to 1980s Block Grant Implementation: 

State and local officials we interviewed are taking some actions to 
implement the selected grant program consolidations. In general, the 
actions taken are similar to the 1980s era of block grant actions 
because in both instances, state and local governments in the three 
case study consolidations relied on existing grant management 
structures and established relationships to facilitate implementation 
of the selected grant program consolidations. These actions include 
relying on the existing grant management structure, identifying the 
existence of carry-over funds from predecessor grant programs, and 
integrating program requirement changes. In addition to these actions, 
state officials reported to us that the TA program and NEPPS case 
study grant program consolidations provided them with flexibility in 
administering the programs. For example, Delaware officials stated the 
TA program provides certain flexibilities, such as choosing which 
recreational trails projects it funds. 

Grant management structure and established relationships: The HEARTH 
Act changed neither the eligible recipients nor the delivery structure 
for administering the CoC grant program. Funds for the CoC grant 
program, like those from the three predecessor homeless grant programs 
before it, are distributed to the same eligible recipients, as 
illustrated in table 2. Under the CoC program, an eligible applicant 
(known as the recipient to whom HUD awards the project and with whom 
HUD enters into a grant agreement for the project) must be designated 
by the Continuum of Care to apply for a grant from HUD on behalf of 
the Continuum that the collaborative applicant represents. The 
Continuum of Care is responsible for developing a grant application 
through a collaborative process and approving the submission of grant 
applications to HUD, among other things. 

Table 2: Comparison of Eligible Applicants of the Predecessor Homeless 
Grant Programs and the Continuum of Care Program: 

Characteristic: Eligible applicants; 
Predecessor homeless grant programs: 
Supportive Housing: 
* State governments; 
* Local governments; 
* Public housing Authorities (and other governmental entities); 
* Private nonprofit organizations; 
* Community mental health centers; 
Shelter Plus Care: 
* State governments; 
* Local governments; 
* Public housing authorities; 
Single Room Occupancy: 
* Public housing authorities; 
* Private nonprofit organizations; 
Consolidated program: 
Continuum of Care: 
* State governments; 
* Local governments; 
* Instrumentals of State or local governments; 
* Public housing authorities; 
* Private nonprofits. 

Source: GAO. GAO-15-125. 

[End of table] 

For example, the Homeless Planning Council of Delaware, a private 
nonprofit organization in one of our selected states, serves multiple 
roles in the state, including serving as the collaborative applicant 
for the statewide Continuum of Care and coordinates the submission, 
ranking, and application for the federal CoC grant funding through 
HUD. Delaware state officials reported that because there was no 
change in the structure of the grant funding stream--meaning the state 
is not the primary recipient of the three predecessor homeless grant 
programs--the CoC program consolidation has had little or no impact on 
the state. 

Existence of carry-over funds from predecessor grant program: States 
reported to us that the budget impact of the TA program consolidation 
was delayed because they relied on carry over funds from predecessor 
grant programs while these funds were still available. For example, 
both Massachusetts and Delaware are spending down federal SRTS funds 
authorized in the 2005 Safe, Accountable, Flexible, Efficient 
Transportation Equity Act: A Legacy for Users (SAFETEA-LU).[Footnote 
43] Until these previously apportioned SRTS funds are obligated or 
rescinded, they will continue to be available for their specified 
period of availability, under the same terms and conditions in effect 
prior to the effective date of MAP-21. Delaware state transportation 
officials told us at the time of our interview that funds apportioned 
under the predecessor program provides a 12-to 18-month period before 
the consolidation will affect them. 

Program requirement integration: The impact of the case study program 
consolidations on state and local program implementation varied, 
depending on any changes in program requirements contained in the 
authorizing legislation. For example, MAP-21 made changes to the cost 
share provision for eligible SRTS projects funded under the TA program 
by requiring a state or local match of 20 percent of project costs. 
Prior to MAP-21, the federal share of the cost of a SRTS project was 
100 percent.[Footnote 44] Based on our interviews, states and local 
officials' actions to implement this program-related change (i.e., the 
requirement for state or local matching funds) are mixed. For example, 
in Massachusetts, the state redirected a portion of its transportation 
dollars to serve as the match for SRTS projects. In Colorado, however, 
officials opted not to fund SRTS projects with state funds: instead, 
barring special appropriations from the General Assembly, local 
governments in Colorado will be responsible for providing matching 
funds. State and local transportation officials in Delaware and 
Florida and local transportation officials in Colorado, also stated 
that at the time the consolidation was enacted, decisions regarding 
federal transportation funding were already made (through the 
statewide transportation planning process)[Footnote 45] and for this 
reason, the TA program consolidation had little immediate impact on 
them.[Footnote 46] 

Performance Accountability Challenges Continue and Opportunities 
Remain to Mitigate Fragmentation, Overlap, and Duplication in Grant 
Program Consolidations: 

In our past work, we concluded that there are various ways to design 
grants to encourage performance accountability and that effective 
performance accountability provisions are of fundamental importance in 
determining if grant program goals are being met. Two factors that we 
have previously concluded as important for effectively reporting on 
grant performance are high-quality performance measures and 
performance data.[Footnote 47] Adding to the complexity of grants 
management, grant programs are typically subject to a wide range of 
accountability requirements (under their authorizing legislation or 
appropriation) and implementing regulations so that funding is spent 
for its intended purpose. Congress may also impose increased reporting 
and oversight requirements on grant-making agencies and recipients. In 
addition, grant programs are subject to crosscutting requirements 
applicable to most assistance programs.[Footnote 48] 

Performance accountability challenges persist in the selected case 
studies, in part because of statutory, regulatory, or administrative 
program requirements were present in the predecessor programs, and 
that continued unchanged in the consolidation implementation. These 
performance accountability challenges identified by federal, state, 
and local officials include lack of central oversight in the states, 
lack of or inaccurate performance data, and conflicting reporting 
requirements, as illustrated in table 3. 

Table 3: Performance Accountability Challenges Identified by State, 
Local, and Federal Officials: 

Performance accountability challenge: Lack of central oversight in the 
states; 
Example: There is limited or no central state agency or entity 
responsible for centrally coordinating and administering both the 
Continuum of Care program and Emergency Solutions Grant homelessness 
programs, in Colorado, Delaware, and Florida. In both states, non-
profit service providers administer the predecessor grant programs, as 
the Balance of State Continuum of Care Collaborative Applicant. In 
Florida, there is no Balance of State Continuum of Care. According to 
Department of Housing and Urban Development officials, the agency does 
not have authority to address fragmentation at the state or local 
level. In addition, the Continuum of Care program was not designed to 
have central oversight. 

Performance accountability challenge: Lack of or inaccurate 
performance data; 
Example: For transportation, the Moving Ahead for Progress in the 21st 
Century Act does not require performance measurements for the 
Transportation Alternatives program. Similarly, for homeless programs 
administered through the Housing and Urban Development, while almost 
all targeted programs maintain performance information (including data 
on the number of homeless served), few targeted programs have 
conducted evaluations to assess how effectively the programs are 
achieving their objectives. 

Performance accountability challenge: Conflicting reporting 
requirements; 
Example: For the National Environmental Performance Partnership System 
(NEPPS) program, Environmental Protection Agency officials reported 
multiple statutory and regulatory requirements govern the individual 
categorical grants eligible for inclusion in a performance partnership 
grant which complicates achieving the goals of NEPPS to promote 
efficiencies and flexibility. 

Source: GAO. GAO-15-125. 

[End of table] 

OMB staff told us that they are identifying opportunities to design 
grant program consolidation authorizations with greater flexibility. 
Through its Uniform Administrative Requirements, Cost Principles, and 
Audit Requirements for Federal Awards (Uniform Guidance),[Footnote 49] 
OMB has consolidated its grants management circulars in an effort to 
promote consistency among grantees and to reduce administrative 
burden, such as, eliminating unnecessary and duplicative requirements, 
on nonfederal entities. OMB officials said this may provide greater 
flexibilities to address some of these accountability challenges. 

State officials reported that these identified accountability 
challenges existed prior to the consolidation and that it is unclear 
how (if at all) consolidations affect them. The experiences of state 
and local officials responsible for grant accountability and 
consolidation implementation suggest opportunities for Congress and 
the executive branch to improve the development and the implementation 
of accountability mechanisms when designing grant program 
consolidations. For example, building accountability into newly 
proposed grant program consolidations is an important but difficult 
task--one requiring trade-offs between federal and state control over 
program finances, activities, and administration. Designing 
accountability provisions provides an opportunity to consider the 
potentially conflicting objectives of increasing state and local 
flexibility, attaining certain national objectives, and improving 
reporting,--which together, leads to better outcome and impact 
evaluations.[Footnote 50] Depending on their focus, evaluations may 
examine aspects of program consolidation (such as performance 
measurements or program reporting) or factors in that program's 
environment that may impede or contribute to the consolidation's 
success. Alternatively, evaluations may assess a consolidation's 
effects beyond its intended objectives, or may estimate what would 
have occurred in the absence of the consolidation, in order to assess 
the net impact. Striking a balance will inevitably involve 
philosophical questions about the proper roles and relationships among 
the levels of government in our federal system. 

