United States Government Accountability Office

GAO

Report to Congressional Requesters

June 2006

FAITH-BASED AND
COMMUNITY
INITIATIVE
Improvements in
Monitoring Grantees
and Measuring
Performance Could
Enhance
Accountability

GAO-06-616

June 2006

Accountability Integrity Reliability

Highlights
Highlights of GAO-06-616 a report to
congressional requesters

FAITH-BASED AND COMMUNITY
INITIATIVE
Improvements in Monitoring Grantees
and Measuring Performance Could
Enhance Accountability

Why GAO Did This Study

What GAO Found

The Administration’s efforts to
improve the federal government’s
provision of social services through
its Faith-Based and Community
Initiative have sparked
considerable interest. GAO was
asked to examine (1) the activities
of the initiative-related centers in
five federal agencies; (2) the grant
award procedures for selected
grants; (3) the extent to which
selected federal and state agencies
are providing information on and
ensuring compliance with
safeguards designed to protect
faith-based organizations (FBO),
beneficiaries, and the government;
and (4) how the progress of the
initiative is being measured. We
interviewed government officials
administering 10 grant programs
and officials from 26 FBOs.

In 2001 the Administration introduced the Faith-Based and Community
Initiative and established initiative-related centers in five federal agencies.
The centers employ a range of activities and resources to implement the
initiative. Since fiscal year 2002, these centers have cumulatively spent more
than $24 million on administrative activities.

What GAO Recommends
We recommend that the Director of
the Office of Management and
Budget (OMB) ensure that all
agencies with initiative-related
centers include information on the
safeguards in grant documents and
in monitoring guidelines, improve
data on grants awarded to FBOs,
and develop a plan for reporting on
progress toward the initiative’s
long-term goals. OMB generally
agreed but expressed some
concerns about the practicality of
implementing a few of the
recommendations. We also
recommend that the Department of
Justice clarify its regulations on
allowed activities and clarify
relevant language in its contracts,
and Justice generally agreed.
www.gao.gov/cgi-bin/getrpt?GAO-06-616.
To view the full product, including the scope
and methodology, click on the link above.
For more information, contact Andrew Sherrill
at (202) 512-7252 or ASherrill@gao.gov.

In reviewing grant applications and awarding grants, federal and state
agencies reported using the same process for FBOs as they do for other
organizations in the 10 grant programs we reviewed. Since 2001, federal
agencies have awarded over $500 million through new grant programs to
provide training and technical assistance to faith-based and community
organizations and to increase the participation of these organizations in
providing federally funded social services.
The government agencies administering the programs that we reviewed
provided grantees with some information on the safeguards designed to
protect the interests of FBOs, beneficiaries, and the government. Most of the
agencies provided grantees with an explicit statement on the safeguard
prohibiting the use of direct federal funds for inherently religious activities.
If these activities are offered, they must be offered separately in time or
location from services provided with direct federal funds and must be
voluntary for the beneficiary. However, we found that Justice’s regulation
and guidance related to these activities is unclear for its correctional
programs. We also found that only four programs provided a statement on
the rights of program beneficiaries and only three provided information on
permissible hiring by FBOs. While officials in all 26 FBOs that we visited said
that they understood that federal funds cannot be used for inherently
religious activities, a few FBOs described activities that appeared to violate
this safeguard. Four of the 13 FBOs that provided voluntary religious
activities did not separate in time or location some religious activities from
federally funded program services. Government agencies are not required to
monitor FBO grantees differently than secular organizations. Few of the
federal and state agencies administering these programs included references
in their monitoring guidelines on grantee compliance with the safeguards.
OMB and the White House Office of Faith-Based and Community Initiatives
assess agencies’ progress in implementing the short-term goals of the
initiative and highlight this progress through a number of published vehicles.
However, it is unclear whether the data reported on grants awarded to FBOs
provide policymakers with a sound basis to assess the progress of agencies
in meeting the initiative’s long-term goal of greater participation of faithbased and community organizations. Moreover, little information is available
to assess progress toward another long-term goal of improving participant
outcomes because outcome-based evaluations for many pilot programs have
not begun. Also, OMB faces other challenges in measuring and reporting on
agencies’ progress in meeting the long-term goals of the initiative.
United States Government Accountability Office

