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Office of Justice Programs Offender Reentry Initiatives Report 2010

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OFFICE OF JUSTICE PROGRAMS’

MANAGEMENT OF ITS

OFFENDER REENTRY INITIATIVES

U.S. Department of Justice

Office of the Inspector General

Audit Division

Audit Report 10-34

July 2010


OFFICE OF JUSTICE PROGRAMS’

MANAGEMENT OF ITS

OFFENDER REENTRY INITIATIVES

EXECUTIVE SUMMARY

State and local agencies, law enforcement, and community groups
face significant challenges in integrating released inmates back into society
and preventing recidivism. Over 650,000 individuals are released from
federal and state prisons annually and a greater number reenter
communities from local jails. According to the Office of Justice Programs
(OJP), over 50 percent of those released from prison will be in some form of
legal trouble within 3 years. 1
OJP has been making a concerted effort to attempt to break the cycle
of reincarceration and to successfully reintegrate offenders into their
communities. In particular, since fiscal year (FY) 2002 OJP has implemented
three offender reentry grant programs to help state, local, and community
organizations provide assistance to released inmates when they transition
from incarceration to life outside prison. The three grant programs are the
Serious and Violent Offender Reentry Initiative (SVORI), the Prisoner
Reentry Initiative (PRI), and the Second Chance Act Prisoner Reentry
Initiative (SCA). The three programs share a common goal: to reduce the
recidivism of offenders released from prison into communities nationwide.
OIG Audit Approach
The objective of this audit was to examine OJP’s design and
management of its three prisoner reentry grant programs. The scope of our
audit covered the development of the SVORI grant program in FY 2002 and
also covered subsequent OJP reentry grant programs through January 2010.
We performed audit work at OJP headquarters, including at the offices
of the Bureau of Justice Assistance (BJA), Office of Juvenile Justice and
Delinquency Prevention (OJJDP), and the National Institute of Justice (NIJ).
In addition, we interviewed officials at the Office of Community Oriented
Policing Services (COPS) and the Department of Labor (DOL) to assess
federal reentry efforts. We reviewed laws, regulations, and other guidance
1

Office of Justice Programs, “Reentry,” http://www.reentry.gov (accessed
December 9, 2009).

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regarding OJP’s reentry program grants funding, design, management,
administration, award activities, policies, and procedures. In addition, we
reviewed documentation related to the reentry grant programs, including
program solicitations, grant award documentation, and monitoring
documentation relating to grants awarded between FYs 2002 through 2009.
We also conducted a case file review to assess the extent of OJP’s
monitoring efforts. In addition, we reviewed the administration of the
reentry grant awards by a sample of grantees. Overall, we reviewed 10
SVORI grants, 24 SVORI grant files, 10 PRI grants, and 23 PRI grant files.
Appendix I contains a more detailed description of our audit objectives,
scope, and methodology.
Because the initial SCA grants were awarded in September 2009, we
could not evaluate the monitoring and effectiveness of the SCA grant
program. Our discussion related to the SCA grant program is limited to the
adequacy of the performance measures designed to monitor the program’s
progress.
Results in Brief
OJP did not establish an effective system for monitoring the SVORI and
PRI grantees to assess whether they were meeting program goals. Our
review of OJP’s official SVORI grant files identified little to no documentation
of grant monitoring activities. Monitoring activities are crucial in identifying
grantee progress toward achieving program goals. While we noted an
increase in documented grant monitoring activities for the PRI grant
program, we found a reduced quality in the desk reviews prepared for the
PRI grant program.
Our audit also identified significant design flaws in the initial
implementation of OJP’s SVORI and PRI reentry grant programs. We did not
find design flaws with OJP’s SCA reentry grant programs. We found that OJP
did not adequately define key terms essential for determining whether
program goals were met, did not require grantees to identify baseline
recidivism rates needed to calculate changes in recidivism, and did not
analyze performance measurement data. As a result of these design flaws,
neither OJP nor the OIG could definitively determine the effectiveness of
OJP’s grant programs in reducing recidivism. Additionally, an independent
national evaluation of the SVORI grant program’s effectiveness concluded
that the program had no significant impact on participant recidivism. We
believe that OJP should ensure that its reentry grant programs are designed
to allow it to determine whether the goal of reducing recidivism is achieved.
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In our report, we make 11 recommendations to assist OJP in designing
and managing current and future reentry grant programs.
Background
OJP awards grants to state and local organizations to develop or
strengthen offender reentry grant programs. Between FYs 2002 and 2004
OJP awarded $116.8 million for its SVORI grant program to individual
grantees in all 50 states. OJP also awarded nearly $12 million for a
nationwide evaluation of the SVORI grant program to determine the
program’s effectiveness in reducing offender recidivism.
Between FYs 2006 and 2008, OJP awarded individual grants in 35
different states and the District of Columbia totaling almost $34 million for
its PRI grant program. In FY 2009 OJP awarded individual grants totaling
$11.4 million for its SCA grant program. In total, from FY 2002 through
FY 2009, OJP awarded $173.9 million and 154 grants through its offender
reentry grant programs.
OJP received $37 million for its FY 2010 SCA demonstration grant
program. As of April 2010, none of this funding was awarded.
Administration and Management of OJP’s Offender Reentry
Programs
We reviewed OJP’s administration and management of the SVORI and
PRI grant programs and found several weaknesses. Specifically, in our
audits of 10 SVORI grants totaling $17.9 million, we found little
documentation of grantee monitoring and we questioned about $5.2 million
in grant expenditures. Six of the 10 SVORI grantees either failed to
accomplish stated grant goals and objectives or their success in achieving
those goals was questionable.
Our review of 23 PRI grants found that OJP did a better job of
monitoring these grants with an increased number of desk reviews, on-site
visits, and increased compliance with financial and programmatic reporting
requirements. OJP implemented a policy requiring annual desk reviews in
April 2008. However, we found a decrease in the proper preparation and
completion of the PRI desk reviews. A desk review or desk monitoring
consists of OJP reviewing grant files at OJP to ensure they are current,
accurate, and complete. While an increase in the frequency of OJP’s
monitoring efforts is encouraging, we believe that OJP should improve the
quality of its monitoring to ensure grantees are making progress in
accomplishing programmatic goals.
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Design of OJP’s Offender Reentry Grant Programs
Appropriate design of grant programs includes decisions on what data
will be collected and who will collect and analyze the data to determine
program effectiveness. We reviewed the design of OJP’s three offender
reentry grant programs and found initial design flaws that we believe
prevented an adequate determination of the effectiveness of the SVORI and
PRI grant programs. The SCA grant program had addressed or was in the
process of addressing the design flaws identified in the SVORI and PRI grant
programs. The following sections describe the design flaws and their impact
on an evaluation of program effectiveness.
Inability to Adequately Measure Recidivism
We identified deficiencies in the design of the SVORI and PRI programs
that included: (1) an inadequate or inconsistent definition of recidivism;
(2) no requirement for reentry grantees to establish a baseline recidivism
rate against which later recidivism rates could be compared; and (3) a delay
in establishing performance measures and the absence of data analysis.
The SVORI solicitations issued between FYs 2002 and 2004 lacked a
sufficient measurable definition of recidivism. For example, SVORI’s FY 2002
solicitation referred to recidivism as the commission of new crimes by
offenders after their release from prison. However, this definition did not
specify a timeframe after release in which to track a program participant’s
new offense. With no timeframe specified, a comparison of recidivism rates
cannot be made.
OJP also did not include a definition of recidivism in three PRI grant
program solicitations for FYs 2006 through 2008. However, in January 2009
BJA disseminated revised program requirements to its PRI grantees that
included a measurable definition of recidivism “. . . as a return to prison with
a new conviction or supervision within 12 months of release.” Similarly, in
the FY 2009 and FY 2010 SCA reentry grant program solicitations, OJP
included a measurable definition of recidivism as a return to a detention or
incarceration facility “. . . with either a new conviction or as the result of a
violation of the terms of supervision within 12 months of initial release.”
Further, we found that OJP did not require its SVORI, PRI, and SCA
grantees to submit baseline recidivism rates. An accurate assessment of
reductions in recidivism cannot be made without a baseline recidivism rate.
When we asked why grantees in each of the three reentry grant
programs were not required to identify a baseline recidivism rate, the Acting
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Administrator of OJJDP stated that he did not know. The Acting Director of
BJA stated that he did not believe OJP should request grantee baseline
recidivism rates because the target population and geographic location of
grant programs may change after a grant is awarded but prior to the
implementation of the grant program.
However, we believe that while the target population and geographic
location of a grant program may undergo changes after a grant has been
awarded, OJP should still require grantees to submit baseline recidivism
rates once the target populations and geographic areas for the grants have
been finalized. Without this information, it is impossible to determine
changes in the recidivism rates of participants. We recommend that OJP
require baseline recidivism rates from its grantees so that historical and
current recidivism rates can be compared to assess the grant programs’
effects on recidivism.
Performance Measures
OJP did not develop performance measures in the first 2 years of the
SVORI grant program, and OJP officials could not provide us with an
explanation for why performance measurements were not developed during
this time period. In FY 2004, however, OJP developed 11 performance
measures for which SVORI grantees were required to provide data.
Yet, after establishing the SVORI program performance
measurements, BJA and OJJDP program managers did not review the data
for accuracy or use it to assess whether the grantees were meeting their
performance goals. OJP officials stated that its Grants Management System
was not an adequate performance measurement collection system because it
did not perform any type of data analysis and grantees were allowed to
submit data that did not address the required performance measures. Also,
OJP officials told us that a process for assessing SVORI grantee performance
measurement data was never developed.
For the PRI reentry grant program, we found that OJP developed
performance measures that were timely provided to grantees in FYs 2006
through 2008. However, as with SVORI, OJP did not analyze the
performance measurement data it received to determine whether or not
program goals were achieved.
According to OJP officials, a new analytical tool, the Performance
Measurement Tool, will be used to collect program data for the SCA reentry
grant program. OJP officials stated it will contain automatic controls to
ensure grantees provide the appropriate type of information for each
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performance measurement, such as whether the information should be
submitted in a numeric or narrative form. In addition, the Performance
Measurement Tool will allow OJP to produce real-time reports and more
efficiently analyze the data collected.
Target Population
During our review we found that OJP did not provide a clear definition
of the target population for the grant programs, or who should receive grant
program services. Each individual grantee decided what crimes were serious
and violent leading to inconsistent offender participation among different
SVORI grantees. This made grant program comparison difficult because
different types of participants have varying rates of recidivism. For OJP’s
PRI reentry grant program, each of the 3 fiscal years had different target
population definitions.
For the SCA reentry grant program, we noted that OJP is allowing each
grantee to determine its own target population. OJP’s decision to allow
grantees the flexibility of determining their own target population is
legislatively consistent. However, we recommend that OJP require the
grantee definition to be clearly stated and communicated to OJP.
Effectiveness of OJP’s Reentry Grant Programs
One potential measure of the effectiveness of reentry programs is its
impact on the rate of recidivism. 2 However, as noted above, we could not
determine the impact of OJP’s grant programs on the rate of recidivism due
to program design flaws.
OJP’s $12 million independent national evaluation of the SVORI grant
program found that the program had no significant impact on participant
recidivism. OIG audits and reviews also identified several grants that were
unsuccessful because of failure to meet stated goals and objectives, and for
the majority of grants, we could not verify success because of a lack of
adequate support related to performance measures.
Study of Effectiveness
We reviewed the national evaluation that NIJ commissioned through
$12 million in grants to RTI International and the Urban Institute. This
evaluation found that although SVORI program participation increased the
2

A successful reentry program should either reduce the rate of recidivism or, if
recidivism is going up for other reasons, slow the increase in the rate of recidivism.

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likelihood that participants would receive a wide range of services, it did not
have a significant impact on recidivism.
Offender Reentry Grant Reviews
We selected a judgmental sample of 10 SVORI grants and 10 PRI
grants to review and assess the effectiveness of individual reentry programs.
We found grantees generally established reentry programs and provided
services to program participants. However, we found that most of the
sampled SVORI grantees did not maintain adequate documentation to
support performance measurement data, thereby making any evaluation of
recidivism questionable.
We found that PRI grantees established reentry programs in which
participants received services. Unlike the SVORI grantees, we found that
some sample PRI grantees did maintain support for their performance
measurement data.
Offender Reentry Program Evaluations
Four of the 10 sampled SVORI grantees had local evaluations
conducted of their SVORI reentry program which contained information on
program recidivism. We reviewed these evaluations which were typically
conducted by the state government or a university. The results of the four
local effectiveness evaluations were inconclusive.
Conclusion and Recommendations
We found that grantee administration of reentry grants improved as
the OJP reentry programs evolved. In the PRI grant program, OJP improved
its collection and retention of administrative grant documentation. OJP also
implemented a policy to require annual desk reviews. We found an
increased frequency of grant monitoring, but also an increased likelihood of
improper review and documentation of desk reviews. We noted that PRI
grantees submitted to OJP required performance measurement data;
however, OJP program managers failed to adequately review them.
We also identified deficiencies in OJP’s design of its offender reentry
grant programs. Specifically, we found that OJP was unable to adequately
measure recidivism because OJP: (1) did not clearly define, document, and
communicate key programmatic terms for the SVORI and PRI grant
programs; (2) did not request baseline recidivism data from grantees at the
beginning of all three offender reentry programs; and (3) did not develop
and utilize a process for assessing performance measurement data collected
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from its SVORI and PRI grantees. These design deficiencies hindered OJP’s
ability to evaluate whether its offender reentry programs reduced recidivism.
In this report, we make a total of 11 recommendations to OJP,
including that it:
•	 require that reentry grantees monitor grant performance to ensure
they achieve program goals and objectives;
•	 develop a consistent definition of recidivism and ensure it is
disseminated to all recipients of reentry grants;
•	 require reentry grantees to establish baseline recidivism rates to
facilitate comparison of recidivism rates between participants of
reentry programs and non-participants;
•	 review past offender reentry programs to identify best practices,
lessons learned, and problems to be avoided when developing and
implementing new reentry programs; and
•	 develop a process for assessing and analyzing performance
measurement data from grantees to determine if program goals are
being met, including whether recidivism has decreased.

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TABLE OF CONTENTS

Page
INTRODUCTION .............................................................................. 1

OJP’s Reentry Initiatives ............................................................1

Prior OIG and GAO Reports ........................................................7

OIG Audit Approach................................................................. 10

FINDINGS AND RECOMMENDATIONS............................................ 11

I. 	ADMINISTRATION AND MANAGEMENT OF OJP’S OFFENDER

REENTRY PROGRAMS .......................................................... 11

OJP’s SVORI Grant Program Monitoring Efforts............................ 11

OIG SVORI Grant Program Review Results ................................. 14

OJP’s PRI Grant Program Monitoring Efforts ................................ 17

OIG PRI Grant Program Review Results...................................... 19

Second Chance Act Offender Reentry Grant Program Monitoring ... 21

Recommendations................................................................... 23

II. DESIGN OF OJP’S OFFENDER REENTRY GRANT PROGRAMS . 24

Design of Offender Reentry Programs ........................................ 24

Effectiveness of OJP’s Reentry Grant Programs ........................... 32

Recommendations................................................................... 41

STATEMENT ON COMPLIANCE WITH LAWS AND REGULATIONS.... 43

STATEMENT ON INTERNAL CONTROLS.......................................... 45

APPENDIX I:	

Objectives, Scope, and Methodology ................... 46


APPENDIX II:	 SVORI Grantees Included in RTI International’s

Nationwide Evaluation......................................... 56

APPENDIX III: Dollar-Related Findings Resulting From SVORI

Grant Audits ........................................................ 58

APPENDIX IV:	 The Office of Justice Program’s Response ........... 59

APPENDIX V:	

Office of the Inspector General Analysis

and Summary of Actions Necessary to Close

the Report ........................................................... 64


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INTRODUCTION
Over 650,000 people in the United States are released from federal
and state prisons annually and a greater number reenter communities from
local jails. According to the U.S. Department of Justice (DOJ) Office of
Justice Programs’ (OJP), over 50 percent of those released from prison will
be in some form of legal trouble within 3 years. 3 A significant challenge to
state and local agencies, law enforcement, and community groups is to
prevent recidivism among released inmates. 4
Based on legislative mandates in fiscal year (FY) 2002 through
FY 2010, OJP established three offender reentry grant programs to help
state, local, and community organizations provide assistance to released
inmates as they transition from incarceration to life outside prison. These
three programs are the Serious and Violent Offender Reentry Initiative
(SVORI), the Prisoner Reentry Initiative (PRI), and the Second Chance Act
Prisoner Reentry Initiative (SCA). From FY 2002 through FY 2009, OJP
awarded $173.9 million and 154 grants under these three programs that
share a common goal: to reduce the recidivism of offenders released from
prison into communities nationwide.
The objective of this audit was to examine OJP’s design and
management of its prisoner reentry initiatives. 5 The scope of our audit
covered the development of the SVORI grant program in FY 2002 through
the SCA grant program as of January 2010.
OJP’s Reentry Initiatives
OJP has been awarding grants to state and municipal organizations for
the purpose of developing or strengthening their offender reentry programs
since FY 2002.

