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). -i- 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. - ii - 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. - iii - 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 - iv - 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 -v- 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. - vi - 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 - vii - 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. - viii - 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 This page intentionally left blank 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. -1- 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. -2- 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. -3- $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. -4- 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. -5- 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. -6- 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). -9- 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. - 10 - 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. - 11 - 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. - 12 - 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. - 18 - 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 - 66 - 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. - 67 -