Contents

Letter

Appendix I

1
Results in Brief
Background
Centers Employ Different Activities and Resources to Implement
the Initiative
Agencies Use Same Grant Award Procedures for Faith-Based as
Other Organizations, and Some New Grant Programs
Established to Encourage More Faith-Based and Community
Organization Participation
Government Agencies Generally Provide Grantees with
Information on Safeguards, but Most Do Not Have Procedures in
Their Monitoring Guidelines for Assessing Compliance
OMB and WHOFBCI Assess Agencies’ Progress in Implementing
Initiative, but Data Limitations and a Lack of Information May
Hinder Ability to Measure Progress toward Achieving Initiative’s
Long-Term Goals
Conclusions
Recommendations for Executive Action
Agency Comments

5
10

40
51
53
54

Centers’ Estimated Expenditures by Category,
Fiscal Year 2005

61

16

22

29

Appendix II

Selected Characteristics of Faith-Based Organizations
GAO Visited
62

Appendix III

Best Practices for the Initiative’s Standards for
Success

65

Best Practices for Outreach and Technical Assistance
Best Practices for Implementation of Equal Treatment Regulations

65
66

Comments from the Department of Justice

68

GAO Comments

72

Comments from the Department of Education

75

Appendix IV

Appendix V

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GAO-06-616 Faith-Based and Community Initiative

Appendix VI

Comments from the Department of Health and
Human Services

77

Comments from the Department of Housing and
Urban Development

79

Appendix VIII

Comments from the Department of Labor

81

Appendix IX

GAO Contacts and Staff Acknowledgments

83

Appendix VII

Tables
Table 1: Executive Orders Related to the Faith-Based and
Community Initiative
Table 2: Equal Treatment Safeguards and the Key Parties They Are
Designed to Protect
Table 3: Selected Federal Programs Providing Funding to Various
Organizations, Including Faith-Based Organizations
Table 4: New Grant Programs Intended to Encourage Faith-Based
and Community Organization Participation in Federally
Funded Social Efforts
Table 5: Extent to Which Safeguards Are Included in Program
Grant Documents
Table 6: OMB’s Green and Yellow Standards for Success for
Executive Agencies with Centers for the Faith-Based and
Community Initiative
Table 7: Most Required Outcome Evaluations Not Completed, and
Some Design Plans May Not Support an Evaluation of
Program Outcomes

11
13
24

26
31

41

48

Figure
Figure 1: Estimated Expenditures of Centers for Faith-Based and
Community Initiatives, Fiscal Years 2002 through 2005

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GAO-06-616 Faith-Based and Community Initiative

Abbreviations
FBCI
FBO
HHS
HUD
OMB
PMA
WHOFBCI

Faith-Based and Community Initiatives
faith-based organization
Department of Health and Human Services
Department of Housing and Urban Development
Office of Management and Budget
President’s Management Agenda
White House Office of Faith-Based and Community
Initiatives

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GAO-06-616 Faith-Based and Community Initiative

United States Government Accountability Office
Washington, DC 20548

June 19, 2006
The Honorable George Miller
Ranking Minority Member
Committee on Education and the Workforce
House of Representatives
The Honorable Pete Stark
Ranking Minority Member
Subcommittee on Health
Committee on Ways and Means
House of Representatives
Each year the federal government provides billions of dollars to
organizations that provide social services to needy families and
individuals. In large part, these funds are provided through competitive
grants and contracts either directly to organizations or through formula
grants passed through state agencies to local organizations. Organizations
providing these services have traditionally included both secular and faithbased organizations (FBO), which include churches and religiously
affiliated entities. In the past, as a condition of receiving public funds,
FBOs were required to secularize their services and premises so that their
social service activities were distinctly separate from their religious
activities.1 More recently, courts have become less concerned with the
religious nature of the organization, and in 1996 Congress enacted
“charitable choice” provisions which authorized religious organizations2 to
compete on the same basis as other organizations for federal funding
under certain programs without having to alter their religious character.3

1

This was based on a number of Supreme Court opinions, which interpreted the First
Amendment and addressed the eligibility of religious organizations to receive federal funds.
See Committee for Public Education v. Nyquist, 413 U.S. 756 (1973).