We have previously cited examples of how fragmentation and overlap can 
lead to inefficient use of resources. We have previously concluded 
that consolidation may also provide an opportunity to reduce 
fragmentation, overlap, and duplication.[Footnote 51] For the three 
selected program consolidations we reviewed as case studies, federal, 
state or local officials identified opportunities to either reduce 
fragmentation, overlap, and duplication. For example, state or local 
officials in three states (Colorado, Florida, and Massachusetts) 
identified duplicative reporting requirements for homeless assistance 
grants. In addition, multiple homelessness grants are available from 
multiple federal agencies: each offers similar services to similar 
beneficiaries, and each has its own grant life cycle (i.e., separate 
grant awards, applications, and reporting requirements).[Footnote 52] 
In some programs, fragmentation of services and overlap is partly a 
result of a program's statute and partly result of programs evolving 
to offer services that meet the varying needs of recipients. More 
specifically, we have found the following; 

* We have previously concluded that fragmentation, overlap, and 
duplication in the homeless grant programs may be reduced by grant 
program consolidation. By authorizing the consolidated CoC grant 
program, the HEARTH Act helped mitigate this duplication in HUD's 
homeless assistance grant programs but does not fully address it 
because of the underlying structure and operations of providing 
federal homeless services and grant programs to low-income people 
remains fragmented. This is because federal programs may not always 
include service providers with expertise and experience in addressing 
the needs of homeless people and because these programs may lack 
incentives that encourage mainstream service providers to serve this 
population. Also, the fragmented nature of federal mainstream programs 
can create barriers to providing a coordinated set of services that 
addresses the multiple needs of homeless people.[Footnote 53] HUD 
officials told us that they are working to decrease fragmentation in 
homelessness grant programs through regulations and by working with 
other federal stakeholders. 

* The ad hoc nature and fragmentation of federal grant program 
authorization contributes to fragmentation, overlap, and duplication. 
In the case of the NEPPS program, EPA officials reported three areas 
where fragmentation, overlap, and duplication exist, and interfere 
with the ability to achieve the NEPPS goals to promote efficiency and 
effectiveness. The three areas are: (1) multiple competing reporting 
guidance, regulations and individual grant reporting requirements, (2) 
duplication in performance measurement requirements, and (3) grants 
with similar purposes administered by multiple federal and state 
agencies. In some instances--such as when a state receives multiple 
categorical water grants--a PPG may provide opportunities for the 
state to reduce overlap and duplication by managing the funding 
streams available from multiple programs with the flexibilities 
afforded by the PPG. However, fragmentation may be exacerbated by the 
silo effect (i.e., across multiple federal agencies) of program 
implementation. 

Lessons Learned Can Inform Both the Design and Review of Grant Program 
Consolidations: 

Ambiguity of Consolidations' Goals May Create Grant Management 
Challenges: 

The key to any consolidation initiative is identifying and agreeing on 
the goals of the consolidation, regarding grant administration and 
changed programmatic outcomes (if any) and designing and planning for 
successful implementation, according to findings from the case studies 
and our prior GAO work.[Footnote 54] Grant consolidations offer the 
opportunity to improve administration by enlarging the limits of 
narrowly targeted grants and by reducing fragmentation, overlap, and 
duplication. In addition, consolidations may be undertaken to improve 
the programmatic outcomes associated with national goals by designing 
the consolidation with consideration of the effects on other closely 
related grant programs excluded from the consolidation. This awareness 
of consolidation purposes can provide the federal, state and local 
recipients of the consolidation the opportunity to develop an 
implementation plan against a realistic expectation of how the 
consolidation goals can be achieved. 

While grant program consolidation goals can be compromised by the 
complexity and number of grant programs affecting a national goal, and 
by the fragmented structure of authorizing new program initiatives 
across multiple Congressional committees and subcommittees, OMB 
officials told us that building a shared understanding of the 
consolidation goals and outcomes among the affected federal, state, 
and local program officials can build a strategy for achieving the 
identified goals. As federal policy makers consider future grant 
program design--including consolidating categorical grant programs or 
authorizing performance partnerships--it is important that leaders 
consider what the consolidation is trying to achieve and what its 
impact might be on simplifying grant administration and improving the 
effectiveness and performance of federal assistance programs. Without 
first identifying goals, a consolidation may not achieve the desired 
outcome, such as reducing the number of programs while still funding 
the same original program or activity. 

Leadership-Driven Engagement May Increase the Likelihood of a 
Successful Implementation: 

Implementing consolidations is not a simple endeavor and may require 
concentrated efforts of both leadership and employees to accomplish 
new organization goals. Whether consolidations originate from within 
an agency in response to changing conditions or from outside 
pressures, or from the most senior levels of government, it is 
essential that top government and agency leaders are committed to the 
consolidation and play a lead role in executing it. Lessons learned 
from prior work on mergers and transformations have shown that, 
leadership must set the direction, pace, and tone, as well as provide 
a clear, consistent rationale to agency staff in order to increase the 
likelihood of a successful consolidation.[Footnote 55] For example, 
states and EPA are jointly responsible for implementing NEPPS program 
requirements, conducting strategic planning, and setting priorities 
that identify optimal ways to leverage available federal resources 
alongside state resources. Federal and state officials involved in 
implementing EPA's PPAs or PPGs told us that strong senior leadership 
plays an important role in ensuring these responsibilities are met. 
Furthermore, they stated that broad adoption of PPGs requires 
effective coordination across programs and within EPA program offices, 
as well as ongoing senior leadership support. 

Our prior work has shown that communication plays a role in grant 
management reform. We have concluded that communication is not just 
"pushing the message out," but should facilitate a two-way, honest 
exchange and allow for feedback from relevant stakeholders.[Footnote 
56] For example, HUD officials responsible for managing the CoC 
program consolidation told us that establishing a help desk to answer 
questions from grant recipients and other community stakeholders 
enabled HUD to understand consolidation implementation challenges and 
to update guidance accordingly in real time. 

Congress and Agencies Could Help Program Consolidations Through 
Legislative Action and Program Consolidation Evaluations: 

In our prior work, we concluded that given the potential benefits and 
costs of consolidation, it is imperative that Congress and the 
executive branch have information to help them effectively evaluate 
grant program consolidation proposals.[Footnote 57] Congressional 
consideration of evaluation requirements and congressional oversight 
can contribute to successful achievement of national goals in grants 
and to improve the efficiency and effectiveness of grant programs. 

Legislative action: Our body of grant consolidation work has 
identified areas where Congress should consider taking legislative 
action to consolidate certain programs in the education, housing, 
welfare, and justice areas.[Footnote 58] When Congress is considering 
grant program consolidation proposals it is important, that the 
proposals be supported by analysis: agencies' responses to key 
questions could help inform such proposals (see text box).[Footnote 
59] Such questions would not necessarily be exhaustive, nor would it 
be necessary to consider all questions in every proposal. 

Text box: 

Key Questions to Consider When Evaluating Grant Consolidation 
Proposals: 

* What are the goals of the consolidation? What opportunities will be 
addressed through the consolidation and what problems will be solved? 
What problems, if any, will be created? 

* Is there a way to track and monitor progress toward the short-term 
and long-term goals? 

* Does the consolidation proposal include a feedback loop? Does the 
feedback enable officials to identify and analyze the causes of the 
program outcomes and how this learning can be leveraged for continuous 
improvement? 

* What will be the likely costs and benefits of the consolidation? Are 
sufficiently reliable data available to support a business-case 
analysis or cost-benefit analysis? 

* How can the up-front costs associated with the consolidation, if 
any, be funded? 

* Who are the consolidation stakeholders, and how will they be 
affected? How have the stakeholders been involved in the decision, and 
how have their views been considered? On balance, do stakeholders 
understand the rationale for consolidation? 

* If the proposed consolidation approach does not include all programs 
with similar activities or that address similar goals, how will the 
new structure interact with those programs not included in the 
consolidation? 

* To what extent do plans show change management practices will be 
used to implement the consolidation?. 

[End of text box] 

Evidence of thinking through some of these considerations may indicate 
that agency officials have developed a strong grant program 
consolidation proposal. Conversely, the absence of consideration of 
these questions could indicate that agency officials have not 
adequately planned their consolidation proposal. 

Program consolidation evaluations: Executive branch agencies could 
conduct and report program evaluations that would assess how well 
federal programs are working and identify steps that are needed to 
improve them. Program evaluations typically examine processes, 
outcomes, impacts, or the cost effectiveness of federal programs. 
Evaluation can play a key role in program planning, management, and 
oversight by providing feedback on both program design and execution 
to program managers, legislative and executive branch policy 
officials, and the public.[Footnote 60] However, as our prior work 
found few executive branch agencies regularly conduct in-depth program 
evaluations to assess their programs' impacts or to learn how to 
improve results.[Footnote 61] Program evaluations that use the key 
questions identified are also important when programs are being 
considered for consolidation. Such analysis is likely to result in 
more effective and improved outcomes of a consolidation. Annually, 
through the President's budget process and congressional budget 
justification,[Footnote 62] agencies have the opportunity to present 
Congress with the rationale for a program consolidation proposal, such 
as a business case analysis. The congressional budget justification 
can be used to support a grant program consolidation proposal. For 
example, the fiscal year 2012 DOJ congressional budget justification 
recognized the potential for consolidation by stating that "whenever 
possible, the President's Budget proposes to consolidate existing 
programs into larger, more flexible programs that offer state, local, 
and tribal grantees greater flexibility in using grant funding and 
developing innovative approaches to their criminal justice needs." 
[Footnote 63] 

In carrying out its mission, OMB provides general guidance to federal 
agencies, assesses the effectiveness of programs, and ensures that 
budget requests are consistent with regulations and presidential 
priorities.[Footnote 64] OMB, as the focal point for overall 
management in the executive branch, plays a key role in improving the 
performance of federal grant programs and has developed or contributed 
many tools to encourage improvements to federal grants and program 
performance. Therefore, in OMB's capacity to provide agency guidance, 
OMB could help agencies identify consolidation opportunities and 
conduct program consolidation evaluations. OMB staff stated there is a 
need for improved guidance relative to grant program consolidation 
opportunities. Agencies and, the Congress--as well as grantees--can 
benefit from guidance, which currently does not exist, to assist with 
identifying consolidation opportunities, particularly those requiring 
statutory changes and developing consolidation proposals. In 
conducting reviews of prior agency budget justifications, we have 
found opportunities for federal agencies to improve information that 
could aid congressional stakeholders in resource decision making and 
program oversight.[Footnote 65] For example, when proposing a grant 
program consolidation, all agencies could include a program 
consolidation evaluation (or business case) in their budget 
justification review that among other things clearly identifies the 
consolidation goals, benefits, and stakeholders that will be affected 
by the consolidation. 

