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Juvenile Justice Grants: The Office of Justice Programs Could Improve the Quality of a Key Fraud Control

GAO-21-302 Published: Mar 31, 2021. Publicly Released: Mar 31, 2021.
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Fast Facts

The Department of Justice's Inspector General has found instances of potential fraud, waste, and abuse in programs of DOJ's Office of Juvenile Justice and Delinquency Prevention. This office awarded nearly $874 million in grants from FY 2017-2019.

DOJ assigns a risk score to each grant to help determine a monitoring priority—high, medium, or low. DOJ's monitoring efforts can help prevent and detect fraud.

However, we found that 47% of these risk scores were inaccurate in FY 2017-2019, resulting in 13% of grants receiving an inaccurate monitoring priority.

We made 3 recommendations to improve monitoring.

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Highlights

What GAO Found

The Department of Justice's (DOJ) Office of Justice Programs (OJP) assigned inaccurate monitoring priority levels for some Office of Juvenile Justice and Delinquency Prevention (OJJDP) grants from fiscal year 2017 through 2019 through its Grant Assessment Tool (GAT). This may have affected whether these grants were selected for in-depth programmatic or financial monitoring—a primary fraud risk control. Specifically, GAO's analysis of 7 of the 38 GAT risk criteria scores determined that for the 1,336 active OJJDP grants, scoring discrepancies or errors caused the total risk score to be incorrect for 47 percent of all quarterly GAT risk scores (4,207 of 9,029). After correcting the identified scoring discrepancies and errors, GAO recalculated the total risk scores and found that OJP assigned inaccurate monitoring priority levels for approximately 13 percent (1,151 of 9,029) of the quarterly GAT risk scores. (See figure).

Accuracy of Quarterly GAT Risk Scores and Monitoring Priority Levels for OJJDP Grants for Fiscal Years 2017-2019

Accuracy of Quarterly GAT Risk Scores and Monitoring Priority Levels for OJJDP Grants for Fiscal Years 2017-2019

OJP officials identified several potential explanations for the scoring discrepancies and errors, including manual score changes that had not been documented and problems with the technical processes used to transfer data from the Grants Management System into the GAT. OJP officials did not identify these issues until GAO's review, in part because GAT scoring and quality assurance processes had not been documented in policy or standard operating procedures. In October 2020, OJP began using a new system to manage the grant-making process called JustGrants. As a result, OJP has an opportunity to ensure that the issues leading to incorrect GAT risk scores are not replicated in the new system. As part of the implementation of JustGrants, OJP has made or plans to make adjustments to address the issues GAO identified. However, OJP has not yet documented the revised GAT scoring and quality assurance processes, though officials stated they plan to do so. By documenting the GAT scoring and quality assurance processes developed for the JustGrants system, OJP can help ensure that quarterly GAT risk scores are accurately assigned and monitoring priority levels correctly represent the grant's risk level, thereby improving the effectiveness of OJP's fraud risk management efforts.

Why GAO Did This Study

OJJDP administers grant programs to improve positive outcomes for juveniles in the justice system. From fiscal year 2017 through fiscal year 2019, OJJDP awarded 927 grants totaling nearly $874 million. In December 2019, GAO reported that OJP uses tools, including the GAT, which provide insight on fraud risks for OJJDP grants. The GAT assigns quarterly risk scores to all grants based on 38 risk criteria. Based on the total score, OJP assigns a priority level of low, medium or high. The monitoring priority level, as well as other factors, then contributes to monitoring decisions.

The Juvenile Justice Reform Act of 2018 included a provision for GAO to review internal controls intended to prevent fraud, waste, and abuse of OJJDP grant funds.

This report examines the extent to which OJP accurately assigns monitoring priority levels for OJJDP grants through the GAT. GAO reviewed GAT scores for 1,336 OJJDP grants active from October 2017 through September 2019 to identify any scoring inconsistencies with OJP guidance or external data sources for seven GAT risk criteria. GAO then selected a non-generalizable sample of 20 grants for additional review of monitoring results, and interviewed OJP officials.

Recommendations

GAO is making three recommendations, including that OJP document the GAT scoring and quality assurance processes developed for the JustGrants system. DOJ concurred with these recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
Office of Justice Programs The Director of the Office of Audit, Assessment, and Management should document any changes to the GAT data sources and scoring processes resulting from OJP's ongoing review of GAT data extract and workflow processes. (Recommendation 1)
Closed – Implemented
In November 2022, the Office of Audit, Assessment and Management (OAAM) provided us a copy of its standard operating procedure (SOP) for the Post Award Risk Assessment Procedure in JustGrants, the system that replaced the GAT in October 2022. The SOP describes relevant data sources and how those data sources and scoring processes for the Post Award Risk Assessment Procedure will be documented within OAAM's information systems. By taking these steps, OAAM can help ensure that grant risk scores and related monitoring priority levels are based on quality information. In turn, these improvements in its control activities can help DOJ better manage the risk of fraud in its grant programs.
Office of Justice Programs The Director of the Office of Audit, Assessment, and Management should document the GAT scoring and quality assurance processes developed for subaward-related risk criteria within the JustGrants system. (Recommendation 2)
Closed – Implemented
In November 2022, the Office of Audit, Assessment and Management (OAAM) provided us a copy of its standard operating procedure (SOP) for the Post Award Risk Assessment Procedure in JustGrants, the system that replaced the GAT in October 2022. The SOP documents the GAT scoring and quality assurance processes for subaward-related risk criteria as well as other risk criteria. OAAM provided additional documentation demonstrating the documentation of the subaward related risk criteria scoring and processes in its information systems. By taking these steps, OAAM will be better positioned to identify and remediate errors associated with the subaward-related risk criteria in a timely manner. Doing so will also help OJP improve its monitoring of grantees with subawards, which it identified as an indicator of fraud risk.
Office of Justice Programs The Director of the Office of Audit, Assessment, and Management should document the GAT quality assurance processes for both new and existing GAT risk criteria within the JustGrants system, to include requirements associated with manual scoring changes. (Recommendation 3)
Closed – Implemented
In November 2022, the Office of Audit, Assessment and Management (OAAM) provided us a copy of its standard operating procedure (SOP) for the Post Award Risk Assessment Procedure in JustGrants, the system that replaced the GAT in October 2022. The SOP documents the scoring and quality assurance processes for risk criteria included in the Post Award Risk Assessment Procedure. The SOP also describes documentation requirements for the scoring methodology and validation process as well as documentation of any manual scoring changes that may occur. By clearly documenting the quality assurance processes for risk criteria included in the Post Award Risk Assessment Procedure in JustGrants, to include requirements associated with manual scoring changes, OJP is better positioned to ensure that risk scores are accurately assigned and monitoring priority levels correctly represent a grant's risk level. This could help improve OJP's ability to effectively monitor and respond to risks, including the risk of grant fraud.

Full Report

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Agency evaluationsCompliance oversightCriminal investigationsFederal assistance programsFederal funding accountabilityFederal fundsFederal spendingFinancial reportingGrant managementGrant monitoringGrant programsHigh-risk listInternal controlsJuvenile justicePublic affairsQuality assuranceRisk assessmentRisk managementUntimely protests