2

The federal legislation applies to charitable, religious, or private organizations but does not
specifically define the term “religious organization.”

3
For a discussion on implementation of charitable choice regulations see GAO, Charitable
Choice: Federal Guidance on Statutory Provisions Could Improve Consistency of
Implementation, GAO-02-887 (Washington, D.C.: Sept. 10, 2002).

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GAO-06-616 Faith-Based and Community Initiative

In 2001, the President created the White House Office of Faith-Based and
Community Initiatives (WHOFBCI) to establish policies, priorities, and
objectives to further expand the work of faith-based and community
organizations. In that same year, the President, by executive order, created
centers for the Faith-Based and Community Initiatives (FBCI) in five
federal agencies that administer a broad range of social service programs.4
Then, through a series of executive orders, the President incorporated
charitable choice principles in social service programs administered by
federal agencies, created initiative-related centers in six additional federal
agencies,5 and established fundamental principles for FBOs receiving
federal funds. Modeled after the charitable choice legislation, these
principles included safeguards designed to protect the interests of FBOs,
beneficiaries receiving social services, and government agencies providing
federal funds. For example, FBOs are allowed to retain religious icons and
symbols in the facilities where they provide services and generally are not
prohibited by federal law from making employment decisions based on
religious grounds, even after receiving federal funds. However, they are
not permitted to provide “inherently religious” activities such as prayer or
worship with direct federal funds or discriminate against beneficiaries on
the basis of religion.
The Administration’s efforts to expand opportunities for these
organizations and to strengthen their capacity to provide social services
through its initiative has sparked considerable interest both among various
parties involved in providing social services and among researchers,
religious leaders, and other groups. Some have lauded efforts to encourage
more FBOs to seek federal funds, maintaining that these organizations are
more in tune with the needs of their communities than other organizations
and can better serve individuals that may need a range of social services.
Others have expressed concerns about the potential for federal funds to be
used for religious purposes and the extent to which organizations are
monitored to ensure the appropriate use of federal funds. Government
agencies primarily monitor grantees by reviewing grantee documents,
conducting site visits, and conducting single audits. The Single Audit Act
requires state and local governments and nonprofit organizations that

4

These agencies are the Departments of Health and Human Services, Housing and Urban
Development, Education, Labor, and Justice.

5

The six additional centers are the Department of Agriculture, the Agency for International
Development, the Department of Commerce, the Department of Veterans Affairs, and the
Small Business Administration, and most recently, the Department of Homeland Security.

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GAO-06-616 Faith-Based and Community Initiative

expend $500,000 or more in federal awards in a fiscal year to have a single
audit, which is an audit of the federal grantee’s financial statements and
compliance with laws and regulations governing federal awards. While
government agencies are responsible for ensuring that grantees comply
with grant requirements, little is known about how these agencies are
working with FBOs to ensure that these organizations understand and
comply with the safeguards.
In addition, a sound performance and reporting system for the initiative is
important in light of claims by some interested parties that the initiative
has increased participation by faith-based and community organizations in
providing federally funded social services. It is also important as Congress
is likely to continue to discuss efforts to formalize—by establishing in
statute—the WHOFBCI and the work activities within the federal centers
for the faith-based and community initiative. An informed debate about
these issues is helped by the availability of credible performance
information focusing on the outcomes achieved with budgetary resources
and other tools.6
To shed light on how centers and federal agencies are carrying out the
initiative and how the government is assessing the initiative’s
performance, you asked us to explore the work of the centers and
agencies in implementing the initiative, including the extent to which
government entities are providing guidance to, and oversight of, faithbased grantees.
Specifically, you asked:
1. How do the activities and resources of the initiative-related centers in
five federal agencies compare?
2. What are the grant award procedures for selected project and formula
grants, and are they the same for all grant applicants, including FBOs?
3. To what extent are selected federal and state agencies providing
information on and ensuring compliance with the safeguards designed
to protect the interests of FBOs, beneficiaries, and the government?

6

For more information on reexamining federal programs and performance budgeting, see
GAO, 21st Century Challenges: Performance Budgeting Could Help Promote Necessary
Reexamination, GAO-05-709T (Washington, D.C.: June 14, 2005).