Consolidation initiatives based on a clearly presented proposal, and 
grounded in accurate and reliable data that sufficiently answer the 
key consolidation evaluation questions can provide a data-driven 
rationale for why an agency is undertaking a particular initiative and 
can show stakeholders that a range of alternatives has been 
considered.[Footnote 66] For example, in our selected case studies, 
program officials identified an opportunity that could streamline the 
CoC grant program. Specifically, officials with the Pasco County, 
Florida Continuum of Care told us they could benefit from having a 
streamlined grant application process. They said the CoC program makes 
three different applications and each application is funded at a 
different time. This process makes it difficult for them to provide 
coordination of care to their homeless population. In addition, 
Massachusetts officials stated they are still administering the 
consolidated grant program as separate programs (as if they had not 
been consolidated) and are therefore unable to identify a benefit for 
consolidating the predecessor categorical grant programs. 

EPA's PPG has elements which illustrate the benefits that can occur 
when agencies must present facts and supporting details for a 
consolidation. For instance, states first elect whether to participate 
in a PPG: if they decide to do so, they identify environmental 
priorities and determine which eligible grant programs to potentially 
include in the PPA--which illustrates a degree of intentional and 
rationale decision making that is consistent with elements of a 
program consolidation evaluation (or business case analysis). Finally, 
to design a PPG, states and EPA develop and negotiate a grant work 
plan consistent with applicable federal statutes; regulations; 
circulars; executive orders; and EPA delegations, approvals or 
authorizations.[Footnote 67] The work plan documents how grantees 
intend to use federal funds and what they will accomplish. Details 
included in a work plan include the commitments for each component and 
a time frame for their accomplishment, a performance evaluation 
process and reporting schedule, and the roles and responsibilities of 
the state and EPA in carrying out the work plan commitments. 

Conclusions: 

The federal government plays an important role in delivering federal 
grant-in-aid to state and local governments. Numerous agencies 
administer fragmented programs, and recent assessments have shown that 
some programs overlap (that is, provide similar products or serve 
similar populations). Consolidating programs carries certain 
implications for recipients (e.g., changes in eligibility, process or 
procedures for eligible applicants), existing programs, personnel, and 
associated information systems. Consolidations can reduce, have no 
impact on, or even increase fragmentation, overlap, and duplication of 
related grant programs that are not included in the consolidation. In 
seeking to avoid increasing unnecessary fragmentation, overlap, and 
duplication, it is critical that federal policy-makers consider what 
other programs or funding streams exist in related areas and what the 
impact of the consolidation on these is likely to be. Even if no 
changes in these other programs are undertaken, design of the 
consolidation can affect the interaction with other programs and 
funding streams. 

As we have previously reported, consolidation initiatives can be 
complex, costly, and difficult to achieve.[Footnote 68] For this 
reason, a case-by-case analysis--one that evaluates the goals of the 
consolidation against the realistic possibility of the extent to which 
those goals would be achieved--is important to ensure effective 
stewardship of government resources in a constrained budget 
environment. 

Considering grant program consolidation design features and their 
implications can help policymakers ensure that accountability and 
information are adequately provided for, whatever type of 
consolidation approach is selected.[Footnote 69] Our findings suggest 
that the design of a grant program consolidation involves choosing 
among policy options that, in combination, establish the degree of 
flexibility afforded to states or localities; prioritize the relevance 
of performance objectives for grantee accountability; designate 
whether accountability for performance rests at the federal, state, or 
local level; and identify prospects for measuring performance through 
grantee reporting. The design may also allow for an evaluation of 
program consolidation performance, an overall assessment of whether 
the program works, and identification of adjustments that may improve 
the results. The availability of guidance on evaluating grant program 
consolidation opportunities could assist agencies' efforts to identify 
such opportunities. Seeking out the interests and concerns of Congress 
and key program stakeholders in advance can help ensure that agency 
evaluations provide the information necessary for effective management 
and congressional oversight of program consolidations. The experiences 
of federal, state, and local officials suggest opportunities for 
Congress and the executive branch to improve grant program 
consolidation design. These opportunities include, evaluating the 
delivery of services with a clear national objective across multiple 
agencies and leveraging lessons learned through feedback from 
implemented consolidations. Using those lessons can support continuous 
improvement in future grant program consolidations. 

Recommendation for Executive Action: 

To assist federal agencies seeking to streamline and improve the 
efficiency of grant programs and improve their outcomes, we recommend 
that the Director of the Office of Management and Budget (OMB) develop 
guidance that presents a range of potential consolidation methods, 
such as performance partnerships, and other hybrid approaches. This 
guidance should assist agencies in identifying consolidation 
opportunities, including those that require statutory changes, and in 
developing sound consolidation proposals. The guidance should include 
questions agencies are expected to include in any consolidation 
proposals such as, 

* What are the goals of the consolidation? What opportunities will be 
addressed through the consolidation and what problems will be solved? 
What challenges, if any, will be created? 

* Is there a way to track and monitor progress toward the short-term 
and long-term goals? Does the consolidation proposal include a 
feedback loop? Does the feedback enable officials to identify and 
analyze the causes of the program outcomes and how this learning can 
be leveraged for continuous improvement? 

* Who are the consolidation stakeholders and how will they be 
affected? What will state, local, or nonprofit entities have to do 
differently? 

* What statutory or regulatory changes are needed to support the 
consolidation? 

* If the proposed consolidation approach does not include all programs 
with similar activities or that address similar goals, how will the 
new structure interact with those programs not included in the 
consolidation? 

Agency Comments and Our Evaluation: 

We provided a draft of this report for review and comment to the 
Administrator of the Environmental Protection Agency, the Secretaries 
of the Departments of Housing and Urban Development and 
Transportation, and the Director of the Office of Management and 
Budget (OMB). OMB did not comment on the recommendation but provided 
technical comments, as did each of the other agencies. We incorporated 
these technical comments as appropriate. Additionally, we provided 
excerpts of the draft report to state and local officials in the four 
states we interviewed for this study and incorporated their technical 
comments as appropriate. 

We are sending this report to relevant agencies and congressional 
committees. In addition, the report is available at no charge on the 
GAO website at [hyperlink, http://www.gao.gov. 

If you or your staff members have any questions or wish to discuss the 
material in this report further, please contact me at (202) 512-6806 
or irvings@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. GAO staff making key contributions to this report are listed 
in appendix III. 

Signed by: 

Susan J. Irving: 
Director for Federal Budget Analysis, Strategic Issues: 

[End of section] 

Appendix I: Summary of Grant Program Consolidations, Fiscal Year 1990 
through 2012 (Text for Interactive figure 3): 

Table 4 lists the 15 consolidated grants we identified during the time 
period of fiscal years 1990 through 2012 along with selected 
characteristics for each. There is no single resource that maintains a 
list of grant consolidations; therefore, this list may not be 
exhaustive. 

Table 4: List of Consolidated Grant Programs and Selected 
Characteristics: 

Consolidated program name: HOME Investment Partnerships; 
Legislation consolidating program: HOME Investment Partnerships Act, 
title II, Pub. L. No. 101-625, 104 Stat. 4079 (Nov. 28, 1990); 
Brief description of consolidated program: Provides funding to 
eligible state and local governments to strengthen public-private 
partnerships and to expand the supply of decent, safe, sanitary, and 
affordable housing, with primary attention to rental housing for very 
low-income and low-income families; 
Federal agency administering consolidated grant: U.S. Department of 
Housing and Urban Development; 
FY 2013 federal obligations[A]: $919.0 million; 
Predecessor program names: Rental Rehabilitation and Development Grant; 
Rehabilitation Loans; Nehemiah Housing Opportunity Grant; Urban 
Homestead; Housing Upgrade Assistance Payments (involving less than 
substantial rehabilitation)[B]. 

Consolidated program name: Supportive Housing[C]; 
Legislation consolidating program: Stewart B. McKinney Homeless 
Housing Assistance Amendments Act of 1992, title XIV, Pub. L. No. 102-
550, 106 Stat. 3672 (Oct. 28, 1992); 
Brief description of consolidated program: To promote the development 
of supportive housing and supportive services, including innovative 
approaches to assist homeless persons in the transition from 
homelessness and to promote the provision of supportive housing to 
enable homeless persons to live as independently as possible; 
Federal agency administering consolidated grant: U.S. Department of 
Housing and Urban Development; 
FY 2013 federal obligations[A]: $0; 
Predecessor program names: Supportive Housing Demonstration; 
Supplemental Assistance for Facilities to Assist the Homeless. 

Consolidated program name: Child Care and Development Block Grant 
(CCDBG); 
Legislation consolidating program: Child Care and Development Block 
Grant Amendments (CCDBGA) of 1996, subtitle VI, Pub. L. No. 104-193, 
110 Stat. 2105 (Aug. 22, 1996); 
Brief description of consolidated program: Provides assistance to low-
income families in obtaining child care. The program was created under 
the Omnibus Budget Reconciliation Act of 1990, Pub. L. No. 101-508, 
104 Stat. 1388 (Nov. 5, 1990). The CCDBGA of 1996 repealed the legacy 
programs and established a consolidated stream of mandatory funding 
for child care for states to integrate into state CCDBG programs which 
is subject to the requirements and limitations of the CCDBG program; 
Federal agency administering consolidated grant: U.S. Department of 
Health and Human Services; 
FY 2013 federal obligations[A]: $2.2 billion; 
Predecessor program names: Aid to Families with Dependent Children 
Child Care; Transitional Child Care; At-Risk Child Care. 