3

Office of Justice Programs, “Reentry,” http://www.reentry.gov (accessed
December 9, 2009).
4

OJP’s 2002 Serious and Violent Offender Reentry Initiative (SVORI) solicitation
defined recidivism as offenders who will commit new crimes after their release from prison.
The term recidivism was then left undefined in all offender reentry program information
from FY 2003 until BJA and OJJDP’s 2009 Second Chance Act Prisoner Reentry Initiative
program solicitations were created. These program solicitations both defined recidivism as
a return to prison, jail, or juvenile residential facility “with either a new conviction or as the
result of a violation of the terms of supervision within 12 months of initial release.”
5

See Appendix I for the objective, scope, and methodology of this audit.

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Serious and Violent Offender Reentry Initiative
In January 2002, OJP posted a solicitation for an offender reentry
discretionary grant program entitled the “Serious and Violent Offender
Reentry Initiative: Going Home.” 6 This program was a collaborative effort
between the DOJ and its federal funding partners, the Departments of Labor
and Health and Human Services. 7 Exhibit 1 summarizes the total amount
that OJP awarded for the SVORI discretionary grant programs.
EXHIBIT 1

SERIOUS AND VIOLENT OFFENDER

REENTRY INITIATIVE FUNDING AWARDED

Fiscal Year
2002
2003
2004
Total

Amount Awarded
$99,519,244
$10,616,075
$6,676,863
$116,812,182

Number of Grantees 8
68
66
62

Source: OJP

Other participating but non-funding federal partners included the
Departments of Veterans Affairs, Education, Housing and Urban
Development, and the Social Security Administration. The goal of this
collaboration was to pool resources to increase the effectiveness of the
SVORI grant program. While other federal agencies contributed funding for
the SVORI grant program, the Bureau of Justice Assistance (BJA) and the
Office of Juvenile Justice and Delinquency Prevention (OJJDP) managed the
grant program, including awarding grant funds and monitoring grantee
activities.
Overall, 69 grants totaling $116.8 million were awarded during the
SVORI grant program. Initial SVORI grant funding was awarded in FY 2002
6

According to the 2002 OJP Financial Guide, discretionary grant awards are made to
states, units of local government, or private organizations at the discretion of the awarding
agency (OJP). Most discretionary awards are competitive in nature because there are
limited funds available and a large number of potential recipients.
7

In FYs 2002 and 2003, the Departments of Labor and Health and Human Services
transferred approximately $52.6 million and $16 million, respectively to OJP to fund SVORI
reentry grants.
8

Ultimately, there were 69 SVORI grantees. However, only 68 received their initial
SVORI grant award in FY 2002. The 69th grantee, Nebraska Department of Correctional
Services (NDCS), received its initial SVORI grant award in FY 2003. In FY 2003 there were
also 65 supplemental grants awarded. All 62 awards in FY 2004 were supplemental grants.

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to grantees in 49 states, the District of Columbia, and the U.S. Virgin
Islands. 9 In FY 2003, supplemental funding was awarded for mental health
and substance abuse services. In FY 2004, a second round of supplemental
grant funding was awarded for grantee training, to enhance promising
practices in specific program areas, and to expand the SVORI grant program
by serving offenders in established Weed and Seed geographic target
areas. 10
The goal of the SVORI grant program was to reduce recidivism among
high-risk offenders by providing services to high-risk offenders who faced
multiple challenges upon returning to the community from incarceration. To
achieve this goal, the SVORI grant program emphasized fostering working
relationships among service providers to more effectively deliver services to
reentering offenders. Using grant funds, grantees either built upon existing
local reentry programs or developed new reentry programs. The local
reentry programs provided services, such as substance abuse services and
employment and training assistance, to ease the transition back into the
community.
OJP made its last SVORI grant award in FY 2004, but grantees
nationwide continued to administer SVORI grants until their individual end
dates, which ranged from FY 2005 to FY 2009. 11 In total, approximately

9

Ultimately, there were 69 SVORI grantees. However, only 68 received their initial
SVORI grant award in FY 2002. The 69th grantee, Nebraska Department of Correctional
Services (NDCS), received its initial SVORI grant award in FY 2003. In FY 2003 there were
also 65 supplemental grants awarded. All 62 awards in FY 2004 were supplemental grants.
10

The 2004 SVORI solicitation stated that supplemental funding was to build or
enhance, among other things, a promising practice, such as, for example, offender risk
assessments, successful housing placements, coordinated case management, or an increase
in the participation of faith-based and community organizations. Promising practices were
those deemed likely to reduce recidivism.
Weed and Seed is a grant program that aims to prevent, control, and reduce violent
crime, drug abuse, and gang activity in designated high-crime neighborhoods across the
country. The more than 250 Weed and Seed sites range in size from several neighborhood
blocks to several square miles, with populations ranging from 3,000 to 50,000.
11

The SVORI grant program was designed so that the initial grant awards made in
FY 2002 were for a 3-year period. Program extensions were approved for some grantees.
As of April 2010, only the State of New Hampshire’s SVORI grant program was still
operating. It was scheduled to end in March 2010.

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$116.8 million in SVORI grant funding was awarded from FYs 2002 through
2004. 12 OJP awarded each grantee an average of $1.7 million.
In addition to the $116.8 million in SVORI grant funding, OJP’s
National Institute of Justice (NIJ) also awarded approximately $12 million in
FYs 2003 and 2004 for an independent evaluation of the SVORI grant
program. The intent of this evaluation was to determine the SVORI grant
program’s impact on recidivism and its overall effectiveness. The evaluators
measured the costs and impact of individual reentry programs that received
funding under the SVORI grant program. Some SVORI grantees also chose
to conduct their own local program evaluations. We discuss both the NIJ
funded evaluation and some of the individual local evaluations in Finding 1 of
this report.
Prisoner Reentry Initiative
The Prisoner Reentry Initiative (PRI) grant program was a continuation
of OJP’s efforts to fund the reintegration of prisoners into the community.
OJP again collaborated with the DOL, but under this initiative each agency
received its own grant funding to administer and award. OJP limited direct
funding to state agencies and federally recognized Indian tribes, while the
DOL made its grant funding available directly to faith-based and community
organizations. 13
During FYs 2006 through 2008, OJP awarded 63 PRI grants totaling
$34 million to state agencies in 35 states and the District of Columbia.
Exhibit 2 summarizes the total amount that OJP awarded for the PRI
discretionary grant program.

12

The $116.4 million awarded to grantees included supplemental funding awarded
under the SVORI program in FYs 2003 and 2004.
13

OJP did not prohibit faith-based and community organizations from being subrecipients of its PRI grant funds. Rather, all PRI grants were made to state agencies,
typically state departments of corrections, or federally recognized Indian tribes.

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EXHIBIT 2

PRISONER REENTRY INITIATIVE FUNDING AWARDED

Fiscal Year
2006
2007
2008
Total

Amount Awarded
$13,384,783
$10,084,969
$10,251,787
$33,721,539

Number of Grantees
20
23
20
63 14

Source: OJP

The PRI grant funding and targeted offender populations varied each
year. OJP had discretion with its PRI grant program funding because the
legislation in the accompanying appropriation laws for each fiscal year was
general and did not contain any restrictions such as limitations on the target
population or the type of services that could be funded. The majority of the
OJP grants funded under the PRI grant program remained active during our
fieldwork, which ended in January 2010. Exhibit 3 shows OJP’s selfestablished funding restrictions by fiscal year.

14

A total of 43 unique grantees received 1-year grants under the PRI grant program
between FYs 2006 and 2008. Some of these grantees received multiple grants over the 3year period and were counted separately under each year.

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EXHIBIT 3

PRI GRANT PROGRAM PARTICIPANT AND FUNDING RESTRICTIONS

BY FISCAL YEAR

Fiscal
Year

Participant Restrictions 15
No juvenile offenders

Funding Restrictions
Pre-release: OJP funding could be used
for any pre-release service.

No sex offenders

2006

Violent offenders allowed
upon receiving a waiver from
OJP
No juvenile offenders

Post-release: OJP funding could not be
used for post-release services. DOL was
responsible for post-release services.
Pre-release: OJP funding could be used
for any service.

No sex offenders

2007

Violent offenders allowed
upon receiving a waiver from
OJP
No juvenile offenders
2008

No sex offenders

Post-release: OJP funds passed through
the grantee to faith-based and community
organizations could only be used for postrelease employment services.
Pre-release: OJP funding could be used
for any service.
Post-release: OJP funds passed through
the grantee to faith-based and community
organizations could be used for any
service.

Source: OJP

The PRI grant program shared a common objective similar to that of
the SVORI grant program – to reduce recidivism by helping released inmates
find work and to provide them access to other critical services in their
communities. However, the PRI grant programs differed from the SVORI
grant program in the following ways: (1) juvenile offenders were not
allowed to participate in the PRI program; (2) offenders released from local
incarceration facilities were eligible to participate in the PRI grant programs
but were not eligible for the SVORI program; and (3) non-violent offenders
were allowed to participate in the PRI program but not SVORI.
An assessment of the 2006 PRI grant program was conducted by a BJA
training and technical assistance contractor. The assessment focused on:
(1) the degree to which PRI grantees had been able to achieve the goals of
the initiative; (2) the nature of pre-release services provided; and (3) issues
relating to internal BJA operations and coordination with the DOL faith based
15

The FY 2007 PRI grant solicitation omitted the no sex offender requirement and
the violent offender’s waiver.

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community organizations providing pre-release services. This evaluation is
discussed in detail in Finding 1 of this report.
Second Chance Act Prisoner Reentry Initiative
In April 2008, the President signed into law the Second Chance Act of
2007. The SCA’s stated purpose was “to build upon the innovative and
successful State reentry programs developed under the SVORI.” 16 The SCA
adopted and enhanced key elements of the PRI grant program, such as drug
treatment, mentoring, and transitional services for ex-offenders through
partnerships with local corrections agencies and faith-based and community
organizations.
While the SVORI and PRI grant programs limited the eligibility of
participants, the SCA legislation and solicitations allow each grant applicant
to define program participant eligibility. This allowed grantees to address
what they consider the most significant issues facing their community.
In September 2009, OJP awarded 20 SCA grants totaling
$11.4 million. In FY 2010, Congress appropriated $37 million for the
FY 2010 SCA offender reentry demonstration grant programs. As of
April 2010, these funds had not yet been awarded. 17
Prior OIG and GAO Reports
The Department of Justice Office of the Inspector General (OIG) and
the Government Accountability Office (GAO) have previously reported on
DOJ’s grant monitoring and documentation efforts, as well as DOJ’s offender
reentry efforts within OJP. These reports are summarized below.
Office of the Inspector General Reports
From January 2005 through September 2008, the OIG issued four
audit reports on the SVORI program grants that identified significant
deficiencies in OJP’s oversight of the grants and the grantees’ use of the

16

42 U.S.C.A. § 17501 (2008).

17

Overall, OJP was appropriated $100 million for offender reentry programs as part
of the SCA legislation in FY 2010.

-7-

funds. 18 Specifically, the four reports found that grantees: (1) did not
properly monitor their sub-grantees; (2) did not properly monitor their
contractors; and (3) claimed and were reimbursed for unallowable and
unsupported costs. As a result of these and other deficiencies, the OIG
questioned $1,782,952 in grant expenditures. 19
Additionally, for the past 10 years the OIG has identified grant
management as 1 of DOJ’s top 10 management challenges. Specifically, the
OIG top challenges reported that grant management continues to be a
challenge within the DOJ for several reasons, including the following:
•	 Many grantees do not submit required financial and progress
reports or do not submit them in a timely fashion.
•	 DOJ’s granting agencies struggle with effectively monitoring
grantees’ activities.
•	 OJP has not consistently awarded grant funds in a timely manner.
•	 Grantees continue to spend significant amounts of OJP grant funds
on unallowable and unsupported costs and do not consistently
comply with applicable laws, regulations, and terms and conditions
of the grants, resulting in significant dollar-related findings.
U.S. Government Accountability Office Reports
The GAO did not review any of OJP’s reentry grant programs (SVORI,
PRI, or SCA). However, GAO has reviewed general grant management
issues in DOJ, and some of GAO’s findings relate to the reentry grant
programs that we reviewed.

18

See Office of Justice Programs Serious and Violent Offender Reentry Initiative
Grant Awarded to the City of Oakland, California, Audit Report GR-90-08-004 (September
2008); Office of Justice Programs Serious and Violent Offender Re-Entry Initiative Grant
Administered by the Michigan Department of Corrections Lansing, Michigan, Audit Report
GR-50-05-004 (January 28, 2005); Office of Justice Programs Grants Awarded to the
Washington Department of Corrections Olympia, Washington, Audit Report GR-90-08-002
(March 2008); and Office of Justice Programs Grant Awarded to the Colorado Department of
Corrections Colorado Springs, Colorado, Audit Report GR-60-05-006 (April 2005). See
Appendix I for additional details.
19

Finding II and Appendix I of this report contain more detail about the results of
these audits.

-8-

In January 2003, the GAO released a report as part of a series of
reviews on DOJ management challenges. 20 In its report, GAO identified long
standing issues regarding grant management, including the lack of
necessary documentation to verify that monitoring activities occurred for
discretionary grant programs. The GAO recommended that OJP:
•	 develop procedures to systematically review case files to ensure
consistent documentation across OJP; and
•	 explore methods of electronically maintaining grant documentation
with the goal being to facilitate more consistent documentation,
more accessible management oversight, and sound performance
measurement.
The GAO’s October 2001 grant report stated that the OJJDP grant files
lacked sufficient documentation of telephone contacts, site visits, progress
and financial reports, and closeout procedures. Additionally, the GAO
concluded that OJJDP was neither systematically overseeing grant managers’
compliance with its monitoring requirements nor assessing the effectiveness
of OJJDP’s grant monitoring practices. The GAO recommended that:
•	 the OJJDP assess whether the shortcomings resulted from a lack of
grant monitoring activities or from a failure to document those
activities;
•	 if OJJDP determined that grant monitoring was not taking place,
investigate why and develop solutions to address these deficiencies;
and
•	 if there was a failure to document grant monitoring activities, OJJDP
develop and enforce clear expectations regarding monitoring
requirements and that supervisory review be included in any new
policies to ensure grant monitoring activities occur.
Although these findings and recommendations are 9 years old, we
believe that they are relevant to our review because we identified similar
findings in this audit.

20

U.S. Government Accountability Office, Major Management Challenges and
Program Risks: Department of Justice, GAO-03-105 (January 2003).

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OIG Audit Approach
The objective of this audit was to examine OJP’s design and
management of its three prisoner reentry grant programs. The scope of our
audit covered the development of the SVORI grant program in FY 2002 and
subsequent OJP reentry grant programs through January 2010.
We performed audit work at OJP headquarters, including, the offices of
the BJA, OJJDP, and the NIJ. In addition, we conducted additional audit
work at the Office of Community Oriented Policing Services (COPS) and the
DOL headquarters. 21 We also reviewed 10 SVORI and 10 PRI grants. 22
To accomplish our objective, we conducted the following audit work:
•	 reviewed laws, regulations, and other guidance regarding OJP’s
reentry program grant funding, design, management,
administration, award activities, policies, and procedures;
•	 interviewed OJP, BJA, OJJDP, COPS, and grantee officials
responsible for the design, implementation, and evaluation of the
prisoner reentry grant programs;
•	 reviewed documentation related to the reentry grant programs,
including program solicitations, grant award documentation, and
monitoring documentation relating to grants awarded between
FYs 2002 through 2009;
•	 analyzed the results of nine OIG audits of reentry grant programs
issued from January 2005 through November 2009; and
•	 analyzed the responses to the previously issued OIG and GAO
reports to determine if corrective actions had been taken or
initiated for insufficiencies identified.
More details on the audit objective, scope, and methodology are
presented in Appendix I.

21

In FYs 2001 through 2009, COPS transferred over $120 million to OJP to fund
reentry grants.
22	

See Appendix I of this report for a list of grantees and awards we reviewed.

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FINDINGS AND RECOMMENDATIONS
I.	

ADMINISTRATION AND MANAGEMENT OF OJP’S
OFFENDER REENTRY PROGRAMS
Our audits of 10 SVORI grantees found that grantee
program compliance and performance was inadequate, and
we questioned grant expenditures totaling about
$5.2 million. 23 Furthermore, a review of OJP’s official
SVORI grant files identified little to no documentation of
grant monitoring activities, such as desk reviews. These
monitoring activities are crucial to assess the quality of
grantee data, as well as grantee progress toward achieving
program goals — both of which are necessary to assess
the effectiveness of the reentry grant programs. While we
saw an increase in documentation of grant monitoring
activities for the PRI grant program, monitoring
deficiencies remained. We recommend that OJP establish
a more effective system of monitoring SCA grant programs
to identify program issues early and to make adjustments
when necessary to improve program performance.