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GAO-06-616 Faith-Based and Community Initiative

4. How is the federal government measuring the progress of the
initiative?
To understand how the centers administer the initiative, we interviewed
center officials in the five agencies that were the first to establish centers
for the Faith-Based and Community Initiative. These are the Departments
of Education (Education), Health and Human Services (HHS), Housing
and Urban Development (HUD), Justice, and Labor. We analyzed data on
their expenditures and work activities and, to assess the reliability of the
data for expenditures, we conducted semistructured interviews with
agency officials about data quality control procedures and reviewed
relevant documentation. We determined the data were sufficiently reliable
for the purposes of this report. Our review focused on 10 programs,
including at least 1 program from each of these five agencies. To obtain
information on how these agencies award and monitor grants to FBOs, we
interviewed program officials administering six federal project grants
(competitive project grants awarded by a federal agency directly to a local
organization), and one competitive procurement program. We chose
programs that awarded grants to numerous FBOs and that provided a
range of social services, including mentoring of children, housing for the
homeless, and business development grants to refugees.7 We also met with
federal program officials responsible for overseeing three formula grant
programs (program grants that are passed through state agencies to local
organizations) that attract or are likely to attract significant FBO
participation.8 For the 10 programs included in our review, we also
analyzed pertinent documents provided to grantees and prospective
grantees, such as grant applications, contracts, and award letters. Our
findings pertain to the 10 programs included in our review and are not
generalizable to all programs administered by these five agencies. To
understand how the federal government measures the progress of the
initiative, we spoke with officials from the Office of Management and
Budget (OMB) and analyzed pertinent documents.

7

The six competitive project grant programs are Mentoring Programs (Education);
Community-Based Abstinence Education Program; Mentoring Children of Prisoners;
Microenterprise Development Program (HHS); Continuum of Care (HUD); and Small
Grassroots Faith-Based and Community Organizations Connecting with the One-Stop
Delivery System (Labor). The competitive procurement program is Justice’s Community
Corrections Contracting.

8

The formula grants included in our review are HHS’s Abstinence Education Program and
its Substance Abuse Prevention and Treatment Block Grant, and HUD’s Emergency Shelter
Grant Program.

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To obtain more specific information on how the three formula grants are
awarded by the states to local organizations and how their grantees are
monitored for compliance with the safeguards, we visited four states—
California, Georgia, Ohio, and Texas—and interviewed numerous state
officials. We also interviewed county officials in California and Ohio and
several federal regional and field office program staff. We chose these
states because they each received significant funding from federal direct
programs in 2003 or 2004 and because FBOs in these states received funds
from at least 3 or more of our selected programs. In addition, we
considered geographic dispersion and diversity in terms of whether the
state established an initiative-related center.9
We also conducted semistructured interviews with 26 selected FBOs in
these four states to determine their understanding of program regulations
and the extent to which they have been monitored for compliance with the
key safeguards related to the initiative. We selected FBOs that had
received federal project and formula grants in 2003 or 2004 from the
10 programs included in our review. Finally, we interviewed independent
auditors in three states who had completed single audits for a few of our
selected FBOs. Because we used a nonprobability sample of FBOs, our
findings are not generalizable to all FBOs receiving federal funds from the
programs included in our review. Our work was conducted from March
2005 through June 2006 according to generally accepted government
auditing standards.

Results in Brief

The five centers for faith-based and community initiatives that we
reviewed employ a range of activities and resources to implement the
initiative, in part based on what activities center officials determined was
necessary to fulfill their responsibilities for the initiative and differences in
center staffing levels and administrative costs. One of the centers’ first
tasks was to identify and eliminate barriers to the participation of faithbased and community organizations in federally funded services. The
centers’ ongoing efforts include collecting data on FBOs’ participation in
federal grant programs, developing pilot programs, and providing outreach
and technical assistance to faith-based and community organizations. The
centers adopted different approaches to technical assistance training
activities based on what they needed to do to support the initiative. In

9

Texas and Ohio have established state faith-based offices, while California and Georgia
have not.