Consolidated program name: Temporary Assistance to Needy Families 
(TANF) Block Grant; 
Legislation consolidating program: Personal Responsibility and Work 
Opportunity Reconciliation Act of 1996 Pub. L. No. 104-193, 110 Stat. 
2105 (Aug. 22, 1996); 
Brief description of consolidated program: To provide families with 
financial assistance and related support services such as child care 
assistance, job preparation, and work assistance; 
Federal agency administering consolidated grant: U.S. Department of 
Health and Human Services; 
FY 2013 federal obligations[A]: $17.2 billion[D]; 
Predecessor program names: Aid to Families with Dependent Children; 
Emergency Assistance; Job Opportunities and Basic Skills Training. 

Consolidated program name: Performance Partnership Grants under the 
National Environmental Performance Partnership System; 
Legislation consolidating program: Omnibus Consolidated Rescissions 
and Appropriations Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 
1321-299 (April 26, 1996) and the Department of Veterans Affairs and 
Housing and Urban Development, and Independent Agencies Appropriations 
Act, 1998, Pub. L. No. 105-65, 111 Stat. 1344, 1373 (Oct. 27, 1997); 
Brief description of consolidated program: Allows states and tribes to 
combine 2 or more of 19 eligible categorical program grants into a 
single multi-program grant with a single budget; 
Federal agency administering consolidated grant: U.S. Environmental 
Protection Agency; 
FY 2013 federal obligations[A]: $421.1 million; 
Predecessor program names: 19 environmental grants[E]. 

Consolidated program name: Teacher Quality Enhancement Grant Programs 
(state, partnership and recruitment grants)[F]; 
Legislation consolidating program: Higher Education Amendments of 
1998, Pub. L. No. 105-244, 112 Stat. 1581 (Oct. 7, 1998); 
Brief description of consolidated program: Focus on improving teacher 
quality and the recruitment of highly qualified teachers; 
Federal agency administering consolidated grant: U.S. Department of 
Education; 
FY 2013 federal obligations[A]: $0; 
Predecessor program names: Numerous programs including: State and 
Local Programs for Teacher Excellence, National Teacher Academies, 
Teacher Scholarships and Fellowships, and Minority Teacher Recruitment. 

Consolidated program name: Juvenile Delinquency Prevention Block 
Grant[G]; 
Legislation consolidating program: Juvenile Justice and Delinquency 
Prevention Act of 2002, Division C, title II, subtitle B, Pub. L. No. 
107-273, 116 Stat. 1758 (Nov. 2, 2002); 
Brief description of consolidated program: To provide financial 
assistance to carry out projects designed to prevent juvenile 
delinquency; 
Federal agency administering consolidated grant: Department of Justice; 
FY 2013 federal obligations[A]: $29.6 million[H]; 
Predecessor program names: Special Emphasis Prevention and Treatment; 
Gang-Free Schools and Communities; Community-based Gang Intervention; 
State Challenge Activities; Juvenile Victims of Child Abuse; Juvenile 
Mentoring; Boot Camps. 

Consolidated program name: Basic State Grant and Tech-Prep Education 
Funding Consolidation; 
Legislation consolidating program: Carl D. Perkins Career and 
Technical Education Improvement Act of 2006, Pub. L. No. 109-270, 120 
Stat. 683 (Aug. 12, 2006); 
Brief description of consolidated program: Permits eligible agencies 
to consolidate all or a portion of funding received under the Tech 
Prep Education program into their Basic State Grant program funding; 
Federal agency administering consolidated grant: U.S. Department of 
Education; 
FY 2013 federal obligations[A]: $1.1 billion; 
Predecessor program names: Tech Prep. 

Consolidated program name: Edward Byrne Memorial Justice Assistance 
Grant[I]; 
Legislation consolidating program: Violence Against Women and 
Department of Justice Reauthorization Act of 2005, Pub. L. No. 109-
162, 119 Stat. 2960, (Jan. 5, 2006); 
Brief description of consolidated program: Provides funding to support 
a range of program areas, including law enforcement; prosecution and 
courts; prevention and education; corrections and community 
corrections; drug treatment and enforcement; planning, evaluation, and 
technology improvement; and crime victim and witness initiative; 
Federal agency administering consolidated grant: U.S. Department of 
Justice; 
FY 2013 federal obligations[A]: $364.9 million; 
Predecessor program names: Edward Byrne Memorial State and Local Law 
Enforcement Assistance; Local Government Law Enforcement Block Grants. 

Consolidated program name: Continuum of Care; 
Legislation consolidating program: Homeless Emergency Assistance and 
Rapid Transition to Housing Act of 2009, division B, Pub. L. No. 111-
22, 123 Stat. 1623 (May 20, 2009); 
Brief description of consolidated program: To promote community-wide 
commitment to the goal of ending homelessness, provide funding for 
efforts by nonprofit providers and state and local governments to 
quickly rehouse homeless individuals while minimizing trauma and 
dislocation caused by homelessness, to promote access to, and 
effective utilization of, mainstream programs and programs funded with 
state or local resources, and optimize self-sufficiency among those 
experiencing homelessness; 
Federal agency administering consolidated grant: U.S. Department of 
Housing and Urban Development; 
FY 2013 federal obligations[A]: $1.9 billion; 
Predecessor program names: Supportive Housing; Single Room Occupancy; 
Shelter Plus Care. 

Consolidated program name: Occupant Protection Grants under the 
National Priority Safety Programs[J]; 
Legislation consolidating program: Motor Vehicle and Highway Safety 
Improvement Act of 2012, div. C, title I, Pub. L. No. 112-141 (July 6, 
2012); 
Brief description of consolidated program: To encourage states to 
adopt and implement occupant protection laws and programs to reduce 
highway deaths and injuries from individuals riding unrestrained in 
motor vehicles; 
Federal agency administering consolidated grant: U.S. Department of 
Transportation; 
FY 2013 federal obligations[A]: $42.4 million*; 
Predecessor program names: Occupant Protection Incentive Grants; 
Child Safety and Child Booster Seat Incentive Grants; Safety Belt 
Performance Grants. 

Consolidated program name: Enhanced Mobility of Seniors and 
Individuals with Disabilities; 
Legislation consolidating program: Federal Public Transportation Act 
of 2012, div. B, Pub. L. No. 112-141. (July 6, 2012); 
Brief description of consolidated program: To provide financial 
assistance in meeting the transportation needs of seniors and persons 
with disabilities where public transportation services are 
unavailable, insufficient or inappropriate; 
Federal agency administering consolidated grant: U.S. Department of 
Transportation; 
FY 2013 federal obligations[A]: $133.2 million; 
Predecessor program names: Elderly Individuals and Individuals with 
Disabilities; New Freedom. 

Consolidated program name: Surface Transportation Program (STP); 
Legislation consolidating program: Moving Ahead for Progress in the 
21[ST] Century Act (MAP-21), Pub. L. No. 112-141, 126 Stat. 405 (July 
6, 2012); 
Brief description of consolidated program: To preserve and improve the 
conditions and performance on any federal-aid highway, bridge, and 
tunnel projects on any public road, pedestrian, and bicycle 
infrastructure, and transit capital projects, including intercity bus 
terminals. The eligible activities under this existing core highway 
program were expanded to fund activities under programs that are no 
longer separately funded; 
Federal agency administering consolidated grant: U.S. Department of 
Transportation; 
FY 2013 federal obligations[A]: $10.0 billion*; 
Predecessor program names: Appalachian Development Highway System; 
Coordinated Border Infrastructure; Truck Parking Facilities[K]; 
Highway Bridge. 

Consolidated program name: National Highway Performance Program[L]; 
Legislation consolidating program: MAP-21, Pub. L. No. 112-141 (July 
6, 2012); 
Brief description of consolidated program: Supports the condition and 
performance of the National Highway System (NHS), supports the 
construction of new facilities on the NHS, and ensures that highway 
construction investments are directed toward performance targets; 
Federal agency administering consolidated grant: U.S. Department of 
Transportation; 
FY 2013 federal obligations[A]: $21.8 billion*; 
Predecessor program names: Interstate Maintenance; National Highway 
System; Highway Bridge. 

Consolidated program name: Transportation Alternatives (TA) Program[M]; 
Legislation consolidating program: MAP-21, Pub. L. No. 112-141 (July 
6, 2012); 
Brief description of consolidated program: Provides funding for 
programs and projects defined as transportation alternatives, 
recreational trail and safe routes to school program projects, as well 
as projects for planning, designing, or constructing boulevards or 
other roadways largely in the right-of-way of former Interstate System 
routes or other divided highways; 
Federal agency administering consolidated grant: U.S. Department of 
Transportation; 
FY 2013 federal obligations[A]: $809 million*; 
Predecessor program names: Recreational Trails (RTP)[N]; Safe Routes 
to School[O]; Transportation Enhancements[P]. 

Legend: * notes fiscal year authorization level. 

Source: GAO analysis. GAO-15-125. 

[A] Fiscal year federal obligations data based on our analysis of 
program data as reported in the Catalog of Federal Domestic Assistance. 

[B] These predecessor programs were terminated, except for the housing 
upgrade assistance payment program with respect to single room 
occupancy dwellings. 

[C] Supportive Housing was subject to a subsequent consolidation. See 
Continuum of Care. 

[D] Congress provided states with $17.2 billion per year in fixed 
federal TANF funding to cover cash benefits, administrative expenses, 
and services primarily targeted to needy families; the amount does not 
vary according to the number of cash assistance recipients, referred 
to as the TANF caseload. 