OJP’s SVORI Grant Program Monitoring Efforts
Policy advisors in OJP’s BJA and OJJDP were responsible for the dayto-day monitoring of the SVORI grantees. 24 In June 2001, OJP developed
the Grant Manager’s Manual to provide a practical tool and reference guide
for the OJP personnel responsible for grant processing, management, and
monitoring. This manual, which was in effect during the SVORI grant
program period, provided general guidance on the broad objectives and
goals for proper grant monitoring and suggested that desk reviews of grant
files should be conducted quarterly. A desk review or desk monitoring
consists of reviewing grant files at OJP to ensure they are current, accurate,
and complete in order to assess grantee performance and compliance.
Because the manual did not provide specific details on how OJP managers
should conduct and document their grant monitoring efforts, we interviewed
OJP officials about this issue.

23

See Appendix III for a table of the questioned costs.

24

Although OJJDP managed 23 of the 69 total SVORI grants, the BJA awarded all 69
SVORI grants.

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According to OJP officials, the monitoring process varied within each
OJP division, and there was not an OJP-wide standardized process for
monitoring grantees or for documenting monitoring efforts. At the inception
of the SVORI grant program in FY 2002, OJP program managers used their
own discretion and knowledge of grants to create annual monitoring plans
and to determine which grants required further review. Each grant manager
was responsible for ensuring that documentation of his or her monitoring
efforts was maintained in both the official grant files and the Grants
Management System for each grant award under his or her purview.
In August 2005, BJA created a Monitoring Guide, which required
the completion of desk reviews semi-annually with deadlines of
March 31 and September 30. 25 In addition, according to the
Monitoring Guide, documentation of completed desk reviews must be
maintained in the Grants Management System.
The Grant Manager’s Manual was revised in April 2008 to require
that desk reviews be conducted approximately once every 6 months
but no less than annually. Prior to this revision, OJP did not have a
policy that stated how often desk reviews should be conducted. The
current Grant Manager’s Manual was revised in October 2008, but
grant monitoring requirements remained the same.
OIG Review of OJP’s SVORI Grant Files
OJP maintains supporting documentation of its management and
administration of OJP grants in official hardcopy files and in the Grants
Management System. Since the Grants Management System’s inception in
2002, OJP has slowly converted to maintaining grant documents primarily in
electronic format.
We reviewed the Grants Management System and hardcopy files for
evidence of desk reviews, onsite visits, telephone and e-mail contacts with
the grantee and other available monitoring documentation. To assess OJP’s
monitoring efforts we also reviewed the same grant files to determine the
grantee’s compliance with reporting requirements.
At OJP headquarters, we judgmentally selected and reviewed 24
out of 69 SVORI grantees. According to the information in the Grants
Management System, from August 2002 through June 2009 45 desk
reviews were documented out of a possible 264 semi-annual desk
25

The Bureau of Justice Assistance Monitoring Guide dated August 19, 2005, is a
supplement to chapter 8 of the Grant Manager’s Manual.

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review opportunities for the 24 sampled grantees. Although the
requirements for preparing desk reviews changed between 2002 and
2009, we believe that OJP should have conducted and documented
more desk reviews than the 45 that we identified.
We also found that 40 percent of the desk reviews performed
were either incomplete or improperly prepared and nearly half of the
desk reviews we examined lacked supervisory signatures and
approvals. We believe desk reviews should be conducted regularly to
ensure grant files are current, accurate, and complete. In addition,
regular desk reviews could identify grantees that are experiencing
difficulties fulfilling the terms of the grant and need more intensive
monitoring, training, and technical assistance.
OJP also monitors grantees by reviewing reports that grantees
are required to submit. The OJP Financial Guide requires grantees to
submit to OJP two types of reports: Financial Status Reports and
program progress reports. Financial Status Reports provide OJP with
information regarding funds spent and the unobligated amounts
remaining for grants. Grantees are required to submit the Financial
Status Reports within 45 days after the end of each calendar quarter.
Program progress reports, which provide information on the status of
funded activities, are required to be submitted to OJP within 30 days
after the end of each semi-annual reporting period.
We examined the SVORI grant files for the 24 sampled grantees
in order to identify evidence of the grantees’ compliance with reporting
requirements. We found that on average, 21 percent of the Financial
Status Reports were submitted late. Further, we found that on
average, 21 percent of the Financial Status Reports could not be
located even though they were identified in OJP’s Grants Management
System as having been submitted to OJP. With regards to semiannual progress reports, we found that on average 53 percent were
submitted late. In addition, an average of 21 percent of the progress
reports could not be located even though they were identified in OJP’s
Grants Management System as having been submitted. All 23 SVORI
grantees whose grants had ended submitted their final progress report
to OJP; however, almost 50 percent of them were submitted an
average of nearly 4 months late. 26 In our opinion, OJP cannot
26

We were unable to compare this aspect of grant monitoring to OJP’s efforts in
monitoring PRI grant programs because the PRI grant program has not ended and final
progress reports have not been submitted.

- 13 -

effectively monitor its grantees without timely financial and
programmatic information.
OIG SVORI Grant Program Review Results
We reviewed 10 SVORI grant audits issued from January 2005 through
November 2009 to determine whether grantees administered the SVORI
programs in compliance with essential grant requirements. The 10 SVORI
grants had a total award amount of $17.9 million. Based on the results of
our external grant audits, we identified significant weaknesses and dollarrelated findings that totaled $5,016,892 in questioned costs (or
approximately 29 percent of the total award amount) and $134,362 in funds
that could be put to better use. 27
We reviewed the results of the individual OIG SVORI grant audits to
identify indications of inadequate OJP monitoring. Specifically, we found
weaknesses in the following areas: (1) monitoring of sub-recipients and
(2) accomplishments and completion of goals. We describe these issues
below.
Monitoring Sub-contractors and Sub-recipients
According to the OJP Financial Guide, the primary recipient of grant
funding is responsible for monitoring grant sub-recipients to ensure that all
fiscal and programmatic responsibilities are fulfilled. During our review of
the OIG external grant audits, we found that 8 of the 10 SVORI grantees we
reviewed had sub-recipients under their grant-funded program. However,
five out of the eight grantees did not adequately monitor grant subrecipients. The monitoring deficiencies included inadequate reviews of subrecipients’ performance and financial documentation to ensure program
records were maintained, accurate, and complete, and that grant funds were
spent appropriately.
Failure to adequately monitor sub-contractors and sub-recipients
increases the risk that grant goals will not be met and increases the risk of
fraud, waste, and abuse.

27

Questioned costs are expenditures that do not comply with legal, regulatory or
contractual requirements, or are not supported by adequate documentation at the time of
the audit, or are unnecessary or unreasonable. Questioned costs may be remedied by
offset, waiver, recovery of funds, or the provision of supporting documentation. Funds that
could be put to better use are future funds that could be used more efficiently if
management took actions to implement and complete audit recommendations. See
Appendix III for the list of questioned costs and funds to better use.

- 14 -

Goals and Accomplishments
Many of the SVORI grantees we reviewed had difficulty meeting the
goals and objectives of their grants. We found that generally the target
populations identified in the grant applications were served under the SVORI
grant program. However, in the Delaware Health and Human Services
(Delaware HHS) and Michigan Department of Corrections grant programs the
number of participants fell short of their stated expectations of how many
participants would complete the reentry programs. For example, at the
Delaware HHS, only 96 of the 303 offenders (32 percent) who started the
post-release phase of the SVORI grant program successfully completed the
program. This is a significant shortfall from the Delaware HHS’s overall goal
of at least 300 offenders successfully completing the program each year for
3 years. While Texas exceeded their planned participation of 150 with 200
participants, only 5 completed the program. Finally, the District of Columbia
had a big disparity between its planned yearly participation of at least 1,200
and their actual participation of 259. Exhibit 4 illustrates the comparison of
anticipated to actual participants in each of the SVORI reentry programs we
reviewed.

- 15 -

EXHIBIT 4

PARTICIPANT INFORMATION FOR SVORI GRANTS


Grantee
Delaware
South Carolina
New York
Texas
Nebraska
District of
Columbia
Michigan
Oakland, California
Washington
Colorado

Number of
Actual
Participants
Admitted
Into
Program

Number of
Participants
Who
Completed
Program

Were all
Participants
Eligible? 28

303

96

Yes

122
128
200
36

32
54
5
2

Yes
Yes
Yes
Yes

259

75

Yes

99

64

At Least 120

Not Reported

5

834
205

Not Reported
Not Reported

24
Not Reported

Not Audited
Could Not
Determine
Yes
Not Audited

Number of
Planned
Participants
300 per year
for 3 years
50 - 60
60
100 - 150
60-90
1,100 or
more per year
At Least 250

Source: OIG Review of Grant Documentation

In addition, 6 of the 10 SVORI grantees we audited ranged from
questionable success to failure in their attempts to meet stated goals and
objectives.
•	 Delaware HHS’s failure to adequately monitor its contractors
resulted in questioned costs of $2,593,494, which was over
99 percent of its grant award of $2,603,234. These questioned
costs consisted primarily of payments to supplement existing
mental health and substance abuse services aimed at increasing
case management capacity and initiating a state-wide reentry
effort.
•	 In New York, two internal reviews conducted by OCFS’ Office of
Strategic Planning and Program Development made
recommendations for improving the program, such as improving
documentation of program activities and enhancing staff size and
training. However, the program continued for more than 2 years
28

Two of the SVORI grant audits, the Michigan Department of Corrections and the
Colorado Department of Corrections, were conducted before the start of this audit and did
not include a review of participant eligibility. The documentation provided by Oakland,
California, did not provide enough information to determine participant eligibility.

- 16 -

and expended over $500,000 in grant funds without taking
significant action on the recommended improvements.
•	 Although the Texas Department of Criminal Justice generally made
adequate progress towards accomplishing SVORI program goals, we
found that 79 out of 117 (68 percent) SVORI participants had
violated their parole and 77 percent had been arrested after their
release. These high recidivism rates could be an indication that the
primary program goal of improving public safety by successfully
reintegrating parolees into the community was not being met, and
the grantee did not have an alternative method for measuring if its
program was successful.
•	 Eight of the nine progress reports submitted by the District of
Columbia Justice Grants Administration did not contain information
on grant activities that could be verified, making it impossible to
assess whether SVORI program goals were met.
•	 The City of Oakland, California, did not exercise adequate
programmatic oversight of its Project Choice program to ensure
that services had been provided to eligible program participants,
that contractors maintained accurate and complete records of
program participants and their outcomes, and that records were
retained for audit purposes.
•	 Although the Washington Department of Corrections generally met
its SVORI program objectives and nearly met their enrollment goal
of 834 with 760 enrolled, 62 percent of participants had been reconvicted for a felony or misdemeanor within 18 months of release
from prison. Washington underwent a local evaluation whose final
results will not be available until 2011.
Six of the eight SVORI grantees whose review included an assessment
of performance reported the performance measures required by OJP.
However, none of these six grantees provided supporting documentation for
the performance measures they reported.
OJP’s PRI Grant Program Monitoring Efforts
OJP’s BJA was responsible for the daily monitoring of the PRI grantees.
As previously stated, in 2005 the BJA published its own monitoring guide as

- 17 -

a supplement to the Grant Manager’s Manual. 29 This guide required semiannual desk reviews. In addition, the revised April 2008 OJP Grant
Manager’s Manual states that desk reviews “should” be conducted semiannually, and are “required” annually.
We judgmentally reviewed 23 out of 63 PRI grant files (printed
and electronic) for evidence of desk reviews, on-site visits, and other
monitoring documentation to assess the extent of OJP’s monitoring
efforts. We also reviewed grantee compliance with reporting
requirements.
From January 2006 through June 2009, OJP conducted 29 desk
reviews. However, we found that 19 (66 percent) of the reviews were
incomplete or improperly prepared and lacked supervisory approvals.
In FY 2008, after the requirement for desk reviews was
established, we found that only 14 of the 23 PRI grants we sampled
had conducted at least 1 desk review. This meant that OJP did not
follow its own requirement for the remaining 9 grants (39 percent) we
sampled.
When we examined the PRI grant files for evidence of the
grantee’s compliance with reporting requirements, we found minor
deficiencies. 30 All required PRI progress reports were submitted. We
believe the improvements that OJP has implemented in the Grants
Management System, including the creation of electronic reminders
when progress reports are due, appear to have played a role in
reducing the number of late and missing Financial Status Reports and
program progress reports identified in the PRI grant files. Overall,
OJP’s development of the Grants Management System has enhanced
its ability to monitor grantees. For example, the Grants Management
System sends electronic reminders to grantees when reports are due.
When reports are not submitted on time, an automatic trigger in the
Grants Management System freezes funds until the reports are
submitted.

29

In the event office-level policy, procedures, or guidance conflict with the
provisions of the Grant Manager’s Manual, the Grant Manager’s Manual is the controlling
document.
30

Of the 23 PRI grantees we reviewed, we found that on average grantees
submitted 1 Financial Status Report late and we could not locate documentation for 2 other
Financial Status Reports.

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In addition, our review of PRI case files identified an increase in
OJP’s grant monitoring activities in the form of more documented desk
reviews, on-site visits, and increased compliance with financial and
programmatic reporting requirements. 31 We found that 40 percent of
the OJP’s SVORI grant program desk reviews were either incomplete
or improperly prepared while our review of the same for the PRI grant
program found evidence that 66 percent were incomplete or
improperly prepared. This represents a significant decrease in the
quality of the desk reviews prepared for the PRI grant programs.
While an increase in the frequency of OJP’s monitoring efforts is
encouraging, OJP should also improve the quality of its monitoring
documentation, which could improve OJP’s responsiveness to grantee
non-compliance, as well as grantee training and technical assistance
needs.
OIG PRI Grant Program Review Results
The OIG conducted PRI grant program reviews to test the grantees’
compliance with essential award conditions relevant to the program’s goals
and accomplishments, reporting (excluding Financial Status Reports), and
monitoring of sub-recipients. As of September 2008, the BJA had awarded
63 PRI grants to state agencies to continue the prisoner reentry programs.
We reviewed 10 PRI grants issued between January 2006 and September
2008. Our PRI grant reviews were limited to examinations of grantee
performance. 32
In our reviews, we identified significant weaknesses related to OJP’s
monitoring of the 10 PRI grant programs, which are described below.
Goals and Accomplishments
We found that the grantees had established reentry programs in which
eligible inmates received the services specified in the grant applications. In
addition, the programs generally provided services in a manner that allowed
the grantees to accomplish the goals and objectives stated in the grants.
However, the 2006 through 2008 PRI grant program solicitations required
that grant programs anticipate at least 200 participants. Exhibit 5 illustrates
31

We found that OJP conducted 29 desk reviews of PRI grant programs within a
span of 3 years versus 45 total desk reviews of SVORI grant programs within a span of
7 years.
32

We did not test grantees’ compliance with: (1) accounting and internal controls,
(2) budget management and controls, (3) expenditures, (4) fund draw-downs, (5) program
income, (6) local matching requirements, and (7) indirect costs.

- 19 -

the comparison of anticipated to actual participants in each the PRI grant
programs reviewed.

Grantee
Florida 2006
Florida 2007
Illinois 2006
Colorado
2007
Colorado
2008
Texas 2006
New York
2006
New York
2008
District of
Columbia
2007
Washington
2006

EXHIBIT 5

PARTICIPANT INFORMATION FOR PRI GRANTS

Number of
Participants
Number of
Who Continued
Number of
Participants
Participation
Planned
Admitted Into
for 12 Months
After Release
Participants
Program 33
200
2,754
5
200
1,120
1
Not Tracked 34
200 or more
0
5
At least 200
64
At least 200

116

200 per year

189

At least 400

246

200

n/a

At least 200

n/a

At least 200

55

n/a

Were All
Eligible?
Yes
Yes
No
Yes
Yes

10
n/a

Yes
Yes

n/a

n/a

Not Tracked

Yes

Not Tracked

Yes

Source: OIG Review of Grant Documentation

As of December 31, 2009, these programs were still ongoing, although
the New York State Division of Criminal Justice Services had not yet started
the program that was funded by the 2008 PRI grant award. 35 It is clear
from the information in Exhibit 8 that certain programs such as the 2006
New York State Division of Criminal Justice Services and the 2006 Illinois
Department of Corrections programs do not appear to be on track to achieve
33

These numbers were taken from the progress reports for the 6-month period
ending December 31, 2009.
34

The grantee did not track the participants once they left the adult transition

center.
35

Only 3 of the 10 PRI grants reviewed were likely to continue to receive funding.
Two were less likely to be continued, one was not going to be continued, and four were
unlikely to be continued due to financial constraints.

- 20 -

their goal of serving at least 200 participants after 2 years into the program.
We recommend that OJP grant managers monitor progress reports and
performance measures to identify instances where grantees are not
complying with grant requirements and may need training and technical
assistance.
Reporting
Grant progress reports provide information on the status of funded
activities and are required to be submitted to OJP within 30 days after the
end of each semi-annual reporting period. According to the OJP Financial
Guide, they should include information about the performance of activities or
the accomplishment of program objectives. 36
Four of the nine PRI grants in which we reviewed progress reports
included reports that were late, incomplete, unsupported, or inaccurate.
For example, during our review the Illinois Department of Corrections
submitted six progress reports. All report narratives were inadequate and
did not address program accomplishments. In fact, during a review of a
judgmental sample of 20 participant case files, we determined that 3
participants who had successfully completed the PRI grant program were
back in custody, but the progress reports consistently reported no
participants were re-incarcerated. We did not find any information in the
case files concerning offender status after they left the correctional system.
We also did not find in the files any information concerning the recidivism
rate of participants in the program.
All 9 of the 10 PRI grantees whose programs had been implemented
reported the performance measures required by OJP. However, only five of
these nine grantees provided supporting documentation for the performance
measures they reported.
Second Chance Act Offender Reentry Grant Program Monitoring
Because the initial SCA grants were awarded in September 2009,
we could not evaluate the monitoring and effectiveness of the SCA
grant program. Our discussion related to the SCA grant program is
limited to the adequacy of the performance measures designed to
monitor the program’s progress.

36

Since our reviews of the PRI grants focused on performance, we limited our
reporting review to progress reports.

- 21 -

OJP’s BJA and OJJDP staff are responsible for monitoring the SCA
grantees. The SCA legislation does not contain specific grant monitoring
requirements. Therefore, the October 2008 Grant Manager’s Manual
remains the primary grant monitoring guidance for OJP grant managers and
the BJA’s August 2005 Monitoring Guide continues to provide additional
grant monitoring guidance for BJA’s grant managers.
OJP officials stated that OJP has begun using the information contained
in the Grants Management System as the official grant file. However, as
previously mentioned, OJP officials stated that the Grants Management
System is an inadequate performance measurement collection system that
cannot perform data analysis functions. One example of this is the fact that
OJP’s Grant Management System has allowed grantees to submit data
unresponsive to the required performance measures. Therefore, the BJA will
use the Performance Measurement Tool to collect performance measurement
data for the SCA grant programs. 37 BJA officials stated that the Performance
Measurement Tool will allow OJP to program data fields to accept only a predetermined format (numerical or narrative) to prevent grantees from
submitting data unresponsive to the required performance measures. In
addition, the Performance Measurement Tool will include a decision tree
structure that will allow grantees to answer only the measures relevant to
their grant programs which leads to a lighter reporting burden on grantees.
Further, the Performance Measurement Tool will provide greater
performance measurement information for grantees such as definitions and
frequently asked questions. Finally, the Performance Measurement Tool will
enable OJP and grantees to produce real-time reports and more efficiently
analyze the performance measures collected. The real-time data collected
from grantees will allow comparison of their performance with other
grantees. OJP estimates that the Performance Measurement Tool will be
available for use with the SCA program grants in June 2010. We believe
that if the Performance Measurement Tool operates as intended, it will
facilitate a more accurate and efficient assessment of grantee performance
measures.
OJJDP SVORI grantees submitted performance data to OJP through the
Grants Management System. However, OJJDP’s SCA grantees will submit
their performance measurement data through OJJDP’s Data Collection and
37

The BJA manages the contract with CSR, Incorporated for the development and
implementation of the Performance Measurement Tool. Through January 2010, nearly
$2.8 million has been spent on the Performance Measurement Tool development,
implementation, training and technical assistance, reporting, and analysis. In addition,
CSR, Incorporated will assist the BJA in analyzing the performance data collected through
the Performance Measurement Tool.

- 22 -

Technical Assistance Tool. 38 This Data Collection and Technical Assistance
Tool will be used to support OJJDP grantees’ ability to identify, collect, and
submit grantee performance data. It is a secure web-based tool that allows
OJJDP grant managers to access the system, view data from all grantees,
and track funds by award number. Grantees are able to view data they
submit as well as data submitted by their sub-grantees, if applicable.
Further, there is a process available to make the data in the Data Collection
and Technical Assistance Tool easily accessible to statistical software and
therefore facilitate data analysis.
We recommend that OJP continue to improve its grant
monitoring process for the SCA reentry grant programs by addressing
untimely reports, the lack of grant performance, and deficiencies in
annual desk reviews.
Recommendations
We recommend that OJP:
1.	

Ensure that reentry grantees implement and adhere to procedures
that will result in the timely submission of complete and accurate
Financial Status Reports and program progress reports.

2.	

Require that reentry grantees monitor grant performance to ensure
they achieve program goals and objectives.

3.	

Enforce the Grant Manager’s Manual requirement to perform and
document annual desk reviews.

4.	

Implement the Performance Measurement Tool and use it to collect
and analyze performance measures data collected from the SCA
grant programs.

38

OJJDP awarded a contract to ICF International (formerly known as Caliber
Associates), to design, develop, and operate a web-based Data Collection and Technical
Assistance Tool to facilitate the data collection of performance measures and indicators
reflecting program outputs and outcomes from grantees for each of the Juvenile
Accountability Block Grant program’s 16 Purpose Areas. The earlier version of the Data
Collection and Technical Assistance Tool was used to collect data for the data reporting
period of October 1, 2003, through March 31, 2005. In 2005, the contract was re-competed
and CSR, Incorporated took over the Data Collection and Technical Assistance Tool.

- 23 -

II.	 DESIGN OF OJP’S OFFENDER REENTRY GRANT
PROGRAMS
We identified design flaws in the initial implementation of
OJP’s SVORI and PRI reentry grant programs. Specifically,
we found that OJP did not adequately define key terms
essential for determining whether program goals were
met, did not require grantees to identify baseline
recidivism rates needed to calculate changes in recidivism,
and did not analyze performance measurement data. As a
result of these design flaws, neither OJP nor the OIG could
determine the effectiveness of OJP’s prior grant programs
in reducing recidivism.
Design of Offender Reentry Programs
Adequate program design is an important element of any grant
program. Program design is essential for deciding what data will be
collected and who will collect and analyze the data to determine program
effectiveness. Some programs such as SVORI and PRI, received little or no
legislative direction, which allowed the funding agency to have sole program
design responsibility. Other programs, such as SCA, are created through
prescriptive legislation that directs the funding agency in the specifics of a
program’s design.
During our review of OJP’s design of its three reentry programs, we
identified weaknesses and deficiencies related to OJP’s efforts to measure
recidivism, design adequate performance measures, analyze performance
measurement data collected from grantees, and adequately identify target
populations.
Inability to Adequately Measure Recidivism
The primary goal of the three reentry grant programs was to reduce
recidivism among offenders who were released from prison. In order to
measure recidivism rate changes, recidivism needs to be clearly defined.
The definition should include the duration of time the offender will be
monitored and the conditions that constitute recidivism. 39 In addition, a

39

Conditions that constitute recidivism may include one or all of the following:
arrest for a new offense, a return to incarceration, a violation of the terms of release, or
prosecution for a prior crime.

- 24 -

baseline recidivism rate should be identified and compared to subsequent
recidivism rates to determine a reentry grant program’s effect on recidivism.
Recidivism
During our review of the FYs 2002 through 2004 SVORI solicitations,
we did not find an adequate definition of recidivism that could be used to
measure and evaluate program results. OJP’s FY 2002 SVORI solicitation
referred to recidivism as the commission of new crimes by offenders after
their release from prison. This definition did not specify a timeframe in
which to track a program participant’s new offense. Further, the 2003 and
2004 SVORI supplemental solicitations did not include a definition for
recidivism.
OJP did not award grant funds in FY 2005, and resumed its efforts in
FY 2006 with the first PRI grant program solicitation. The goal of PRI was to
link returning adult, non-violent offenders with faith-based and community
organizations to help them find work and avoid relapse into criminal activity.
OJP subsequently offered two additional PRI program solicitations in
FYs 2007 and 2008.
In the PRI grant program, as in the SVORI grant program, OJP initially
did not define recidivism. DOL officials, who awarded PRI grants for 3 years
directly to faith-based community organizations, stated that they took the
lead in establishing uniform definitions of recidivism. They relied on a DOJ
Bureau of Justice Statistics (BJS) definition of recidivism included in a BJS
study. 40 They acknowledged their surprise to find out in April 2008 — the
third year of the PRI grant program — that OJP was not using the BJS
definition of recidivism. DOL officials stated that shortly after the 2008
grants were awarded, they convinced BJA to develop a uniform recidivism
definition to use for the DOJ programs and the DOL programs.

40

U.S. Department of Justice Office of Justice Programs Bureau of Justice Statistics,
Recidivism of Prisoners Released in 1994, Special Report NCJ 193427 (June 2002). “The
study uses four measures of recidivism: rearrest, reconviction, resentence to prison, and
return to prison with or without a new sentence. Except where expressly stated otherwise,
all four study measures of recidivism refer to the 3-year period following the prisoner’s
release in 1994.”

- 25 -

In January 2009, OJP disseminated revised program requirements to its PRI
grantees, which included a definition for recidivism. 41
The BJA and OJJDP SCA grant program solicitations for FY 2009 and
FY 2010 reflect language from the legislation stating “project[s] must have
as a goal the reduction of recidivism by 50 percent within a five-year
period.” The BJA and OJJDP program solicitations for FY 2009 and FY 2010
include a measurable definition of recidivism as a return to a detention or
incarceration facility “with either a new conviction or as the result of a
violation of the terms of supervision within 12 months of initial release.”
Baseline Recidivism Rate
In the grant solicitations for each fiscal year of the three reentry grant
programs, OJP did not require its grantees to submit baseline recidivism
rates. An accurate assessment of reductions in recidivism cannot be
conducted without a baseline recidivism rate. We recommend that OJP
request baseline recidivism rates from grantees so that recidivism rates can
be compared.
The Acting Administrator of the OJJDP stated that he did not know why
grantee baseline recidivism rates were not required. The Acting Director of
the BJA stated that it should not request grantee baseline recidivism rates
because of changes in the target population and geographic location of grant
programs that occur after the grant has been awarded but prior to the grant
program’s implementation. The Acting Director of the BJA also stated that
these programmatic changes occur approximately 25 percent of the time
and that grantees should not be required to collect data that may not be
used. He stated that external evaluators assist grantees in calculating
baseline recidivism rates after a target population and geographic location
has been finalized for use in the reentry programs.
While it may be difficult to calculate baseline recidivism rates until a
target population and geographic location are finalized, it is possible to do
so. Moreover, this information is vital to determining recidivism reduction
and program effectiveness, and we believe OJP should require grantees to
41

Recidivism was defined in an updated OJP memorandum as “a return to prison
with a new conviction or supervision within 12 months of release.” This definition differed
from the definition used by BJS in its 2002 report because the OJP memorandum only
measures events in the 1-year period following release, while BJS used a 3-year period in
its report. In addition, the definition in the OJP memorandum does not include re-arrests
while BJS did include re-arrests in its 2002 report. U.S. Department of Justice Office of
Justice Programs Bureau of Justice Statistics, Recidivism of Prisoners Released in 1994,
Special Report NCJ 193427 (June 2002).

- 26 -

submit explicit baseline recidivism rates in the offender reentry grant
program solicitations.
Performance Measures
The requirements for documenting and reporting performance
measures were not included in program solicitations until OJP issued its
2004 supplemental SVORI grant solicitation – 2 years after awarding initial
SVORI funding in 2002. When we asked BJA and OJJDP officials about the
lack of performance measures, they could not provide any explanation.
However, in the SVORI FY 2004 supplemental solicitation, OJP identified
11 performance measures that were required to be included in all
subsequent semi-annual progress reports submitted by SVORI grantees,
including those grantees that did not receive additional funding through the
2004 supplemental award.
Although OJP required grantees to include the specific performance
measures in their semi-annual progress reports, OJP officials stated that the
submission of these measurements was only cursorily verified by program
managers in the BJA and OJJDP. These measures were not reviewed for
accuracy and were not utilized to assess whether the grantees were meeting
their performance goals. Furthermore, grantees submitted the performance
measurement data through the Grants Management System, which OJP
officials stated was an inadequate performance measurement collection
system. 42 The Grants Management System does not perform data analysis
and grantees were able to submit data that did not address the required
performance measures. For example, the grantees were allowed to submit a
narrative response for a performance measure that required a numeric
response, which did not provide the type of information needed to evaluate
program performance. OJP officials informed us that a process to assess the
grantee data in a meaningful manner was never developed.
Although performance measures were included in the FYs 2006
through 2008 PRI grant program solicitations, OJP again did not establish a
process to assess PRI grant performance measurements. As we discuss
later in this report, BJA conducted one evaluation that focused on the
grantees’ implementation of the 2006 PRI grant programs, but no
assessments were made of the 2007 and 2008 PRI programs. Also, OJP did
not review performance measurement data to determine whether or not
42

OJP’s Grants Management System is an online electronic database designed to
allow OJP’s grantees access to online grant forms, submit application materials (e.g.,
program narratives and budgets) as file attachments, and submit periodic financial and
programmatic reports.

- 27 -

program goals were achieved, including recidivism rate reduction, for any of
its PRI grants. Further, we found no OJP assessments of PRI grantees that
included performance measurement analyses. OJP continued to collect
grantee data through the Grants Management System with no process in
place to assess the performance measurement data being collected.
Unlike the SVORI and PRI grant programs, the SCA grant program was
based on prescriptive legislation that identified eight specific program
outcomes:
•	 a reduction in recidivism rates, to be reported in accordance with
the measure selected by the Director of the Bureau of Justice
Statistics (BJS) under section 234(c)(2) of the SCA;
•	 reduction in crime;
•	 increased employment and education opportunities;
•	 reduction in violations of conditions of supervised release;
•	 increased payment of child support;
•	 increased housing opportunities;
•	 reduction in drug and alcohol abuse; and
•	 increased participation in substance abuse and mental health
services.
As a result, specific performance measures were included in SCA grant
solicitations that addressed all eight of the SCA’s declared performance
outcomes. For comparison purposes, Exhibit 6 shows which categories of
performance measures were included in each of OJP’s reentry program
solicitations.

- 28 -

EXHIBIT 6

OJP REENTRY PROGRAM PERFORMANCE MEASURES 43


Grant
Programs

General
Program 44

Pre- &
Postrelease
Services,
and
Transition
Plans

2004 SVORI
2006 PRI
2007 PRI
2008 PRI
2008 PRI
update
2009 BJA
SCA
2009 OJJDP
SCA

√
√
√
√

√
√
√
√

√
√
√
√

√

√

√

Reduce
Recidivism
and
Increase
Public
Safety

Employment,
Education,
Housing,
Substance
Abuse, Alcohol,
and Mental
Health Services

Child
Support

√

√

√

√

√

√

√

√

√ = Performance Measure Included
Source: OJP

While the SCA performance measures generally improved upon OJP’s
past reentry program performance measures, there were still some
deficiencies. No SCA performance measures relate to pre- and post-release
services and transition plans. The SVORI and PRI grant programs contained
performance measures regarding the number of:
•	 participants referred to pre- and post-release services;
•	 participants who received pre- and post-release services;
•	 offenders for whom a transition plan was developed;
•	 offenders who completed the program; and
•	 services provided by faith- and community-based providers,
including the types of services provided.
However, the SCA grant program did not have similar types of performance
measures.
43

Performance measures were not included in the FY 2002 and FY 2003 grant
program solicitations.
44

The general program category includes performance measures related to the
general characteristics of the target populations.

- 29 -

Requiring grantees to provide this type of performance data will allow
OJP to obtain information useful for structuring future reentry programs.
Collecting data regarding how many participants were referred and
ultimately participated in pre- and post-release services may indicate a
problem with the grantee’s program management if a low number of
participants are referred or receive post-release services. In addition,
collecting information on how many participants receive transition plans and
complete the program will help OJP identify whether grantees need training
or technical assistance, since low numbers may indicate that a grantee is
experiencing difficulties in implementing its reentry program. Further,
determining the types of services provided by the faith- and communitybased grantees may provide OJP with information on which services make a
program more successful in achieving performance outcomes.
We believe that such performance data would assist OJP in designing
future reentry programs. However, OJP did not adequately refer to its prior
grant programs and review lessons learned when designing new reentry
grant programs. We interviewed the Senior Policy Advisor for BJA who
drafted BJA’s 2009 SCA grant solicitation, and he said that he referred to the
results of an October 2008 planning meeting and the SCA legislation when
designing the 2009 SCA grant program. 45 In addition, he said he drew upon
his own experience within the corrections field to draft BJA’s 2009 SCA grant
solicitation. However, he acknowledged that he did not review lessons
learned from OJP’s SVORI and PRI offender reentry grant programs. He
stated that he did not review the performance and design of OJP’s past
offender reentry programs because the SCA legislation was so prescriptive.
We recommend both BJA and OJJDP amend their 2009 SCA grant
program performance measures to include measures that require grantees
to report performance information similar to the pre-release and postrelease performance measures included in the SVORI and PRI grant
programs. These additional measures will allow OJP to assess whether
grantees need training and technical assistance and could allow OJP to
determine what aspects of a reentry program are most beneficial in the
design of future OJP reentry programs.