[E] The 19 grants eligible for inclusion in a PPG are the following: 
Air Pollution Control, State Indoor Radon Grants, Water Pollution 
Control, Nonpoint Source Management, Wetlands Development Grants 
Program, Water Quality Cooperative Agreements, Public Water System 
Supervision, Underground Water Source Protection, Hazardous Waste 
Management, State and Tribal Response (Brownfields), State Underground 
Storage Tanks, Pesticides Cooperative Enforcement, Pesticide 
Applicator Certification and Training, Pesticide Program 
Implementation, Lead-Based Paint Program, Toxic Substances Compliance 
Monitoring, Environmental Information Exchange Network, Pollution 
Prevention State Grants, Multi-media Sector Grants. 

[F] This program was substantially restructured under the Higher 
Education Opportunity Act, Pub. L. No. 110-315, 122 Stat. 3078 (Aug. 
14, 2008) and is now called the Teacher Quality Partnership Grants 
Program. 

[G] The Department of Justice refers to this program as the Title II 
Formula Grants Program. 

[H] Dollars are fiscal year 2013 awarded dollars. 

[I] This program resulted from the merger of the two predecessor 
programs. 

[J] The National Priority Safety Programs include the consolidated 
occupant protection grant (in place of three former occupant 
protection grant programs) and numerous other grant programs which 
were either revised programs or new programs, under a consolidated 
application process. 

[K] MAP-21 repealed the truck parking facilities program while at the 
same time established criteria for eligible truck parking facility 
projects. 

[L] This new core highway formula program may fund activities carried 
out under the Interstate Maintenance, National Highway System, and 
Highway Bridge programs which were eliminated. This new program only 
funds eligible bridge projects within the National Highway System. STP 
funding, however, is available for eligible bridge projects outside 
the National Highway System. 

[M] The TA program provides a single funding source for a variety of 
alternative transportation projects previously eligible under 
separately funded programs, 23 U.S.C. § 213. 

[N] Under the TA program, there is a set-aside requirement for the RTP 
activities unless a state opts out of the set-aside requirement. 23 
U.S.C. § 213. A description of eligible RTP activities is found at 23 
U.S.C. § 206. Under MAP-21, RTP activities are also eligible for STP 
funding. 

[O] Activities under the SRTS program are also eligible for funding 
under STP under the revised listing of eligible transportation 
alternatives activities. 

[P] Prior to MAP-21, transportation enhancement activities were funded 
under a set-aside requirement under STP. This set-aside was eliminated 
under MAP-21, but a revised listing of activities (now referred to as 
"transportation alternatives" under 23 U.S.C. § 101(a)(29)) are 
eligible under the TA program (and remain eligible under STP). 

[End of table] 

[End of section] 

Appendix II: Objectives, Scope, and Methodology: 

As part of our ongoing body of work associated with improving grant 
design and management across the federal government, we were asked to 
identify what federal grant programs have been consolidated in the 
past and asked to examine whether overlap and duplication may be 
reduced by consolidating several federal grant programs, and to 
identify outcomes that have occurred from prior consolidations in 
terms of savings or improved performance. To accomplish this, we 
answered the following objectives: 

1. Describe approaches taken to grant programs that have been 
consolidated from fiscal year 1990 through 2012. 

2. Examine federal, state, and local actions taken to administer the 
selected case study consolidated grant programs. 

3. Analyze the lessons learned for future consideration of grant 
program consolidations. 

For our first reporting objective, we conducted a literature review 
which consisted of reviewing the federal government websites 
USAspending.gov[Footnote 70] and Grants.gov,[Footnote 71] the Catalog 
of Federal Domestic Assistance (CFDA),[Footnote 72] and prior 
presidential budget submissions and conference reports. We also 
reviewed our prior grant management reports, along with reports from 
the Congressional Research Service, the Congressional Budget Office, 
and the Federal Funds Information for States (FFIS) database.[Footnote 
73] We reviewed public laws to clarify when we had identified a 
potential consolidation through one of these sources. The list we 
developed represents our best effort to comprehensively identify all 
grants consolidated from fiscal year 1990 through fiscal year 2012. 
However, it is possible other grants were consolidated during this 
time that our methodology did not identify. We selected 1990 because 
federal, state, and local officials working in these program areas may 
be more aware of the consolidations that happened at or after that 
time than before it. During our review, we identified that some of the 
grants on our list were consolidated using hybrid approaches, and we 
interviewed officials at OMB to learn more about these approaches. In 
conducting this research, we intentionally excluded grant waivers: 
while we have previously reported on them, for this engagement we 
concluded they were generally for narrow administrative purposes or 
specific grant waiver cases were unrelated to our scope.[Footnote 74] 

Further, for our second and third objectives, we conducted three case 
study reviews in four states (and selected localities) to examine how 
selected consolidated grant programs were administered. The selected 
locations and grant program consolidations are not generalizable, but 
they provided important insights about grant consolidations. 

Selected grant consolidated programs: We selected two grant programs--
the Department of Housing and Urban Development (HUD) Continuum of 
Care (CoC) program and the Department of Transportation (DOT) 
Transportation Alternatives (TA) program--in part because they were 
both consolidated in the past 6 years, thus increasing the likelihood 
of receiving sufficient program information (programs consolidated 
more than 6 years ago are less likely to have sufficient information 
in part because there are fewer agency officials in the appropriate 
positions who oversaw the program). We selected the Environmental 
Protection Agency (EPA) National Environmental Performance Partnership 
System (NEPPS) because the approach used to consolidate it was 
different than the other approaches; in addition, at the time we 
selected our programs, it was the only performance partnership 
established we identified. For purposes of this report, we considered 
these three to be consolidated grant programs because they were 
identified as such through our literature review. We reviewed federal 
data for each program--such as state population and state grant award 
amounts--and considered other factors, such as geographic dispersion, 
agency documents, our prior reports, and likely travel costs. For each 
of the selected programs, we conducted either in-person or telephone 
interviews with state and local grant officials. To interview the 
federal officials involved with these programs, we developed a semi-
structured data collection instrument to ensure uniform data 
collection.[Footnote 75] Furthermore, the Departments of Labor, Health 
and Human Services and Education and Related Agencies Appropriations 
Act for fiscal year 2014 provided authority for those entities 
receiving funds under the act to establish up to 10 Performance 
Partnership pilots designed to improve outcomes for disconnected 
youth.[Footnote 76] During our case study review, we learned that OMB 
is leading this initiative and we met with OMB officials to better 
understand this pilot. 

Selected states and entities: After selecting the programs, we chose 
four states--and local entities in each--to conduct a case study 
review of how the programs were being implemented. The four states we 
selected were Colorado, Delaware, Florida, and Massachusetts. To 
select the states, we conducted interviews with subject matter 
specialists seeking location recommendations for each of the selected 
programs, including interviews with federal officials who oversee the 
grant programs and relevant national associations. We also reviewed 
federal agency documents and data for each program which contained 
either state specific participation or funding and we reviewed prior 
reports we have issued on the selected programs and we considered 
other factors such as states where we have previously conducted prior 
grant work. To select localities in each state, we used a similar 
method.[Footnote 77] 

Table 5 provides details about the states and selected entities 
included in our review. 

Table 5: Summary of Selected States and Entities: 

Consolidated grant program: Continuum of Care program; 

State: Colorado; 
Selected entities: 
* Colorado Department of Local Affairs, Division of Housing; 
* Colorado Coalition for the Homeless; 
* Metro Denver Homeless Initiative; 
* City of Colorado Springs; 
* Pikes Peak United Way. 

State: Delaware; 
Selected entities: 
* Delaware State Housing Authority; 
* Homeless Planning Council of Delaware. 

State: Florida; 
Selected entities: 
* Florida Department of Children and Families Office on Homelessness; 
* Coalition for the Homeless of Pasco County, Florida; 
* Florida Coalition for the Homeless. 

State: Massachusetts; 
Selected entities: 
* Department of Housing and Community Development; 
* Somerville Homeless Coalition. 

Consolidated grant program: Transportation Alternatives program: 
National associations; 

State: Colorado; 
Selected entities: 
* Colorado Department of Transportation; 
* Colorado Parks and Wildlife; 
* City and County of Denver Department of Public Works; 
* Pikes Peak Area Council of Governments. 

State: Delaware; 
Selected entities: 
* Delaware Department of Transportation; 
* Delaware Division of Parks and Recreation; 
* Wilmington Area Planning Council. 

State: Florida; 
Selected entities: 
* Florida Department of Transportation; 
* Florida Department of Environmental Protection; 
* Miami-Dade Metropolitan Planning Organization. 

State: Massachusetts; 
Selected entities: 
* Massachusetts Department of Transportation; 
* Pioneer Valley Planning Commission. 

State: National associations; 
Selected entities: 
* American Association of State Highway and Transportation Officials; 
* Rails to Trails Conservancy. 

Consolidated grant program: NEPPS; 

State: Colorado; 
Selected entities: 
* Colorado Department of Public Health and Environment. 

State: Delaware; 
Selected entities: 
* Delaware Health and Social Services, Division of Public Health; 
* Delaware Department of Agriculture; 
* Delaware Division of Natural Resources and Environmental Control. 

State: Florida; 
Selected entities: 
* Florida Department of Environmental Protection. 

State: Massachusetts; 
Selected entities: 
* Massachusetts Department of Environmental Protection; 
* Massachusetts; 
* Department of Agricultural Resources. 

State: National associations; 
Selected entities: 
* Environmental Council of States; 
* Association of Clean Water Administrators. 

Source: GAO. GAO-15-125. 

[End of table] 

Lessons learned. For objective 3, to analyze lessons learned for 
future consideration of grant program consolidations, we reviewed 
existing literature pertaining to grants management and identified key 
questions to consider when evaluating grant program consolidations, 
and attributes for conducting a program consolidation evaluation. In 
addition, we interviewed agency officials and reviewed legislation and 
best practices developed in our prior reports and OMB memos. 

[End of section] 

Appendix III: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Susan J. Irving, (202) 512-6806 or irvings@gao.gov. 

Staff Acknowledgments: 

In addition to the contact named above, Stanley J. Czerwinski, William 
J. Doherty (Assistant Director), and Sandra L. Beattie (Analyst-in-
Charge), supervised this review and the development of the resulting 
report. Alicia P. Cackley, Steven L. Cohen, James Cook, Deirdre Duffy, 
Karin K. Fangman, Susan E. Iott, Donna Miller, Cynthia Saunders, and 
Paul J. Schmidt made key contributions to this report. 

[End of section] 

Related GAO Products: 

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Overlap, and Duplication and Achieve Other Financial Benefits. 
[hyperlink, http://www.gao.gov/products/GAO-14-343SP]. Washington, 
D.C.: April 8, 2014. 

Grants Management: Improved Planning, Coordination, and Communication 
Needed to Strengthen Reform Effort. [hyperlink, 
http://www.gao.gov/products/GAO-13-383]. Washington, D.C.: May 23, 
2013. 

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to Identify, Assess, and Reduce Inefficiencies. [hyperlink, 
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Justice Grant Programs: DOJ Should Do More to Reduce the Risk of 
Unnecessary Duplication and Enhance Program Assessment. [hyperlink, 
http://www.gao.gov/products/GAO-12-517]. Washington, D.C.: July 12, 
2012. 

Streamlining Government: Questions to Consider When Evaluating 
Proposals to Consolidate Physical Infrastructure and Management 
Functions. [hyperlink, http://www.gao.gov/products/GAO-12-542]. 
Washington, D.C.: May 23, 2012. 

State and Local Governments: Fiscal Pressures Could Have Implications 
for Future Delivery of Intergovernmental Programs. [hyperlink, 
http://www.gao.gov/products/GAO-10-899]. Washington, D.C.: July 30, 
2010. 

Grants Management: Enhancing Accountability Provisions Could Lead to 
Better Results. [hyperlink, http://www.gao.gov/products/GAO-06-1046]. 
Washington, D.C.: Sept. 29, 2006. 

Results-Oriented Cultures: Implementation Steps to Assist Mergers and 
Organizational Transformations. [hyperlink, 
http://www.gao.gov/products/GAO-03-669]. Washington, D.C.: July 2, 
2003. 

Federal Assistance: Grant System Continues to Be Highly Fragmented. 
[hyperlink, http://www.gao.gov/products/GAO-03-718T]. Washington, 
D.C.: April 29, 2003. 

Homelessness: Consolidating HUD's McKinney Programs. [hyperlink, 
http://www.gao.gov/products/GAO/T-RCED-00-187]. Washington, D.C.: May 
23, 2000. 

Welfare Programs: Opportunities to Consolidate and Increase Program 
Efficiencies. [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-95-139]. Washington, D.C.: May 
31, 1995. 

Program Consolidation: Budgetary Implications and Other Issues. 
[hyperlink, http://www.gao.gov/products/GAO/T-AIMD-95-145]. 
Washington, D.C.: May 23, 1995. 

Block Grants: Characteristics, Experience, and Lessons Learned. 
[hyperlink, http://www.gao.gov/products/GAO/HEHS-95-74]. Washington, 
D.C.: Feb 9, 1995. 

State Rather Than Federal Policies Provided the Framework for Managing 
Block Grants. [hyperlink, http://www.gao.gov/products/GAO/HRD-85-36]. 
Washington, D.C.: March 15, 1985. 

Lessons Learned from Past Block Grants: Implications for Congressional 
Oversight. [hyperlink, http://www.gao.gov/products/GAO/IEP-82-8]. 
Washington, D.C.: September 23, 1982. 

[End of section] 

Footnotes: 

[1] GAO, Grants to State and Local Governments: An Overview of Federal 
Funding Levels and Selected Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-12-1016] (Washington, D.C.: Sept. 25, 
2012). 

[2] See Office of Management and Budget, Fiscal Year 2015, Historical 
Tables, Budget of the U.S. Government. Specifically, Table 12.3, 
"Total Outlays for Grants to State and Local Governments, by Function, 
Agency, and Program: 1940-2015". Constant dollar amounts reflect 
adjustments for inflation (e.g., the purchasing power of the $135 
billion spent in 1990 represents about $217 billion in fiscal year 
2013 dollars). Total federal outlay data for fiscal year 2013 reflects 
the most current available at the time of this report publication. 
These data include grants to states for Medicaid, the federal 
government's largest single grant program. 

[3] GAO, State and Local Governments: Fiscal Pressures Could Have 
Implications for Future Delivery of Intergovernmental Programs, 
[hyperlink, http://www.gao.gov/products/GAO-10-899] (Washington, D.C.: 
July 30, 2010). 

[4] GAO, Housing Assistance: Opportunities Exist to Increase 
Collaboration and Consider Consolidation, GAO12-554 (Washington, D.C.: 
Aug. 16, 2012). 

[5] GAO, 2012 Annual Report: Opportunities to Reduce Duplication, 
Overlap and Fragmentation, Achieve Savings, and Enhance Revenue, 
[hyperlink, http://www.gao.gov/products/GAO-12-342SP] (Washington, 
D.C.: Feb. 28, 2012) and Program Consolidation: Budgetary Implications 
and Other Issues, [hyperlink, 
http://www.gao.gov/products/GAO/T-AIMD-95-145] (Washington, D.C.: May 
23, 1995). Fragmentation, overlap, and duplication are further 
discussed and defined in the background of this report. 

[6] GAO, Grants to State and Local Governments: An Overview of Federal 
Funding Levels and Selected Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-12-1016] (Washington, D.C.: Sept. 25, 
2012) and Grants Management: Enhancing Performance Accountability 
Provisions Could Lead to Better Results, [hyperlink, 
http://www.gao.gov/products/GAO-06-1046] (Washington, D.C.: Sept. 29, 
2009). 

[7] In addition to figure 3, more details about the grants we found 
can be seen in appendix I. 

[8] Federal and association officials we interviewed indicated there 
is minimal local involvement associated with administering the NEPPS. 

[9] GAO, A Glossary of Terms Used in the Federal Budget Process, 
[hyperlink, http://www.gao.gov/products/GAO-05-734SP] (Washington, 
D.C.: September 2005) and "Chapter 10, Federal Assistance: Grants and 
Cooperative Agreements" in GAO, Principles of Federal Appropriations 
Law, Third Edition, Volume II, [hyperlink, 
http://www.gao.gov/products/GAO-06-382SP] (Washington, D.C.: Feb. 
2006). 

[10] As we have previously found, some block grants have 
characteristics normally associated with categorical grants. This type 
of variation in the characteristics of specific block grants explains 
why there is some disagreement concerning precisely what constitutes a 
block grant and how many of them exist. GAO, Grants to State and Local 
Governments: An Overview of Federal Funding Levels and Selected 
Challenges, [hyperlink, http://www.gao.gov/products/GAO-12-1016], 
(Washington, D.C.: Sept. 25, 2012). 

[11] See OMB, Fiscal Year 2015, Historical Tables, Budget of the U.S. 
Government. Specifically, Table 12.3, "Total Outlays for Grants to 
State and Local Governments, by Function, Agency, and Program: 1940-
2015." We used data for fiscal years 1980 through 2013 and converted 
them to 2013 constant dollars for a more accurate comparison of grant 
spending from year to year. Total federal outlay data for fiscal year 
2013 reflects the most current available at the time of this report 
publication. 

[12] The U.S. ACIR was an independent intergovernmental agency 
established in 1959 to improve the ability of federal, state, and 
local governments to work together cooperatively, efficiently, and 
effectively. Consisting of appointed and elected officials from all 
three levels of government, ACIR was created with the recognition that 
each level of government had an important and distinct role to play in 
formulating and administering policies. The Treasury, Postal Service, 
and General Government Appropriations Act, 1996, Pub. L. No. 104-52, 
109 Stat. 468, 480 (1995), terminated ACIR effective September 30, 
1996. Congress subsequently authorized ACIR to continue in existence 
beyond this date for the purpose of performing a congressionally 
authorized contract. Pub. L. No. 104-328, 110 Stat. 4004 (1996). 

[13] [hyperlink, http://www.gao.gov/products/GAO/T-AIMD-95-145], 2013 
Annual Report: Actions Needed to Reduce Fragmentation, Overlap, and 
Duplication and Achieve Other Financial Benefits, [hyperlink, 
http://www.gao.gov/products/GAO-13-279SP] (Washington, D.C.: Apr. 9, 
2013) and 2012 Annual Report: Opportunities to Reduce Duplication, 
Overlap and Fragmentation, Achieve Savings, and Enhance Revenue, 
[hyperlink, http://www.gao.gov/products/GAO-12-342SP] (Washington, 
D.C.: Feb. 28, 2012). 

[14] According to the Association of Government Accountants (AGA), 
"blending" requires statutory authority. For the purpose of this 
report, we refer to "blending" as a type of "hybrid" approach. 
According to AGA, the Environmental Protection Agency's Performance 
Partnership Grants are an example of "blending," where financial 
assistance from individual awards are consolidated into one award. 
Each individual award loses its award-specific identity. AGA is 
preparing a paper for release later this year directed to policy 
makers and practitioners to help them develop and implement projects 
using this approach. 