45

In October 2008, representatives from numerous groups, including the American
Jail Association, the American Correctional Association, the Center for Effective Public Policy,
the NIJ, the Urban Institute, and the Council of State Governments Justice Center, attended
a meeting at BJA in Washington, D.C., to plan for the implementation of the SCA grant
program and gather information for the solicitation.

- 30 -

Target Population
During our review of the grant material and solicitations for each of
the three reentry programs, we noted that OJP did not provide a clear
definition of the target population, which affected OJP’s ability to determine
the effectiveness of its reentry programs.
The SVORI grant program, which began in FY 2002, focused on
“serious and violent offenders” who were considered to be the greatest
threat to public safety. According to OJP’s former Assistant Deputy Attorney
General, participating federal agencies agreed on a definition of “serious and
violent” that included crimes with firearms and those resulting in bodily
injury such as manslaughter or rape. The SVORI grant program did not
include offenders who had committed non-violent crimes.
However, OJP’s FY 2002 through 2004 SVORI grant solicitations did
not specify the types of crimes that would meet the definition of a “serious
or violent offender.” The omission of a specific definition left the decision
regarding offender participation to the grantee, which led to inconsistent
offender participation among different SVORI grant programs, inconsistent
comparisons of individual grant programs, and difficulties in measuring
program effectiveness.
OJP’s PRI grant solicitation in FY 2006 included a specific definition of
the grant program’s target population: adult non-violent offenders. The
solicitation excluded all violent and sex-related offenders from participating
in the program. However, the solicitation included a provision that allowed
grantees to request a waiver from OJP to include adult violent offenders in
their target populations if the grantees could not obtain a sufficient pool of
non-violent offenders. We believe that, compared to the FY 2002 SVORI
grant solicitation, OJP made significant improvements to the FY 2006 PRI
grant program by providing a more specific definition of the FY 2006 PRI
target population.
However, OJP’s PRI grant solicitation for FY 2007 had a different
definition of the target population. In the FY 2007 PRI solicitation, only
juvenile offenders were excluded from participating in the PRI grant
program. In addition, OJP officials continued to exclude sex-related
offenders and allowed grantees to request a waiver from OJP to include
violent offenders. When we asked OJP officials about the omission of these
requirements, they acknowledged the inaccuracy of the solicitation and had
no explanation for it.

- 31 -

In the FY 2008 PRI grant solicitation, the target population excluded
juvenile and sex-related offenders, which meant that both violent and nonviolent adult offenders were allowed to participate. OJP made this change to
allow grantees the flexibility of choosing the type of offenders they wanted
to include in the target population.
Allowing grantees to decide how to define their target populations
continued in the FYs 2009 and 2010 SCA grant program. We do not have
concerns with OJP’s decision to design its reentry programs to allow
grantees to decide which offenders are eligible to participate in a particular
grant program. However, we are concerned that OJP attempted to define
the target population with descriptions that were not adequately defined,
such as in the FY 2002 SVORI, and inaccurate solicitations that provided
incorrect guidance to potential grantees, such as in the FY 2007 PRI.
However, these deficiencies were corrected in OJP’s SCA grants for FYs 2009
and 2010.
Effectiveness of OJP’s Reentry Grant Programs
A potential measure of the effectiveness of reentry programs is
the recidivism rate. However, OJP officials could not provide specific
data on recidivism rates, and stated that they were awaiting the
results of a national evaluation.
We found that based on OJP’s design of its reentry grant
programs, the effectiveness of the reentry grant programs could not
be determined. In addition, based on detailed testing at grant sites,
we found that several programs were not successful, and much of the
data that could demonstrate the level of effectiveness of individual
reentry programs was unsupported.
Additionally, when completed, OJP’s independent national
evaluation of the SVORI grant program identified no significant impact
on recidivism.
Offender Reentry Grant Reviews
To assess the effectiveness of the SVORI and PRI offender reentry
grant programs, we selected a judgmental sample of the grants awarded for
each program and conducted site visits to review available documentation.

- 32 -

Overall, we reviewed 10 SVORI and 10 PRI grantees. 46 The results of these
reviews are described below.
Serious and Violent Offender Reentry Initiative
Our review of 10 SVORI grants found that 6 of the 10 grantees
generally provided services specified in the grant application by establishing
reentry grant programs and providing employment, housing, and substance
abuse services to offenders. For the two offender reentry programs in the
City of Oakland, California, and the State Washington, we were unable to
determine whether services were provided. In each instance, the participant
case files were either incomplete or missing and, as a result, we were unable
to determine whether the participants were eligible or received services.
In New York, the Office of Child and Family Services’ (OCFS) Office of
Strategic Planning and Program Development conducted two internal reviews
of the SVORI grant program. The first review, completed in March 2005,
identified several deficiencies that made it impossible to determine if
program requirements were implemented and program goals were met. The
deficiencies identified included inadequate documentation of program
activities, participant accomplishments, and required forms that were not
included in participant case files. In addition, program staff did not receive
training necessary to perform their duties. The second program review,
conducted in March 2006 to assess the progress made since the original
review, stated that it “did not find much evidence of changes or follow
through on recommendations.”
In addition, eight grantees did not maintain supporting documentation
for required performance measures as required by the OJP Financial Guide. 47
Without this documentation, we were unable to verify the accuracy of the
performance measurement data that the SVORI grantees submitted to OJP.
Consequently, we could not evaluate the recidivism of the participants.

46

The 10 SVORI grants that we included in our review were comprised of 6 grant
audits performed concurrent with this audit and 4 grants that the OIG had previously
audited.
47

We reviewed performance measurement data for eight of the SVORI grants. The
other two grants were previously audited using a program that did not include a review of
performance measurement data

- 33 -

Prisoner Reentry Initiative
We judgmentally selected 10 PRI grants and focused our review on
performance measurement data. 48 We found that the PRI grantees
established reentry programs in which eligible participants received the
services specified in the grant applications. The grantees generally rendered
services in accordance with the program’s stated goals and objectives. In
addition, we verified that the target populations were generally served.
Five of the 10 PRI grantees we reviewed supported their required
performance measurement data. Required performance measure
documentation was not maintained for four PRI grantees. The remaining
PRI grantee program had not progressed to the point where performance
was measurable.
Two PRI grantees recommended that OJP improve training and provide
more technical assistance to the grantees. These grantees stated that the
required OJP performance measures were ambiguous and confusing. One
grantee stated that OJP was not responsive to its request for assistance
interpreting the performance measures, and gave OJP poor ratings for
assistance and training.
Offender Reentry Program Evaluations
SVORI local evaluations were not included as a requirement in grant
solicitation and subsequent awards. However, 7 out of the 10 SVORI grant
programs audited by the OIG underwent voluntary local evaluations that
were paid for by the grantees. Only four out of the seven local evaluations
contained information on program recidivism. 49 These evaluations were
typically conducted by the state government or a university.
In addition, in FYs 2003 and 2004 OJP awarded 2 grants to RTI
International (RTI) to conduct a national evaluation of the 69 SVORI
grantees and assess the effectiveness of the SVORI grant programs. 50 The
SVORI grantees agreed to participate in the national evaluation as a
prerequisite to receiving the SVORI grant awards. Neither the PRI nor the
48

See Appendix I for a list of the 10 judgmentally selected PRI grants reviewed.
In addition to the four local evaluations we reviewed, the Washington Department
of Corrections (WDOC) underwent a local evaluation, but the final results will not be
available until 2011. The WDOC was also included in the RTI International (RTI) national
evaluation.
49

50

Although all 69 grantees were preliminarily measured by RTI evaluators, the RTI’s
comprehensive national evaluation efforts only included 14 grantees.

- 34 -

SCA grantees participated in the national evaluation, and the grantees were
not required to fund their own program evaluations.
Local SVORI Program Evaluations
We reviewed four local SVORI evaluations that contained information
regarding the programs’ impacts on recidivism. Exhibit 7 summarizes the
reported recidivism outcomes of these four local evaluations.
EXHIBIT 7

SVORI PROGRAM LOCAL EVALUATION RECIDIVISM OUTCOMES

Grantee
City of Oakland,
California

Population
Served
Adult and juvenile
offenders.

Sample Size*

Recidivism
Outcomes
Lower recidivism rates
achieved. 51

60 SVORI
participants
evaluated out of 94
program participants.
Nebraska
Adult offenders
19 SVORI
Lower recidivism rates
Department of
achieved.
only.
participants; 53 nonCorrections
SVORI participants as
matched control
group.
Adult offenders in
98 SVORI
Texas Department
No statistically significant
of Criminal Justice
administrative
participants
impact on re-arrest or
segregation only.
evaluated out of 203
return to prison rates
program participants. found.
Adult offenders
303 admitted
Delaware Health
Lower recidivism rates
only.
program participants
and Human
for those who completed
Services
evaluated of which
the program
96 completed the
(65.5 percent) versus
SVORI program while those who did not
207 did not complete complete the program
the program.
(82 percent).
* Small sample sizes may not be representative of an overall population and therefore limits
evaluation conclusions.
Source: OIG

The results of the local grant program evaluations indicate that the
SVORI grant program has had a positive effect on recidivism. However, we
do not believe that the results can be used to accurately determine the
effect the SVORI grant programs have had on recidivism because the small
51

While the external evaluation stated that lower recidivism rates were achieved
through the City of Oakland, California’s Project Choice SVORI grant program, a prior OIG
audit concluded that the grantee could not provide sufficient support to confirm who
participated in the program, which raises some concern about the accuracy of the
evaluation’s conclusions. See U.S. Department of Justice Office of the Inspector General,
Serious and Violent Offender Reentry Initiative Grant Awarded to the City of Oakland,
California, Audit Report GR-90-08-004 (September 2008).

- 35 -

sample sizes used in three of the evaluations were not representative of the
local SVORI participant populations. For instance, the City of Oakland
evaluation stated that the sample was so small that it was impossible to
draw conclusions that could be confidently extrapolated to a larger
population. In addition, the Texas sample was small and evaluators stated
that small samples require a fairly substantive change for the impact of
treatment to be detected. Texas evaluators found that the SVORI program
resulted in no statistically significant impact.
In another example, the evaluators concluded that the State of
Nebraska’s SVORI grant program reduced recidivism because 4 out of 19
(21 percent) SVORI grant program participants and 14 out of 53
(26 percent) non-SVORI grant program participants had a new arrest during
the 6-month follow-up period. As a result, the State of Nebraska’s SVORI
grant evaluators supported the expansion of the SVORI grant program.
However, we believe the value of the conclusions is greatly diminished
because of the small sample sizes, with a small difference between the
recidivism rates and the short measurement period.
The fourth local evaluation was of the Delaware Health and Human
Services (Delaware HHS) SVORI grant program. The evaluators of the
Delaware HHS SVORI grant program concluded that lower recidivism rates
were realized when program participants completed the program. However,
the Delaware HHS SVORI grant program evaluators did not conclude that
the success was a result of the SVORI program, stating that participants
completing the program “may have been more motivated to shed their
criminal behavior” and that “some and maybe many would have been
successful even without SVORI . . . .”
Moreover, it is difficult to compare the results of offender reentry
programs with widely varying offender populations. As shown in Exhibit 7,
one of the programs focused on both juvenile and adult offenders, two
programs focused on adult offenders in the general population, and one
program focused on adult offenders in the administratively segregated
population. 52 These different programs encounter inherently different
challenges due to the participant age and environmental differences which
make comparisons difficult.

52

Administratively segregated prisoners are isolated due to a perceived risk of
violence, membership in disruptive gangs, or a history of escape. These offenders are
normally not eligible for programs and services that are offered to offenders in the general
population.

- 36 -

RTI International’s National SVORI Evaluation
OJP’s National Institute of Justice (NIJ) awarded two grants in
May 2003 and June 2004, totaling $12 million, to RTI International (RTI) and
its subcontractor, the Urban Institute, for a comprehensive study on the
SVORI grant program. 53 The RTI’s study consisted of a 1-year design and
implementation phase and a 4-year impact study. The RTI conducted a
multi-site effort that included an implementation assessment, an impact
evaluation, and a cost-benefit evaluation. 54 OJP officials stated that OJP is
relying primarily on this independent national evaluation to assess the
effectiveness of the SVORI grant program.
Eighty-nine SVORI programs in 69 sites were included in the
implementation evaluation. RTI performed the planned tasks and
accomplished the established goals for phase one and released a 245-page
report in July 2004, entitled A National Portrait of SVORI, based on reviews
of grantee proposals and work plans, telephone interviews with program
directors, and visits to selected sites.
During the second phase, the RTI evaluated 16 SVORI programs at 14
selected sites to assess the effectiveness of the overall SVORI grant
program. The 16 programs consisted of 12 adult programs and 4 juvenile
programs. 55 The impact evaluation involved a series of in-person interviews
of SVORI participants and non-SVORI participants before they were released
from prison and at periodic intervals after their release from prison.
RTI and the Urban Institute produced a series of topical reports and
made presentations to congressional lawmakers, executive branch policymakers, and fellow researchers. A complete final research product
presenting the overall results of the evaluation was supposed to be
submitted to the NIJ during the last year of the project in 2008. However,
RTI produced six reports showing the results of the project because the
audiences for these reports were different.

53

The first grant was awarded in May 2003 for approximately $1.9 million. The
second grant followed in June 2004 for approximately $10.1 million. RTI worked in
collaboration with its subcontractor, Urban Institute, to perform the evaluation.
54
The implementation assessment documented the types of programs administered
by SVORI grantees, the impact evaluation assessed the effectiveness of the program, and
the cost-benefit evaluation determined whether program benefits exceeded program costs.
55

The 14 sites selected for the evaluation are shown in Appendix II of this audit

report.

- 37 -

After three extensions, the RTI submitted six draft reports to the NIJ in
June and July 2009. The NIJ received the final reports in December 2009.
RTI’s Report Results
The NIJ provided us with the RTI’s final reports, which are described in
Exhibit 8.

- 38 -

EXHIBIT 8

SUMMARY OF RTI’S FINAL REPORTS

Report Title
The Multi-site Evaluation of SVORI:
Methodology and Analytic Approach

Results Summary
Describes the methods and analytic
approach used to conduct the
evaluation.

Final report submitted December 2009
Prisoner Reentry Experiences of Adult
Females: Characteristics, Service
Receipt, and Outcomes of Participants in
the SVORI Multi-site Evaluation

According to official corrections data,
women who participated in SVORI had
significantly higher reincarceration rates.

Final report submitted December 2009
Reentry Experiences of Confined
Juvenile Offenders: Characteristics,
Service Receipt, and Outcomes of
Juvenile Male Participants in the SVORI
Multi-site Evaluation

RTI reported that SVORI failed to
generate differences between juvenile
males in the SVORI program and their
non-SVORI counterparts.

Final report submitted December 2009
Prison Reentry Experiences of Adult
Males: Characteristics, Service Receipt,
and Outcomes of Participants in the
SVORI Multi-Site Evaluation

An Economic Evaluation of the Serious
and Violent Offender Reentry Initiative

According to official data obtained from
state Departments of Corrections,
reincarceration rates for both groups
were high with about 40% of the SVORI
participants and the non-SVORI
population reincarcerated within 24
months of release. Although members
of the SVORI group were less likely to
have an officially recorded arrest
obtained from the National Crime
Information Center (NCIC) during the 24
months following release, the
differences were not statistically
significant.
There was no evidence of any cost
benefit for SVORI participation.

Final report submitted December 2009
Multi-site Evaluation of SVORI:
Executive Summary and Synthesis

Summarizes the overall content and
findings of the preceding six reports.

Final report submitted December 2009

Final report submitted December 2009

The final RTI reports found that although SVORI program participation
increased the likelihood that participants would receive a wide range of
services, the SVORI program did not have a significant impact on recidivism.
Among adult males, the SVORI and non-SVORI groups were equally likely to
be reincarcerated throughout the 24-month follow-up period. Although
members of the SVORI group were less likely to be rearrested during the
24 months after release than the non-SVORI group, the differences were not
- 39 -

statistically significant, and rearrest rates for both groups were about
70 percent, with at least one rearrest within 24 months of release. The RTI
found that the SVORI and non-SVORI groups were equally likely to be
reincarcerated within 3, 6, and 9 months of release, but that the SVORI
participants were significantly more likely to be reincarcerated within 12, 15,
21, and 24 months of release. For juvenile males, members of the SVORI
group were more likely to be incarcerated at the time of the 9- and 15month post-release interviews, although the differences were not statistically
significant.
American University’s Evaluation of DOJ’s 2006 PRI Grant Program
OJP, through its training and technical assistance contractor American
University, performed one PRI grant evaluation for the 2006 PRI grant
program. In May of 2009, American University published its report
summarizing the results of an assessment conducted on the implementation
experience of 20 PRI grantees who received FY 2006 PRI grants. 56 The
purpose of the assessment was to provide a synopsis of the PRI grant
program participants’ experience, focusing on: (1) the degree to which PRI
grantees were able to achieve initiative goals; (2) the nature of pre-release
services provided; and (3) issues that emerged relating to internal agency
operations and coordination with the DOL faith based community
organizations providing post-release services. The assessment found:
•	 a lack of coordination and communication between the DOJ and the
DOL, which created a lack of follow through by the OJP grantees
with the services offered by the DOL partner;
•	 a lack of information sharing, which prevented the development of
performance data that could have depicted the impact of the
initiative; and
•	 the DOJ grantees providing pre-release services experienced
difficulty coordinating with the DOL grantees providing post-release
services because the two federal agencies’ programs were
developed separately and lacked overarching communication and
organization necessary to facilitate program implementation.

56

American University, Assessment of the Implementation Experience and Status of
FY2006 BJA PRI Program Grantees (May 2009). This assessment was not awarded through
a competitive bid. American University conducted this assessment as a part of their work
as OJP’s training and technical assistance contractor.

- 40 -

American University was unable to conclude whether the services
provided by the OJP grantees resulted in reducing recidivism because there
was no mechanism established for systemic follow up of inmates
participating in the program after they were released. American University
stated that the PRI grant program established a framework to start
connecting individuals who were leaving correctional institutions with
employment opportunities, and the PRI grant program did help create the
necessary support systems for them to be successful.
Second Chance Act Program Evaluations
The SCA legislation does not require the BJA to fund an evaluation of
the SCA grant programs. However, the SCA legislation states that priority
will be given to grant applications that “provide for an independent
evaluation.” The SCA legislation further states that a condition of receiving
financial assistance is that each applicant shall develop a comprehensive
strategic reentry plan, which should contain measurable annual and 5-year
performance outcomes and, to the extent possible, use randomly assigned
and controlled studies to determine the effectiveness of the funded program.
OJP did not use FY 2009 SCA funds for an evaluation of the SCA grant
programs. BJA employees working with the SCA grant program stated that
they anticipated the BJA would use $1 to 2 million of the FY 2010 SCA
funding for an NIJ evaluation to determine the effectiveness of the SCA
grant programs.
As of January 2010 OJP had not provided funding for an SCA grant
program evaluation to determine its effectiveness.
Recommendations
We recommend that OJP:
5. Develop a consistent and detailed definition of recidivism and ensure it
is disseminated to all grantees.
6. Require grantees in offender reentry programs to provide baseline
recidivism rates to facilitate an accurate measurement of the
programs’ impact on recidivism.
7. Develop a process for analyzing grantees’ performance measurement
data to determine if program goals are being met, including whether
recidivism has decreased.
- 41 -

8. Add pre- and post-release performance measures that were included
in the SVORI and PRI grant programs to SCA.
9. Conduct a review of past offender reentry programs to identify best
practices, lessons learned, and problems to be avoided when
developing and implementing new reentry programs.
10. Ensure that the target population descriptions in future grant
solicitation material include detailed and precise definitions.
11. Consider arranging for an evaluation of the SCA reentry programs.

- 42 -

STATEMENT ON COMPLIANCE

WITH LAWS AND REGULATIONS

As required by the Government Auditing Standards we tested, as
appropriate given our audit scope and objectives, selected transactions,
records, procedures, and practices, to obtain reasonable assurance that
OJP’s management complied with federal laws and regulations for which
noncompliance, in our judgment, could have a material effect on the results
of our audit. OJP’s management is responsible for ensuring compliance with
federal laws and regulations applicable to the OJP. In planning our audit, we
identified the following laws, regulations, and requirements that concerned
the operations of the auditee and that were significant within the context of
the audit objectives:
•	

Continuing Appropriations for Commerce, Justice, State, and the
Judiciary, Pub. L. No. 106-553 (2001);

•	

Commerce/Justice/Science Appropriations Act, Pub. L. No. 107-77
(2002);

•	

21st Century Department of Justice Appropriations Authorization
Act, Pub. L. No. 107-273 (2002);

•	

Division B, Title I of the Consolidated Appropriations Act, Pub. L.
No. 108-7 (2003);

•	

Division B, Title I of the Consolidated Appropriations Act, Pub. L.
No. 108-199 (2004);

•	

Division B, Title I of the Consolidated Appropriations Act, Pub. L.
No. 108-447 (2005);

•	

Science, State, Justice, Commerce, and Related Agencies
Appropriations Act, Pub. L. No. 109-108 (2006);

•	

Fourth (Year-Long) Continuing Appropriations Resolution, Pub. L.
No. 110-5 (2007);

•	

Division B, Title II of the Consolidated Appropriations Act, Pub. L.
No. 110-161 (2008);

•	

Second Chance Act of 2007, Pub. L. No. 110-199 (2008);

•	

Division B, Title II of the Omnibus Appropriations Act, Pub. L.
No. 111-8 (2009); and

•	

Division B of the Consolidated Appropriations Act, Pub. L. No.
111-117 (2010).

- 43 -

Our audit included examining, on a test basis, OJP’s compliance with
the aforementioned laws, regulations, and requirements that could have a
material effect on OJP’s operations, through interviewing auditee personnel
and grantee officials, examining procedural practices, analyzing data, and
assessing internal control procedures. Nothing came to our attention that
caused us to believe that OJP was not in compliance with the
aforementioned laws and regulations.

- 44 -

STATEMENT ON INTERNAL CONTROLS
As required by the Government Auditing Standards we tested as
appropriate, internal controls significant within the context of our audit
objectives. A deficiency in an internal control exists when the design or
operation of a control does not allow management or employees, in the
normal course of performing their assigned functions, to timely prevent or
detect: (1) impairments to the effectiveness and efficiency of operations,
(2) misstatements in financial or performance information, or (3) violations
of laws and regulations. Our evaluation of OJP’s internal controls was not
made for the purpose of providing assurance on its internal control structure
as a whole. OJP’s management is responsible for the establishment and
maintenance of internal controls.
Through our audit testing, we did not identify any deficiencies in OJP’s
internal controls that are significant within the context of the audit objectives
and based upon the audit work performed that we believe would affect OJP’s
ability to effectively and efficiently operate, to correctly state financial and
performance information, and to ensure compliance with laws, regulations,
and other applicable requirements.
Because we are not expressing an opinion on OJP’s internal control
structure as a whole, this statement is intended solely for the information
and use of the auditee. This restriction is not intended to limit the
distribution of this report, which is a matter of public record

- 45 -

APPENDIX I
OBJECTIVES, SCOPE, AND METHODOLOGY
Objective
The objective of this audit was to examine OJP’s design and
management of its offender reentry initiatives.
Scope and Methodology Section
We conducted this performance audit in accordance with 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.
Our audit scope generally encompassed OJP’s offender reentry
initiatives from July 2002, the development of the SVORI grant program
through January 2010, and the status of the SCA offender reentry grant
program.
To accomplish our objectives, we conducted work at OJP’s office in
Washington, D.C., including interviews with various officials and staff within
the Bureau of Justice Assistance, the Office of Juvenile Justice and
Delinquency Prevention, Community Oriented Policing Services, and the
Office of Audit, Assessment and Management. We also interviewed
Department of Labor officials because of their collaboration with OJP on
offender reentry programs. We obtained and reviewed budgetary
information from OJP’s Office of the Chief Financial Officer. We attended the
President’s Prisoner Reentry Initiative FY 2008/Generation 3 Grantee
Orientation Workshop to obtain programmatic, training and technical
assistance information in May 2009. We identified and reviewed current and
historical internal policies and manuals pertaining to the grant monitoring
process, including OJP’s Grant Manager’s Manuals and other applicable DOJ
directives and orders, correspondence, and public laws and related
legislative history pertaining to OJP’s offender reentry initiatives. We also
reviewed peer review scores when available; grant applications; award files;
and applicable correspondence among OJP staff. Further, we analyzed
results from 10 external audits of SVORI grant programs and 10 external
reviews of PRI grant programs for any commonality among the findings.

- 46 -

Related OIG Grant Audits and Reviews
We reviewed 10 OIG SVORI grant audits that were issued from
January 2005 through November 2009. The 10 SVORI grants in our review
included 9 full-scope grant audits and 1 limited scope review of the District
of Columbia Justice Grant Administration’s SVORI grant program. Of the
nine full-scope grant audits, four were completed before the start of this
audit: Michigan Department of Corrections; City of Oakland, California;
Washington Department of Corrections; and Colorado Department of
Corrections. Two of the SVORI grant audits, the Michigan Department of
Corrections and the Colorado Department of Corrections, were conducted
before the start of this audit and used an audit program that did not include
a review of performance measurement data. Therefore, we did not include
results concerning goals and accomplishments pertaining to Michigan and
Colorado. The OIG’s limited review of the District of Columbia included the
following areas: expenditures, progress reports, goals and
accomplishments, and monitoring of sub-contractors and sub-recipients. For
the remaining seven grantees, we tested the accounting records to
determine if reimbursements claimed for costs under the awards were
allowable, supported, and in accordance with applicable laws, regulations,
guidelines, and the terms and conditions of the grants.
For the OIG audit work conducted concurrently with this audit, a
combination of BJA and OJJDP grants representative of the SVORI grant
population was selected. Twenty-two OJJDP grants made up 32 percent of
the grant universe, while 47 BJA grants made up 68 percent of the grant
universe. The OIG audited two OJJDP grants, or 33 percent of the overall
grant universe, and four BJA grants, or 67 percent of the overall grant
universe. The table below shows the percentages of the BJA and OJJDP
selected grants out of the total SVORI audit universe versus the total BJA
and OJJDP grants out of the total SVORI grant universe.
OIG SVORI AUDITS COMPARED TO THE TOTAL SVORI GRANT
UNIVERSE
Program
Office
OJJDP
BJA
Total

Concurrent OIG
SVORI Audits
2
4
6

Percent
33
67
100

Total SVORI
Grants Awarded
22
47
69

Percent
32
68
100

In addition to selecting a representative balance of BJA and OJJDP
grants, the OIG assigned weights to each grant based on whether the
federal share was above or below $1 million, the grant was open or closed,
there were funds de-obligated or not, the average violent crime rate for the
corresponding state exceeded the national average, and other criteria
- 47 -

deemed pertinent from OJP interviews conducted. OIG audits were
conducted on the grants that generally received the highest weighted scores.
The SVORI grant audits conducted by the OIG are listed in Appendix III.
In addition, we examined 10 OIG reviews of PRI grant programs
conducted concurrently with this audit. These 10 OIG PRI grant program
reviews were conducted on 7 PRI grantees, with 3 grantees receiving PRI
grant awards in more than 1 year of the PRI grant program. The total PRI
grant program universe consists of 63 PRI grants, with 20 (32 percent)
awarded in FY 2006, 23 (37 percent) awarded in FY 2007, and 20
(31 percent) awarded in FY 2008. The FY 2008 PRI grant programs have
only recently begun, therefore the OIG selected fewer FY 2008 PRI grant
programs to undergo review. In total, five PRI grants (50 percent) were
selected from FY 2006, three (30 percent) were selected from FY 2007, and
two (20 percent) were selected from FY 2008. The table below shows the
percentages of the selected PRI grants by fiscal year out of the total PRI
grant program review universe versus the total PRI grants awarded each
fiscal year out of the total PRI grant universe.
OIG PRI REVIEWS COMPARED TO THE PRI GRANT UNIVERSE BY
FISCAL YEAR
Fiscal
Year
2006
2007
2008
Total

OIG PRI Grant
Program Reviews
5
3
2
10

Percent
50
30
20
100

Total PRI Grants
Awarded
20
23
20
63

Percent
32
37
31
100

In addition, the OIG assigned weights to each grant based on whether
the federal share was above or below $1 million, the grant was open or
closed, there were funds de-obligated or not, the average violent crime rate
for the corresponding state exceeded the national average, and other criteria
deemed pertinent from OJP interviews conducted. Generally, our selected
assist work grants made up the higher weighted scores. The PRI grant
program reviews conducted by the OIG are listed below.

- 48 -

OIG REVIEWS OF 2006 PRI GRANT PROGRAMS

Award Number
2006-RE-CX-0005
2006-RE-CX-0013
2006-RE-CX-0014
2006-RE-CX-0021
2006-RE-CX-0022

Grantee
Washington State
Department of Corrections
Illinois Department of
Corrections
Texas Department of
Criminal Justice
New York State Division of
Criminal Justice Services
Florida Department of
Corrections

Grant Start
Date

Date
Closed

Award
Amount

04/01/2006

Open

$450,000

09/01/2006

Open

$450,000

09/01/2006

Open

$1,350,000

06/01/2006

Open

$815,538

01/01/2006

Open

$450,000

OIG REVIEWS OF 2007 PRI GRANT PROGRAMS

Award Number
2007-RE-CX-0003
2007-RE-CX-0007
2007-RE-CX-0024

Grantee
Colorado Division of Criminal
Justice
District of Columbia – Justice
Grants Administration
Florida Department of
Corrections

Grant
Start Date

Date
Closed

Award
Amount

10/01/2007

Open

$450,000

07/01/2007

Open

$450,000

09/01/2007

Open

$450,000

OIG REVIEWS OF 2008 PRI GRANT PROGRAMS

Award Number
2008-RE-CX-0002

2008-RE-CX-0016

Grantee
New York State
Division of
Criminal Justice
Services
Colorado Division
of Criminal
Justice

Grant Start
Date

Award Amount

Grant End
Date

04/01/2008

$540,000

Open

09/01/2008

$540,000

Open

Grant File Sample Selection
We judgmentally selected 24 SVORI grant program files for our SVORI
grant program file review. We reviewed these grant program files for
completeness and evidence of grant monitoring. Our 24 selected grant file
review included 10 grants for which the OIG conducted audit work. We then
selected a combination of BJA and OJJDP audits that are representative of
the SVORI grant universe. Twenty-two OJJDP grants made up 32 percent of
the universe population, while 47 BJA grants made up 68 percent of the 69
total SVORI grant programs. Our judgmental sample for our case file review
included 9 OJJDP grants, or 37 percent of the case file review sample, and
- 49 -

15 BJA grants, or 63 percent of the case file review sample. The table below
shows the percentages of the BJA and OJJDP grants selected for the grant
file review out of the total SVORI grant file review universe versus the total
BJA and OJJDP grants awarded out of the total SVORI grant universe.
OIG SVORI GRANT FILE REVIEW UNIVERSE COMPARED TO THE
TOTAL SVORI GRANT UNIVERSE
Program
Office
OJJDP
BJA
Total

SVORI Grant
File Review
Universe
9
15
24

Percent
37
63
100

Total SVORI
Grants Awarded
Universe
22
47
69

Percent
32
68
100

In addition to selecting a representative balance of BJA and OJJDP
grants, we assigned weights to each grant based on whether OIG audit work
had been conducted or was underway, the federal share was above or below
$1 million, the grant was open or closed, geographic distribution, there were
funds de-obligated or not, the average violent crime rate for the
corresponding state exceeded the national average, and other criteria
deemed pertinent from OJP interviews conducted. The grants selected for
the grant file review generally made up the highest weighted scores, but
also contained 14 grants with middle and low scores for a distributed sample
population. The 24 SVORI grants selected for our review are listed below.