[15] For additional information on a wide range of substantive and 
other requirements, [hyperlink, 
http://www.gao.gov/products/GAO-12-1016], "Appendix III: Cross-cutting 
Grants Legislation and OMB Circulars/Agency Grant Regulations". 

[16] Pub. L. No. 97-35, 95 Stat. 357 (Aug. 13, 1981). 

[17] Our prior in-depth reviews focused on seven of the nine block 
grants enacted in 1981: maternal and child health; preventive health 
and human services; alcohol, drug abuse, and mental health services; 
social services; community services; low-income home energy 
assistance; and education. GAO, Block Grants: Characteristics, 
Experience, and Lessons Learned, [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-95-74] (Washington, D.C.: Feb. 9, 
1995), Block Grants: Overview of Experience to Date and Emerging 
Issues, and State Rather Than Federal Policies Provided the Framework 
for Managing Block Grants, [hyperlink, 
http://www.gao.gov/products/GAO/HRD-85-36] (Washington, D.C.: Mar. 15, 
1985). 

[18] Pub. L. No. 97-35, §§ 1741-1745. 

[19] For information on GAO's grant administrative costs findings, see 
GAO, Grants Management: Programs at HHS and HUD Collect Administrative 
Cost Information but Differences in Cost Caps and Definitions Create 
Challenges, [hyperlink, http://www.gao.gov/products/GAO-15-118] 
(Washington, D.C.: Dec. 12, 2014). 

[20] Pub. L. No. 112-141, 126 Stat. 405 (July 6, 2012). 

[21] TA program eligible activities include on-and off-road pedestrian 
and bicycle facilities, infrastructure projects for improving non-
driver access to public transportation and enhanced mobility, 
community improvement activities, and environmental mitigation; 
recreational trail projects; safe routes to school projects; and 
projects for planning, designing, or constructing boulevards and other 
roadways largely in the right-of-way of former divided highways. 
Department of Transportation officials told us that they do not 
consider the TA program a consolidation but instead consider it a 
program restructuring. 

[22] Pub. L. No. 112-141, § 1122, 126 Stat. 405, 494 (July 6, 2012), 
codified at 23 U.S.C. § 213. 

[23] 23 U.S.C. § 101(a)(29). Prior to MAP-21, transportation 
enhancement activities were specifically funded under a set-aside 
requirement for the Surface Transportation Program. 

[24] Section 1404 of the Safe, Accountable, Flexible, Efficient 
Transportation Equity Act: A Legacy for Users (SAFETEA-LU), Pub. L. 
No. 109-59, 119 Stat. 1144, 1228 (Aug. 10, 2005), as amended. See 23 
U.S.C. § 402, note. 

[25] 23 U.S.C. § 206. 

[26] The TA program is funded by contract authority from the Highway 
Account of the Highway Trust Fund. Funds are subject to the overall 
Federal-aid obligation limitation. An amount equal to 2% of the total 
amount authorized from the Highway Account of the Highway Trust Fund 
for Federal-aid highways each fiscal year is to be reserved for the TA 
program. 23 USC § 213 (a) Contract authority is a form of budget 
authority that permits obligations to be incurred in advance of 
appropriations. Contract authority is unfunded, and a subsequent 
appropriation is needed to liquidate or pay the spending. 

[27] ESG funds are allocated by formula to metropolitan cities, urban 
counties, territories, and states for select outreach, emergency 
shelter, homelessness prevention, rapid re-housing assistance, and 
homeless management information systems. 42 U.S.C. §§ 11371-11378. 

[28] The HEARTH Act is set forth in Division B of Pub. L. No. 111-22, 
123 Stat. 1632 (May 20, 2009). 

[29] The CoC program is set forth under §§ 1301-1306 of Pub. L. No. 
111-22 and generally codified under 42 U.S.C. §§ 11381-11386e. 
Pursuant to §1002(b)(2) of the HEARTH Act, a fourth program, Safe 
Havens (for Homeless Individuals Demonstration) was listed as 
consolidated. However, HUD notes in its interim regulations on the CoC 
program that new Safe Haven projects are no longer eligible under CoC. 
77 Fed. Reg. 45422, 45431 (July 31, 2012). 

[30] The act was originally named the Stewart B. McKinney Act but was 
subsequently changed to the McKinney-Vento Act. 

[31] See the Executive Summary contained in Homeless Emergency 
Assistance and Rapid Transition to Housing; Continuum of Care Program, 
77 Fed. Reg. 45422 (July 31, 2012). 

[32] The federal government increasingly partners with nonprofit 
organizations as they bring much strength to these partnerships, such 
as flexibility to respond to needs and access to those needing 
services. This increase is attributable to several reasons such as, a 
shift in recent decades away from government providing most services 
directly and the trend in devolution in certain policy areas such as 
welfare, which contributed to a lessening role of the federal 
government and more localized control in the hands of state, local, 
and nonprofit organizations. See GAO, Nonprofit Sector: Increasing 
Numbers and Key Role in Delivering Federal Services, [hyperlink, 
http://www.gao.gov/products/GAO-07-1084T], (Washington: D.C.: July 24, 
2007). For additional nonprofit work see GAO, Nonprofit Sector: 
Significant Federal Funds Reach the Sector through Mechanisms, but 
More Complete and Reliable Funding Data Are Needed, [hyperlink, 
http://www.gao.gov/products/GAO-09-193], (Washington, D.C.: Feb 26, 
2009). 

[33] PPG's were authorized under the Omnibus Consolidated Rescissions 
and Appropriations Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 
1321-299 (April 26, 1996) and expanded to include interstate agencies 
under the Department of Veterans Affairs and Housing and Urban 
Development, and Independent Agencies Appropriations Act, 1998, Pub. 
L. No. 105-65, 111 Stat. 1344, 1373 (Oct. 27, 1997). 

[34] The 19 grants eligible for inclusion in a PPG are the following: 
Air Pollution Control, State Indoor Radon Grants, Water Pollution 
Control, Nonpoint Source Management, Wetlands Development Grants 
Program, Water Quality Cooperative Agreements, Public Water System 
Supervision, Underground Water Source Protection, Hazardous Waste 
Management, State and Tribal Response (Brownfields), State Underground 
Storage Tanks, Pesticides Cooperative Enforcement, Pesticide 
Applicator Certification and Training, Pesticide Program 
Implementation, Lead-Based Paint Program, Toxic Substances Compliance 
Monitoring, Environmental Information Exchange Network, Pollution 
Prevention State Grants, and Multi-media Sector Grants. 

[35] The Catalog of Federal Domestic Assistance (CFDA) is the single 
authoritative, government-wide compendium and source document for 
descriptions of federal grant programs. However, we previously found 
there are a number of challenges with CFDA including that it contains 
active and non-active funded programs which have been archived at an 
agency's request. See [hyperlink, 
http://www.gao.gov/products/GAO-12-1016] for additional identified 
CFDA challenges. 

[36] GAO, Justice Grant Programs: DOJ Should Do More to Reduce the 
Risk of Unnecessary Duplication and Enhance Program Assessment, 
[hyperlink, http://www.gao.gov/products/GAO-12-517] (Washington, D.C: 
July 12, 2012). 

[37] Pub. L. No. 113-76, div. H, title V, § 526, 128 Stat. 5, 413-416 
(Jan. 17, 2014). 

[38] OMB Memorandum M-11-21, Implementing the Presidential Memorandum 
"Administrative Flexibility, Lower Costs, and Better Results for 
State, Local, and Tribal Governments" (Washington, D.C., April. 29, 
2011) and OMB Memorandum M-13-17, Next Steps in the Evidence and 
Innovation Agenda (Washington, D.C., July 26, 2013). 

[39] We have previously defined organizational culture to be the 
underlying assumptions, beliefs, values, attitudes, and expectations 
shared by an organization's members. There is a consensus among 
organizational culture experts that an organization's beliefs and 
values affect the behavior of its members. GAO, Organizational 
Culture: Techniques Companies Use to Perpetuate or Change Beliefs and 
Values, [hyperlink, http://www.gao.gov/products/GAO/NSIAD-92-105], 
(Washington, D.C.: Feb. 27, 1992). 

[40] GAO, Managing For Results: Key Considerations for Implementing 
Interagency Collaborative Mechanisms, [hyperlink, 
http://www.gao.gov/products/GAO-12-1022], (Washington, D.C.: Sept. 27, 
2012) and GAO, Results-Orientated Government: Practices That Can Help 
Enhance and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C. Oct. 21, 
2005). 

[41] GAO, Early Learning and Child Care: Federal Funds Support 
Multiple Programs with Similar Goals, [hyperlink, 
http://www.gao.gov/products/GAO-14-325T] (Washington, D.C.: Feb. 5, 
2014). 

[42] [hyperlink, http://www.gao.gov/products/GAO-06-15]. 

[43] Under SAFETEA-LU, the Federal Highway Administration (FHWA) 
distributed SRTS funding through annual apportionments established by 
the statutory formula. Once FHWA apportioned these funds, they were 
available to be awarded by states. After the states have established 
project agreements with their grantees, the states may obligate the 
funds in accordance with each state's approved transportation 
improvement program. 

[44] In our prior work we found that most federal funds for highway 
projects require a 20 percent match from state and local governments. 
In addition, grants with federal matching requirements may promote 
relatively more state and local spending than non-matching grants, 
thus reducing the likelihood that states will use the federal funds to 
replace, rather than supplement, their own spending. GAO, Federal 
Grants: Design Improvements Could Help Federal Resources Go Further, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-97-7] (Washington, 
D.C.: Dec. 18, 1996) and Safe Routes to Schools: Progress in 
Implementing the Program, but a Comprehensive Plan to Evaluate Program 
Outcomes is Needed, [hyperlink, 
http://www.gao.gov/products/GAO-08-789] (Washington: D.C.: July 31, 
2008). 