- 50 -

SVORI BJA GRANTEES JUDGMENTAL GRANT FILE REVIEW SAMPLE

Award Number
2002-RE-CX-0001

2002-RE-CX-0005

2002-RE-CX-0008

2002-RE-CX-0014
2002-RE-CX-0015
2002-RE-CX-0018
2002-RE-CX-0025
2002-RE-CX-0030
2002-RE-CX-0032
2002-RE-CX-0033

2002-RE-CX-0042
2002-RE-CX-0055
2002-RE-CX-0064

2002-RE-CX-0066

2003-RE-CX-0001

Grantee
Illinois
Department of
Corrections
Virginia
Department of
Corrections
Delaware Health
and Human
Services
Alaska
Department of
Corrections
Virgin Islands
Colorado
Department of
Corrections
State of New
Hampshire
State of New
Mexico
State of Hawaii
Michigan
Department of
Corrections
Washington
State
Department of
Corrections
City of Oakland
Texas
Department of
Criminal Justice
District of
Columbia Justice
Grants
Administration
Nebraska
Department of
Correctional
Services

Grant Start
Date

Award Amount

Date Closed

07/01/02

$2,365,461

06/30/09

07/01/02

$2,396,647

05/15/08

07/01/02

$2,603,234

06/07/07

07/01/02

$1,497,574

05/28/08

07/01/02

$1,035,000

01/24/08

07/01/02

$2,163,367

09/04/08

07/01/02

$2,173,334

Open

07/01/02

$2,219,528

04/22/08

07/01/02

$2,429,979

12/18/08

07/01/02

$1,052,000

01/13/09

07/01/02

$2,145,962

11/19/07

07/01/02

$1,052,000

06/11/07

07/01/02

$2,124,599

08/05/08

07/01/02

$2,086,722

12/31/06

07/01/02

$2,386,908

09/09/08

- 51 -

SVORI OJJDP GRANTEE JUDGMENTAL GRANT FILE REVIEW SAMPLE

Award Number
2002-RE-CX-0002

2002-RE-CX-0012

2002-RE-CX-0013

2002-RE-CX-0028

2002-RE-CX-0044
2002-RE-CX-0045

2002-RE-CX-0049

2002-RE-CX-0050

2002-RE-CX-0060

Grantee
Indiana
Department of
Corrections
South Carolina
Department of
Juvenile Justice
Idaho
Department of
Juvenile
Corrections
New York State
Office of Children
and Family
Services
Oklahoma Office
of Juvenile Affairs
Missouri
Department of
Social Services
Utah Department
of Human
Services
Nevada
Department of
Human
ResourcesDivision of Child
Human
ResourcesDivision of Child
Wisconsin
Department of
Corrections

Grant Start
Date

Award Amount

Date Closed

07/01/02

$2,387,000

04/29/08

07/01/02

$1,051,980

01/17/08

07/01/02

$2,087,000

05/04/07

07/01/02

$1,237,504

05/25/07

07/01/02

$1,049,050

04/17/07

07/01/02

$873,750

04/20/08

07/01/02

$1,080,100

01/05/08

07/01/02

$708,994

09/8/09

07/01/02

$2,344,847

06/04/07

We judgmentally selected 23 PRI grant files for our PRI grant program
file review. We reviewed the selected grant program files for completeness
and evidence of monitoring. Our 23 selected grant files included 10 grants
for which the OIG performed reviews. OIG auditors did not conduct full
grant audits, but instead performed supplemental audit steps to evaluate
performance measures only for the PRI grant program. All PRI grants were
administered by BJA.
Sixty-three total PRI program grants were awarded from FYs 2006
through 2008. The 63 total PRI grant award consisted of 20 awards in
FY 2006 or 32 percent of the grant universe, 23 awards in FY 2007 or
37 percent of the grant universe, and 20 awards in FY 2008 or 31 percent.
- 52 -

We judgmentally selected nine grants from FY 2006 (39 percent), eight from
FY 2007 (35 percent), and six from FY 2008 (26 percent). The table below
shows the percentages of PRI grant files selected for our review by fiscal
year versus the total PRI grants awarded by fiscal year out of the total PRI
grant universe.
OIG PRI GRANT FILE REVIEW UNIVERSE COMPARED TO THE
TOTAL PRI GRANT UNIVERSE
Fiscal Year
2006
2007
2008
Total

Case file
Universe
Selected
9
8
6
23

Percent
39
35
26
100

Total Universe
Population
20
23
20
63

Percent
32
37
31
100

In addition, the OIG assigned weights to each grant based on whether
OIG audit work had been conducted or a review was underway, the federal
share was above or below $1 million, the grant was open or closed, there
were funds de-obligated or not, the average violent crime rate for the
corresponding state exceeded the national average, geographic distribution,
and other criteria deemed pertinent from OJP interviews conducted. The PRI
grants selected for the PRI grant file review generally made up the highest
weighted scores, but also contained 12 grants with distributed scores to
make up a diverse sample population. The PRI grants selected for our PRI
grant file review are listed below.

- 53 -

2006 PRI GRANTEE JUDGMENTAL GRANT FILE REVIEW SAMPLE

Award Number
2006-RE-CX-0003
2006-RE-CX-0005
2006-RE-CX-0013
2006-RE-CX-0014
2006-RE-CX-0017
2006-RE-CX-0020
2006-RE-CX-0021
2006-RE-CX-0022
2006-RE-CX-0024

Grantee
Michigan Department of
Corrections
Washington State
Department of Corrections
Illinois Department of
Corrections
Texas Department of
Criminal Justice
Pennsylvania Department
of Corrections
State of Colorado
New York State Division of
Criminal Justice Services
Florida Department of
Corrections
Youth & Adult Correctional
Agency, California

Grant Start
Date

Date
Closed

Award
Amount

06/01/2006

09/25/09

$450,000

04/01/2006

Open

$450,000

09/01/2006

Open

$450,000

09/01/2006

Open

$1,350,000

10/01/2006

Open

$449,000

10/01/2006

Open

$449,704

06/01/2006

Open

$815,538

01/01/2006

Open

$450,000

07/01/2006

Open

$1,800,000

2007 PRI GRANTEE JUDGMENTAL GRANT FILE REVIEW SAMPLE

Award Number
2007-RE-CX-0003
2007-RE-CX-0007
2007-RE-CX-0008
2007-RE-CX-0010
2007-RE-CX-0011
2007-RE-CX-0012
2007-RE-CX-0021
2007-RE-CX-0024

Grantee
Colorado Division of Criminal
Justice
District of Columbia – Justice
Grants Administration
Michigan Department of
Corrections
Pennsylvania Department of
Corrections
State of California
Community Service &
Development
Nevada Department of
Corrections
Kansas Department of
Corrections
Florida Department of
Corrections

- 54 -

Grant
Start Date

Date
Closed

Award
Amount

10/01/2007

Open

$450,000

07/01/2007

Open

$450,000

10/01/2007

Open

$450,000

10/01/2007

Open

$427,439

07/01/2007

Open

$450,000

07/01/2007

Open

$450,000

09/01/2007

Open

$450,000

09/01/2007

Open

$450,000

2008 PRI GRANTEE JUDGMENTAL GRANT FILE REVIEW SAMPLE

Award Number
2008-RE-CX-0002

2008-RE-CX-0005

2008-RE-CX-0012

2008-RE-CX-0016

2008-RE-CX-0018

2008-RE-CX-0020

Grantee
New York State
Division of
Criminal Justice
Services
Michigan
Department of
Corrections
California
Department of
Corrections and
Rehabilitation
Colorado Division
of Criminal
Justice
Pennsylvania
Department of
Corrections
Nevada
Department of
Corrections

Grant Start
Date

Award Amount

Grant End
Date

04/01/2008

$540,000

Open

08/01/2008

$540,000

Open

04/01/2008

$540,000

09/01/2008

$540,000

Open

09/01/2008

$539,971

Open

09/01/2008

$540,000

Open

Open

We obtained what we believe to be necessary and sufficient
documentation to achieve our audit objectives. Throughout the audit, we
relied on computer-generated data to obtain necessary information about
grant proposals and awards from OJP’s Grants Management System.
Although we did not assess the reliability of such computer-derived
information, we do not believe our reliance on this data affects our findings
and recommendations.

- 55 -

APPENDIX II
SVORI GRANTEES INCLUDED IN RTI INTERNATIONAL’S
NATIONWIDE EVALUATION
State

Grantee Agency

Focus of Impact
Evaluation

CO

Colorado Department of
Corrections

Juveniles

FL

Florida Department of
Juvenile Justice

Juveniles

IN

Indiana Department of
Corrections

Adults

IA

Iowa Department of
Corrections

Adults

Kansas Department of
Corrections

Adults

Kansas Juvenile Justice
Authority

Juveniles

KS

ME

Maine Department of
Corrections

Adults

MD

Maryland Department of
Public Safety and Correctional
Services

Adults

MO

Missouri Department of
Corrections

Adults

NV

Nevada Department of
Corrections

Adults

OH

Ohio Department of
Rehabilitation and Corrections

Adults

OK

Oklahoma Department of
Corrections

Adults

PA

Pennsylvania Department of
Corrections

Adults

South Carolina Department of
Corrections

Adults

South Carolina Department of
Juvenile Justice

Juveniles

SC

WA

Award Amount
$2,163,367
$1,404,441
$2,387,000
$2,087,000
$1,352,000
$1,046,733
$2,156,006

$2,384,563

Washington State
Department of Corrections

Adults

Source: RTI Impact Evaluation Reports

- 56 -

$1,468,852
$1,867,282
$2,549,517
$1,090,305
$2,288,194
$1,052,002
$1,051,980
$2,145,962

SVORI GRANTEES SELECTED FOR RTI INTERNATIONAL’S

COST-BENEFIT EVALUATION

State
IA

OH

PA

SC

Grantee Agency

Focus of CostBenefit Evaluation

Iowa Department of
Corrections

Adults

Ohio Department of
Rehabilitation and
Corrections

Adults

Pennsylvania Department of
Corrections

Adults

South Carolina Department of
Corrections

Adults

South Carolina Department of
Juvenile Justice

Juveniles

Award Amount
$2,087,000

$2,549,517

2,288,194

Source: RTI Impact Evaluation Reports

- 57 -

$1,052,002
$1,051,980

APPENDIX III
DOLLAR-RELATED FINDINGS RESULTING FROM SVORI GRANT
AUDITS

Program
Office

SVORI
Grantee

Award
Amount

Questioned
Costs and
Funds to
Better Use

Percent
of Award
Questioned

BJA

Delaware Health and
Human Services

$2,603,234

$2,593,494

99.63

BJA

City of Oakland,
California

$1,052,000

$1,052,000

100.00

New York State Office
of Children and Family
Services

$1,237,504

$760,454

61.45

BJA

Washington
Department of
Corrections

$2,145,962

$359,432

16.75

BJA

Colorado Department
of Corrections

$2,163,367

$349,084 57

16.14

BJA

Michigan Department
of Corrections

$1,052,000

$22,436

2.13

South Carolina
Department of
Juvenile Justice

$1,051,980

$7,277

0.69

BJA

Texas Department of
Criminal Justice

$2,124,599

$7,077

0.33

BJA

District of Columbia
Justice Grants
Administration

$2,086,722

$0

0.00

BJA

Nebraska Department
of Correctional
Services

$2,386,908

$0

0.00

$17,904,276

$5,151,254

OJJDP

OJJDP

Totals

28.77%

Source: Data from OIG audit reports issued between January 2005 and October 2009

57

The dollar-related finding of $349,082 relating to the OIG grant audit of the
Colorado Department of Corrections included $134,362 in funds to better use and $214,722
in questioned costs.

- 58 -

APPENDIX IV
THE OFFICE OF JUSTICE PROGRAMS’
RESPONSE TO THE DRAFT REPORT

u.s. llepJlrtlllcllt
u.s.
1)1~llarllllClll of Justice
Juslicc
Office
Justice Progmms
Prog rams
Ofl1ce of Juslice
ODicI'
AS.I'i.wwlI (l1,,,rnI'Y
AI/oriley (jem:ml
General
qUh'" of Ihe AS,I'iHWII

2010
JUN 21 2010
MEMORANDUM TO:
MEMORANDUM'I'O:

Glenn A. Fine
Inspector General
United States Department (If
of Justice

THROUGH:
THROUOH:

Raymond 1.
J. Beaudet
Assistant
Inspector General for Audit
Assistanllnspcctor
Office
the Inspector General
Offiee of Ihe
Uni ted Slales
States Dcpartmenl
Department of Justice
Justice
United

!'ROM
FROM::

SUBJECT:

LauricO.
~
Laurie O. Robinson
Assistant Altorney
Anorney Geoera~
Gcnera~
General's Draft Audit Report,
Response to Office of the Inspector Gcneral's
Report.
Juslice Programs'
Programs ' Management ofits
of its Offender Reentry
Office of
o/JI/s/ice
res
Inilialives
!"i1ia/h

This memorandum provides a response to
General 's (DIG's)
(OIG's) May 20,
10 Office of the Inspector General's
Office of
Justice Progrom!'
its Offen(kr
Offender Rf.'l'ntry
Reentry
20
I 0 druft audit
afJustiCe
Pmgram.~' Management of
afits
2010
audil report, entitled Ojfice
Iniliatives. Overall.
Overall, the Office of Justice Programs (OJP) agrees with the conclusions and the
Init;alives,
recommendations detailed in the draft audit report.
rev iew,
The draft audil
audit report contains 11
II recommendations and no questioned Cosls.
costs. For case of review,
TIle
the draft audit report reco
mmendations are restated in bold and are
arc followed by OJP's respoose.
response.
Ihe
recommetuJiJtions
I.

OJP ensure tbat
that reentry
We recommend that O.JP
re~ntry grantees implement and adhere to
~ llbmi~s ion or
of complete and accurate
procedures lhut
IhKI will result in the timely submissiun
Federal Financial Reports and program progress reports.
Ifederal
The Office of Justice Programs agrees
wi th Ihe
the recommendation.
recommendation. The Bureau of Justice
llgrees with
Delinquency
Assistance
(BJA), in collaboration with the Office
Omce of Juvenile Justice
JUSlice lind
and Oelintlucocy
Assistllnce (OJA),
Prevention (OJJOP),
(OJJDP), conducted a post-award management Il".llning,
training workshop 00
on May 2627,2010,
(SeA) grllmecs.
grantees. This workshop
27.2010. in Washington, DC, for all Second Chance Act (SCA)
effective grant management.
management, and included a
lhe importance of
ofcffcClivc
included infonnation on the
with reponing
reporting requirements
Attachment 1).
I).
session on
011 complying wilh
requiremt:lll'l (see Attochmcnt
In addition. on April 82010,
BJA conducted a webinar ("Post Award Gront
Grant
8 2010, aJA
Management") on post-award grant management for fiscal )'ear
year (FY) 2009 SeA
SCA grantees,
requirements. The webinur
webinar may be accessed at
llddressed grantee
granlee reporting requircmL"TlIs.
which addressed

- 59 -

http://www.
na ti onltl
onlll recnt
recntryrcsourcecenter
.org/2009-~ccond-chancc-aet -grantce-resourcc­
hlln
:/Iwv.'W. nnli
I'yrcsourcecelller.ord2009-scc(md-chance-act-granlcc-rcsourccPi!ill:.
Thc Office
Officc of Justice Programs requests
this rt:commendation.
recommendation.
Q~~. The
rcquests closure of
oflhis

2.

We recommend that OJP require tbllt
tha t reentry grantees
grantct:s monitor grant performullec
performance
to ensurc
cnsurc they
thcy achic\'e
ac hieve program goals and objectives.
The
ustice Programs agrees with the rccommcndmiOl\.
recommendation. In FY
Th~ Office
omc~ of J
Ju.~licc
roy 2010, BJA and
performance measures for thc
the SeA
SCA Programs and require SCA
OJJDP developed per[ormuncc
grantees to
10 report on their progress in meeting
mt:eting program goals
goal~ and objectives in their
7-10).
1,2010,
0). By October J.
2010, BJA
I3JA and
program progress reports (see Attachment 2, pages 1-1
OJJDP will devclo
developp internal procedures to enhance the compliance rate for the data
collected in BJA
's Performance Measurement Tool (PMT). and in OJJDP's Data
BJA's
(DCTA T).
Collection Tool (OCTAD.

3.
3.

We recommend that
Manual requiremcnt
requirement to
lhat OJP enforce the Grant Manager's MMnuul
perform and
lind documcnt annual
annual dcsk reviews.
agrees with the recommendation.
BlA
Office of Justice Programs agrces
recommcndation. By July 1,2010, BJA
The Ofliceof
dt:sk reviews
rev iews in grant
and OJJDP will incorporate the completion
complction and documt:ntution
documentation of desk
managers' performance work pIons,
plans.

4.

We rccommend
recommend thai
that OJP
implement the Performance Measurement
Tool a nd usc it
O,JP implernenllhe
Meu~urcmcnl Toolaod
....c performance
pcrformance measurcs
grant
to collcct
analyze
measures data collected from the SeA grnllt
collect and analy
programs.
Justice Programs agrees with the recommendation.
n:commendation. fiJA
BJA added the SeA
Thc Onlce
Office of Juslice
The
SCA
PM"!" in Jan
uary 2010 to allow for the co11cction
January
collcction and analysis of grantee
Programs to the PMT
performance measures data. Beginning on July 1,2010,
grantees will
wi ll begin
performam~e
1,2010. SeA
SCA grnntecs
rcporting in PMT on the results of performance measures data co11ected
reporting
collected for the quarter
ending June 30, 2010.
whic h may be accessed at
In April 2010, BJA conducted tbe
lhe following series ofwebinars,
ofwebinar~, which
lit
hltp://www.nationulreenlryresourcecenter .orgl2009-second-clmnce-act -grantee-resourct:­
http://www.lllltionalrL..Clllrvrcsourcccenter.onY2009-seeond-cllUnCC-ltCI-f,:rantee·fCsource·
page.
~.
•
•
•

S.
5.

Performance Mca:'lures
Measures and Dala
Data Collection
Overview of Pcrfonllance
Overview
Col lcction-Adu lt Mentoring
Ovcrview ofPerformanee
ofPerfonllilllee Measures and Data Collcction·Adult
Grantees
Performance MCllsurcs
Measures for Second Challcc
Chance Juvenile Reentry Granlecs
Grantccs

We recommend thai
that OJ]'
OJP devt"!op
develop a consistcnt
dctailed definition of recidivism
con.~islcol and detailed
and ensure it is disseminated to all grantees_
grantees.
Office of Justice I'rograms
I)rograms agrees with the recommendation. In FY 2010, BJA and
The Officc
detaikd
OJJDP issued ajoint solicitation for the SCA Programs, which included deloiled
information and a definition ofrccidivislll,
of recidivism, for purpo!iCs
purposes of this initiative. Spccifically,
Specifically,

2

- 60 -

was defined as aII return
ret urn to
prison, jai l and/or a juvenile detention
recidivism WllS
10 pris(lO,jail
delcnllon or
fa(;il ity, with either allnew
new conviction or as the result of a violation of
the
corre(;tional
correctiunal facility,
oflhe
tcrms
terms of supervision, within 12 months of initial release (sec
(.'ICC Attachment
AIlrlehmcnt 2,
2. page 1).
I).
BJA and OJJOP
defi nition of recidivism at the
thc
I3JA
01101' also
ulsu discussed
Jiscussed with SCA grantees the definition
trai ning workshop held
hel d on May 26·27,
26~27, 2010,
20 10, in Washington,
Washington, DC, and through a series of
training
webinars held in FY 2010.
2010. The link 10
to the webinars
webinflrs can he
be found al
at
webiotlrs
Ili ng/webellsts.
nglwcbcasts. The
The Office of 1ustiec
Justice
http://www.nationalrecntrvresouT(;cccnteT.nrg/tra! ni
hllp:l/www.nutiollalrecntryresourcccentcr.orgitrai
recommendation.
Programs requests elosure
Pnlgnlills
closure of this recommendation.
6.

tbat OJP
ree ntry progrllms
programs to
We recommend thllt
O,)P require grantees in offender reentry
IlJ provide
recidivism {"".ltes
meas urement of the programs'
fltdlilafe an
lin accurate
Hccurale measurement
baseline recillhisrn
rilles to facilitate
impact on recidivism.
reeommt:ndation. BlA
to work
The Office of Justice Programs agrees with the recommendution.
81A plans 10
baseline recidivism data is collected to facilitate
closely with its SCA
SeA grantees to ensure ba~elinc
facilitate:
the SCA Programs' impact on reeidivi~m
recidivism within the target
an accurate measurement of
ortbe
31,2010,
A and OJ1DP
OJJDP anticipale
an ticipate developing ba~clinc
basel ine
population. By
l3y December
D~cember 31.
2010, Bl
BJA
recidivism rates for their respective SCA grantees.
b'J"lmlees.

7.

We recommend that
tbat OJP
O.JP develop
process for anal)'zing
analYLing grantees'
performa nce
'VI.'
dc,'e1u(I:Ia pmcc~s
grlllltecs' Ilcrrormllnce
m ea~ urement data
measurement
d:'Ita to determine if program goals
gUllls arc
nrc being met, including
inclUding wbetber
whetber
decreased.
recidivism bas decreased.
The Office of Justice Programs agrees
agrec." with the recommendation. By September 30,
2010, BlA
OlJDP will work with Consulting Services and Research, [ne.
Inc. and the
2010.
BJA and OJ10P
Center (NRRC) to develop guidelines for analyzing SCA
National Reentry Resource Centcr
grantees' performance
perfonnance data to detennine
determine ifSCA Programs
Progmms goals
goal~ arc being met,
mel. including
gr.Jlllees'
31I,,2010,
OJJOP will
wilt
whether recidivism has decreased. In
[n addition,
addition. by December 3
2010. OJJDP
Ulilluul report for its SCA
vities and
seA grantees
grllntees which summari7.es
summarizes whether acti
activities
publish an mmual
accomplisluncnts
l1ccomplislunents arc
are consistent with program goals.

8,
8.

recommend tbat OJP add pre- and
post~rclea se pcrformanee
mea.~ ure5 that
We recommcndlbut
lind post-release
performance measures
were included in the SVORI and PRJ
programs to SeA.
wert'.
PRI grant Jlrograms
2010, BJA
The Office of Justice Programs agrees with the reeonunendation.
'Ihe
recommendation. Tn
In FY 2010.
IJJA
perfommnce measures in thejoll1t
the joint SCA solicitation
established pre- and post-release perfomlunce
DP, similar to measures in the Serious and Violent Offender Reentry
issued with Oll
01JOP.
Initiative (PRI)
Initiative (SVORI) and Prisoner Reentry [nitiative
(PRl) grant
gram programs
Auaclunent 2, pages 7-10).
7~1O). By December 31, 2010, OJJDP
OJ10P will explore adding
lIdding pre·
pre-(see Attachment
ped and issued in FY 20 II.
and post-release performance measures to solicitations
solieit.1tions develo
developed

3J

- 61 -

9.

0,11' co"duet
conduct aII review of
past offender rttntry
reentry programs to
We recommend
rccummc"d that 0.11'
nfpast
identify best pmcliees,
practices, lessons learned, and problems to be avoided when developing
identif}'
developin~
and
lind implementing new reentry programs.
Thc Otlicc
Ofliee of Justice Programs agrees with the recommendation. Prior 10 any SeA
The
SCA
Program soli(;itation
solicitation being
developed, HJA
heing developed.
13JA held a meeting with the
tht:: evaluators
evalumors of three
Progrom
prior DOl-funded
learned which were
DOJ-fundcd reentry initiatives and
aud NIJ,
NIJ. to identify such lessons learnl:d
incorporatcd intn
into thc
incorporated
the initial SCA solicitation.
solicitlltion.
In April 2010, BJA, through the NRRC, convened researchers.
researchers, practitioners.
practitioners, and
policymakers
a two-day "What Works
Expcrt~ Roundtahle."
Roundtable." The first
tirst day
policymakcrs for u
\Vork~ in ({eentry
Reentry Expcns
orlhe
was devuted
devo ted to gleaning 'Iessons
' lessons leumed'
learned ' from previous reentry initiatives
of
the meeting wus
(including SVORI,
SVORI , PR1
the 1111ensivc
Intensive Aftercare Program, Ready4Work,
PRJ., thc
Ready4Work. the Offender
Reentry
Youth Offender Reentry Program, and the Transition
l'ran~ition from Prison
Reenlry Program and Youlh
BlA is in the process of working with the
and Jail to Community Initiatives). BJA
Ihe Urban
report on the infonnation
information exchanged during the roundtable
Institute to finalize ail n:poJ1
discussions.

10.

that O.IP
O.JP ensure that the target population descriptions
We recommend thai
de~eriptions in future
inelude detailed and precise definiliolls.
definitions.
grant solicitation material
malerial include
with the recommendation. In FY 20
2010,
The Offiee
Office of Justice Programs agrees v.ith
I0, DlA
I3JA and
ajoinl solicitation for the SCA
OJJDP issued ajoint
SeA Programs, which included detailed and
precise definitions for SCA applicants to
10 use in detennining,
dd~nnining, developing, and describing
local target populations ill
in their applications (sec Attachment 2, page 3).
J). Within their
localtargcl
applications, SCA applicants
targel population
applic3tions,
applicanls must now identify and define the target
popul3tion proposed
reaso n for
lor selecting the
in their projects.
projects. In addition, SeA applicants must provide a reason
target population, and provide supporting documentation to justify
justify their decision. The
targct
Office of Justice Programs
recommendation.
Offiee
Progr.J.ms requests closure of this recommendation,

11.
II.

We recommend tbat
that OJP
O,JP consider arranging for an evaluation of Ihe
reentry
the SCA rct'ntry
programs.
Offiee of Justice Programs agrees wilh
with the recommendation. In FY 2010, the
The Office
(NIl) worked with BJA to
National Institute of Justice (NU)
10 develop and release the fullowing
followiog
evaluation solicitalions
solicitations of
the SeA
SCA Programs,
accessed at
three evaluatiOn
orlhe
Programs. which may be acccssed
httQ:l/www.ojp.gov/funding/archived solicitations 10. hIm..
lillQ:llwww.ojp.gov/fundiug/archiv.:dsolicitationsIO.htm
•
•
•

orthc Multi-Site Demonstration Field Experiment: Whllt
What Works in
Evaluation ofthc
Reentry Research
ReenlrY
Second Chance Act FY2010
FY20 I0 State,
Stote,
Evaluation ofthc Bureau of Justice Assistance Sl:eond
Tribal, and
<lnd Local Reentry
Reenlry Courts Program
Evaluation of
ofthe
Justice Assistance
As~istance Second Chance Act Adult
the Bureau of Juslice
Demonstration Projects

4

- 62 -

Additionally, although there
not an evaluation
(her~ is
iii nut
evaluatIOn specifically directed at SeA juvenile
Nil
if they
IJ evaluations, if
grantees, these grantees may be asked to participate in one of the N
meet
the criteria under the evaluation solicitation.
Office of Justice Programs
mectthc
solicitation. The Oflice
requests closure of this recommendation.
Thank
you have any questions regarding this
thi s rcsponse,
TIlaI\k. you for your continued cooperation. If
[fyou
response.
contact Maureen A. Hennebcrg,
Hcnncberg, Director,
Managemcnt.
please eonltlet
DireclUr, Officc
Oftlcc of Audit, Assessmcnt, and Management,
on (202) 616-3282.
61 6-3282.
Attachments

cc;
ec:

Beth
Bcth McGarry
A~sistant Attorney General
Deputy Assistant
Operati ons and Management
for Operations

Bureh, II
James H. Burch,
Acting Director
Bureau of Justicc
Justice Assistance
JcfrSlowikowski
Jcfl'Slowikowski
Acting Administrator
Officc of Juvenile Justice and Delinquency Prevention
Oniee
PrevC11lion
Kristina Rose
Acting Director
National Institutc of
or Justice
Nutionallnslitulc

Hennebcrg
Maureen A. !-Icnncbcrg
Director
Office of
of Audit, Assessment, and
und Management
Managemcnt
Pau!!
Marcia
Marcill K. Paull
Chief Financial Officer
ChiefFillancialOfficer
Jeffery A. Haley
Deputy Directo
r, Audit and Review
Revicw Division
Director,
Audit, Assessment, and
Office of Audit.
llnd Management
A, Theis
Richard A.
up
Assistant Director, Audit Liaison Gro
Group
Justice Manngemcnt
Management Division

5

- 63 -

APPENDIX V

OFFICE OF THE INSPECTOR GENERAL

ANALYSIS AND SUMMARY OF ACTIONS

NECESSARY TO CLOSE THE REPORT

The OIG provided a draft of this audit report to the Office of Justice
Programs (OJP). OJP’s response is incorporated in Appendix IV of this final
report. The following provides the OIG analysis of the response and
summary of actions necessary to close the report.
1.	 Closed. OJP concurred with our recommendation that it ensure that
reentry grantees implement and adhere to procedures that result in
timely submission of complete and accurate Federal Financial Reports
and program progress reports. OJP submitted an agenda for a postaward management training workshop for all Bureau of Justice
Assistance (BJA) and Office of Juvenile Justice and Delinquency
Prevention (OJJDP) Second Chance Act (SCA) grantees held in May
2010. In addition, the OJP submitted the website address for a
webinar provided to fiscal year (FY) 2009 SCA grantees that addressed
grantee reporting requirements. After reviewing the agenda for the
workshop and the webinar, we are satisfied that OJP has taken steps
to make SCA grantees aware of reporting procedures to facilitate the
timely submission of complete and accurate Federal Financial Reports
and program progress reports. This recommendation is closed.
2.	 Resolved. OJP concurred with our recommendation that it require
reentry grantees to monitor grant performance to ensure they achieve
program goals and objectives. OJP plans on developing internal
procedures to enhance the compliance rate for the data collected in
BJA’s Performance Measurement Tool (PMT) and in OJJDP’s Data
Collection Tool (DCTAT). This recommendation can be closed when we
receive documentation demonstrating that these internal procedures
have been developed and implemented.
3.	 Resolved. OJP concurred with our recommendation that it enforce

the Grant Manager’s Manual (GMM) requirement to perform and 

document annual desk reviews. OJP plans to incorporate the GMM 

requirement to complete and document desk reviews into grant

managers’ performance work plans by July 2010. This

recommendation can be closed when we receive documentation 


- 64 -

demonstrating that these requirements have been incorporated into
grant managers’ performance work plans.
4.	 Resolved. OJP concurred with our recommendation that it implement
the Performance Measurement Tool (PMT) and use it to collect and
analyze performance measure data collected from the SCA grant
programs. OJP added SCA grant programs to the PMT in January
2010. SCA grantees will begin reporting performance measurement
data in the PMT for data collected for the quarter ending June 30,
2010. In addition, BJA provided a presentation on the National
Reentry Resource Center’s website entitled “Overview of Performance
Measures and Data Collection” for SCA reentry grantees which
informed SCA grantees that the PMT would be used for performance
measurement data submission. This recommendation can be closed
when we receive documentation that PMT is being used to collect and
analyze performance measures data from the SCA grant programs.
5.	 Resolved. OJP concurred with our recommendation that it develop a
consistent and detailed definition of recidivism and ensure it is
disseminated to all grantees. OJP included a specific and detailed
definition of recidivism in the FY 2010 BJA and OJJDP joint SCA
program solicitation. Specifically, OJP defined recidivism for its adult
and juvenile SCA reentry grant programs as a return to prison, jail, or
a juvenile detention or correctional facility, with either a new
conviction or as the result of a violation of the terms of supervision
within 12 months of initial release. However, we believe that OJP
should consider a recidivism definition that includes a time period of
2 or 3 years, which we believe would provide a better reflection of
recidivism than does a 1-year period. This recommendation can be
closed when we receive evidence and the result of OJP’s consideration
to revise its definition of recidivism to include a 2 or 3 year time period
for future reentry grants. If OJP, after careful consideration, decides
not to adjust its current recidivism definition, OJP must provide
documentation justifying its rationale for this decision.
6.	 Resolved. OJP concurred with our recommendation that it require
grantees in offender reentry programs to provide baseline recidivism
rates to facilitate an accurate measurement of program impact on
recidivism. BJA plans on working closely with its SCA grantees to
ensure baseline recidivism data is collected. OJP anticipates that by
December 31, 2010, BJA and OJJDP will have developed baseline
recidivism rates for their respective SCA grantees. This
recommendation can be closed when we receive documentation that
baseline recidivism rates have been developed for BJA and OJJDP
- 65 -

FY 2010 SCA grantees and will be a requirement for future reentry
grants.
7.	 Resolved. OJP concurred with our recommendation that it develop a
process for analyzing grantees’ performance measurement data to
determine if program goals are being met, including whether
recidivism has decreased. OJP plans to work with Consulting Services
and Research, Inc., and the National Reentry Resource Center to
develop guidelines for analyzing SCA grantees’ performance data. In
addition, OJJDP plans on publishing an annual report for its SCA
grantees that summarizes whether activities and accomplishments are
consistent with program goals. This recommendation can be closed
when we receive documentation of the guidelines developed for
analyzing reentry program performance data to determine if program
goals are being met, including whether recidivism has decreased.
8.	 Resolved. OJP concurred with our recommendation that it add to the
SCA grant programs the pre- and post-release performance measures
that were included in the Serious and Violent Offender Reentry
Initiative (SVORI) and Prisoner Reentry Initiative (PRI) grant
programs. Although the OJP response refers to performance measures
improvements in the FY 2010 joint SCA solicitation with BJA and
OJJDP, those performance measures were unchanged from the
FY 2009 BJA and OJJDP SCA solicitations and did not relate to pre- and
post-release services and transition plans. In its response, OJP stated
that it would explore adding pre- and post-release performance
measures to its FY 2011 solicitations. This recommendation can be
closed when we receive documentation of the inclusion of pre- and
post-release performance measures that were included in the SVORI
and PRI grant programs to SCA. In particular and as stated in the
audit report, the missing performance measures relate to the number
of participants referred to pre- and post-release services, the number
of participants who received pre- and post-release services, the
number of offenders for whom a transition plan was developed, the
number of offenders who completed the program, and the services
provided by faith- and community-based providers (including the types
of services provided).
9.	 Resolved. OJP concurred with our recommendation that it conduct a
review of past offender reentry programs to identify best practices,
lessons learned, and problems to be avoided when developing and
implementing new reentry programs. Prior to the SCA grant
programs, BJA held a meeting with the evaluators of the prior DOJfunded reentry initiatives and NIJ to identify lessons learned. In
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addition, in April 2010 a 2-day roundtable was held devoted to
gleaning lessons learned. This recommendation can be closed when
we receive documentation showing OJP’s review of past offender
reentry programs to identify best practices, lessons learned, and
problems to be avoided when developing and implementing new
reentry programs.
10. Closed.	 OJP concurred with our recommendation that it ensure future
grant solicitation material include detailed and precise definitions of
target populations. The BJA and OJJDP joint FY 2010 SCA grant
program solicitation included detailed and precise definitions for SCA
applicants to use in determining, developing, and describing local
target populations. SCA applicants must identify and define the target
population proposed, a reason for selecting the target population, and
supporting documentation to justify their decision. This
recommendation is closed.
11. Closed.	 OJP concurred with our recommendation that it consider
arranging an evaluation of the SCA reentry programs. BJA worked
with the National Institute of Justice (NIJ) to develop and release three
evaluation solicitations of the SCA grant programs, one of which is
directed at BJA’s SCA adult demonstration programs. This
recommendation is closed.

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