[45] The statewide transportation planning process is the process 
administered through each state's department of transportation through 
which states decide how to spend transportation funds. This process is 
informed by MPOs that lead transportation planning in urbanized areas. 

[46] States must comply with federal transportation planning 
requirements administered jointly by the Federal Highway 
Administration and the Federal Transit Administration, states have 
considerable discretion to allocate federal transportation funds and 
select projects. See, GAO Statewide Transportation Planning: 
Opportunities Exist to Transition to Performance-Based Planning and 
Federal Oversight. [hyperlink, http://www.gao.gov/products/GAO-11-77] 
(Washington, D.C.: Dec 15, 2010) and Metropolitan Planning 
Organizations: Options Exist to Enhance Transportation Planning 
Capacity and Federal Oversight, [hyperlink, 
http://www.gao.gov/products/GAO-09-868] (Washington, D.C.: Sep 9, 
2009). 

[47] GAO, Grants Management: Enhancing Accountability Provisions Could 
Lead to Better Results, [hyperlink, 
http://www.gao.gov/products/GAO-06-1046] (Washington, D.C.: Sept. 29, 
2006) and [hyperlink, http://www.gao.gov/products/GAO-12-1016]. 

[48] GAO, Grants Management: Improved Planning, Coordination, and 
Communication Needed to Strengthen Reform Efforts, [hyperlink, 
http://www.gao.gov/products/GAO-13-383] (Washington, D.C.: May 23, 
2013). 

[49] OMB consolidated eight (A-21, A-87, A-110, A-122, A-89, A-102, A-
133, and A-50) of its grants management circulars into the Uniform 
Guidance. 78 Fed. Reg. 78,590 (Dec. 26, 2013). The new Uniform 
Guidance is scheduled to go into effect for grantees on December 26, 
2014. 

[50] Outcome evaluations assess the extent to which a program achieves 
its outcome oriented objectives. It focuses on out-puts and outcomes 
(including unintended effects) to judge program effectiveness but may 
also assess program process to understand how outcomes are produced. 
Impact evaluations are a form of outcome evaluation that assess the 
net effect of a program by comparing program outcomes with an estimate 
of what would have happened in the absence of the program. This form 
of evaluation is employed when external factors are known to influence 
the program's outcomes, in order to isolate the program's contribution 
to achievement of its objectives. See, GAO, Performance Measurement 
and Evaluation: Definitions and Relationships, [hyperlink, 
http://www.gao.gov/products/GAO-11-646SP] (Washington, D.C.: May 2011). 

[51] GAO, Opportunities to Reduce Potential Duplication in Government 
Programs, Save Tax Dollars, and Enhance Revenue, [hyperlink, 
http://www.gao.gov/products/GAO-11-318SP] (Washington, D.C.: Mar. 1, 
2011). 

[52] GAO, Homelessness: Fragmentation and Overlap in Programs 
Highlight the Need to Identify, Assess, and Reduce Inefficiencies, 
[hyperlink, http://www.gao.gov/products/GAO-12-491] (Washington, D.C.: 
May 10, 2012). 

[53] GAO, Homelessness: Barriers to Using Mainstream Programs, 
[hyperlink, http://www.gao.gov/products/GAO/RCED-00-184] (Washington, 
D.C.: July 6, 2000). 

[54] GAO, Streamlining Government: Questions to Consider When 
Evaluating Proposals to Consolidate Physical Infrastructure and 
Management Functions, [hyperlink, 
http://www.gao.gov/products/GAO-12-542] (Washington, D.C.: May 23, 
2012). 

[55] GAO, Highlights of a GAO Forum: Mergers and Transformation: 
Lessons Learned for a Department of Homeland Security and Other 
Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-03-293SP] (Washington, D.C.: Nov. 14, 
2002) and Results-Oriented Cultures: Implementation Steps to Assist 
Mergers and Organizational Transformations, [hyperlink, 
http://www.gao.gov/products/GAO-03-669] (Washington, D.C.: July 2, 
2003). 

[56] [hyperlink, http://www.gao.gov/products/GAO-12-542]. 

[57] [hyperlink, http://www.gao.gov/products/GAO-12-542]. 

[58] GAO, Housing Assistance: Opportunities Exist to Increase 
Collaboration and Consider Consolidation, [hyperlink, 
http://www.gao.gov/products/GAO-12-554], (Washington, D.C.: Aug. 16, 
2012), Justice Grant Programs: DOJ Should Do More to Reduce the Risk 
of Unnecessary and Duplication and Enhance Program Assessment, 
[hyperlink, http://www.gao.gov/products/GAO-12-517] (Washington, D.C.: 
July 12, 2012), Department of Education: Information on Consolidation 
Opportunities and Student Aid, [hyperlink, 
http://www.gao.gov/products/GAO/T-HEHS-95-130] (Washington, D.C.: Apr. 
6, 1995), and Welfare Programs: Opportunities to Consolidate and 
Increase Program Efficiencies, [hyperlink, 
http://www.gao.gov/products/GAO/HEHS-95-139] (Washington, D.C.: May 
31, 1995). 

[59] These key questions have been adapted from [hyperlink, 
http://www.gao.gov/products/GAO-12-542] to apply to grant 
consolidation and have been informed by discussions with subject 
matter experts to more closely relate to the nature of grant programs 
as opposed to programs at large. 

[60] GAO, Program Evaluation: Strategies to Facilitate Agencies' Use 
of Evaluation in Program Management and Policy Making, [hyperlink, 
http://www.gao.gov/products/GAO-13-570] Washington, D.C.: June 26, 
2013). 

[61] GAO, Government Efficiency and Effectiveness: Strategies for 
Reducing Fragmentation, Overlap, and Duplication and Achieving Cost 
Savings, [hyperlink, http://www.gao.gov/products/GAO-13-631T] 
(Washington, D.C.: May 16, 2013). 

[62] In a congressional budget justification, agencies submit 
documents to the appropriations committees in support of their budget 
request. The justification typically explains changes between the 
current appropriation and the amounts requested for the next fiscal 
year. 

[63] [hyperlink, http://www.gao.gov/products/GAO-12-342SP]. 

[64] As we previously reported, Congress enacted the Federal Grant and 
Cooperative Agreement Act of 1977 to establish standards for executive 
agencies in selecting the most appropriate funding vehicle. The act 
directed OMB to provide guidance to executive agencies to promote 
consistent and efficient use of funding vehicles. GAO, Grants to State 
and Local Governments: An Overview of Federal Funding Levels and 
Selected Challenges, [hyperlink, 
http://www.gao.gov/products/GAO-12-1016] (Washington, D.C.: Sept. 25, 
2012). 

[65] GAO, Veteran's Health Care Budget: Improvements Made, but 
Additional Actions Needed to Address Problems to Estimates Supporting 
President's Request, [hyperlink, 
http://www.gao.gov/products/GAO-13-715] (Washington, D.C.: Aug. 8, 
2013), and Bureau of Prisons: Opportunities Exist to Enhance the 
Transparency of Annual Budget Justifications, [hyperlink, 
http://www.gao.gov/products/GAO-14-121] (Washington, D.C.: Dec. 6, 
2013). 

[66] [hyperlink, http://www.gao.gov/products/GAO-12-542]. 

[67] A PPA---or comparable negotiated agreement--can serve as a grant 
work plan for a PPG or other state grants. A comprehensible PPA that 
serves as the PPG work plan can be the most strategic, flexible and 
outcome-oriented option for states and regions. States are not 
required to negotiate PPAs with EPA in order to combine grants in a 
PPG. In fiscal year 2012, 33 states and territories were using PPAs 
and 42 were using PPGs. 

[68] [hyperlink, http://www.gao.gov/products/GAO-12-542]. 

[69] [hyperlink, http://www.gao.gov/products/GAO/GGD-98-137]. 

[70] The Office of Management of Budget (OMB) launched USAspending.gov 
to meet the requirements of the Federal Funding Accountability and 
Transparency Act of 2006, Pub. L. No. 109-282, 120 Stat. 1186 (Sept. 
26, 2006), to establish a single searchable website, accessible by the 
public at no cost that displays comprehensive data on federal awards 
and subawards. 

[71] Grants.gov serves as the central grant identification and 
application portal for more than 1,000 federal grant programs that 
fund training, research, planning, construction, and the provision of 
services in areas such as health care, education, transportation, and 
homeland security. 

[72] CFDA is the single authoritative, government-wide compendium and 
source for descriptions of federal programs that provide assistance or 
benefits to the American public. 

[73] FFIS is designed to help states manage their federal funds by 
providing timely analysis of the impact of federal actions on states. 
Its primary mission is to track and report on the fiscal impact of 
federal budget and policy decisions on state budgets and programs. 

[74] Grant waivers can be used to support state and local innovations 
by allowing federal agencies to suspend certain programmatic 
requirements in discretionary or mandatory programs. Some waivers are 
then rigorously evaluated to learn what works and what is cost 
effective. Each grant waiver must be approved by federal agency 
officials before grantees can have their desired flexibility. See GAO, 
Federal Assistance: Grant System Continues to Be Highly Fragmented, 
[hyperlink, http://www.gao.gov/products/GAO-03-718T] (Washington, 
D.C.: Apr. 29, 2003). 

[75] For NEPPS, we also interviewed EPA Region officials for each of 
the regions that oversee the states we selected. We interviewed 
officials in EPA Region I, Region III, Region IV, and Region VIII. 

[76] Pub. L. No. 113-76, div. H, title V, § 526, 128 Stat. 5, 413-416 
(Jan. 17, 2014). 

[77] We did not interview local governments about EPA's performance 
partnerships because federal EPA regional and association officials 
indicated there is minimal local involvement associated with 
administering these grants. 

[End of section] 

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