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general, HUD’s and Education’s centers help organizations learn how to
apply for funds, while Labor’s center helps grantees learn how to manage
grants. Justice’s and HHS’s centers coordinate with program offices that
provide training to these organizations. The next phase of the centers’
work will focus on encouraging partnerships between faith-based and
community organizations and state and local governments. Since fiscal
year 2002, the five centers estimated that they had cumulatively expended
more than $24 million on administrative activities, but these estimates
generally did not include additional funding that agency program offices
provided to assist in the initiative’s implementation, such as administrative
costs associated with program offices’ efforts to assist faith-based and
community organizations. In fiscal year 2005, four of the centers spent the
largest proportion of their funding on staff salaries and benefits—ranging
from 35 percent to 87 percent—followed by other expenditures for such
administrative costs as rent, contracts, and travel. Factors such as the
number of staff and differences in administrative costs such as rent and
travel account for, in part, the differences in resources across centers.
Federal and state officials told us they do not treat FBOs any differently
than other organizations during the grant award process in the 10 federal
programs we examined. Some new programs have been established since
the beginning of the initiative to provide training and technical assistance
to faith-based and community organizations and increase faith-based and
community organization participation in delivering federally funded
services. In the programs we reviewed, agencies used standard criteria and
independent reviewers to evaluate applications for funding, and reviewers
do not necessarily know whether an applicant is faith-based because
organizations are generally not required to identify themselves as FBOs.
Funding decisions were generally based on applicants’ scores that were
awarded for various criteria, such as the quality of the project plan. While
the process to award funds is the same for faith-based as for other
organizations, between fiscal years 2002 and 2005, federal agencies have
awarded over $500 million through new competitive grant programs that
are intended to encourage greater participation of faith-based and
community organizations in providing these social services. Some of these
programs, such as Labor’s Prisoner Reentry Initiative, limit eligibility to
these organizations, while others, such as HHS’s Compassion Capital Fund
Demonstration Program, fund intermediary organizations that provide
capacity-building assistance to faith-based and community organizations.
The government agencies administering the programs that we reviewed
provided grantees with some information on the safeguards designed to
protect FBOs, their clients, and the government, but few agencies included

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in their monitoring guidelines checks for grantee compliance with the
safeguards related to nonallowable activities and nondiscrimination
against beneficiaries. Specifically, 7 of the 10 federal programs that we
reviewed provided a statement to grantees regarding the prohibition on
the use of direct federal funds for inherently religious activities. Officials
at Justice told us that they believe FBOs in the Community Corrections
Contracting program are exempt from the prohibition on providing
inherently religious activities because of an exception specified in the
agency’s regulations. However, we believe that the scope of this exception
is left unclear and thus could create uncertainty for FBO program staff
about allowable religious activities using federal funds. Regarding the
safeguards on nondiscrimination against beneficiaries and permissible
hiring by FBOs, only 4 provided a statement on nondiscrimination and
only 3 provided information on permissible hiring by FBOs based on
religion. While officials in all 26 FBOs that we visited told us that they
understood that federal funds could not be used for inherently religious
activities, 4 of the 13 FBOs that offered voluntary religious activities—
such as prayer or worship—did not appear to understand the requirement
to separate these activities in time or location from their program services
funded with federal funds. For example, one FBO official told us that she
discusses religious issues while providing federally funded services if
requested by a participant and no other participants object, and a few told
us that they pray with beneficiaries during program time if requested by
the beneficiary. Government agencies are not required to monitor FBO
grantees differently than secular organizations. Only 2 of the 7 federal
agencies providing project and procurement grants, and 5 of the 13 state
agencies administering formula grants included references in their
monitoring guidelines on grantee compliance with these safeguards.
Agencies’ single audit reviews, which can be used as an effective tool to
monitor organizations, only apply to those organizations expending
$500,000 or more in federal funding in a given year, and generally do not
include specific checks for these safeguards.
OMB and WHOFBCI assess agencies’ progress in implementing the shortterm goals of the initiative, but data limitations—such as the difficulty in
identifying an FBO—and a lack of publicly available information hinder
the federal government’s efforts to measure agencies’ progress in
achieving the initiative’s two long-term goals. OMB and WHOFBCI assess
agencies’ implementation of the initiative and grade agencies’ efforts to
carry out activities in accordance with the Standards for Success that
outline the centers’ responsibilities, such as collecting accurate data on
the participation of faith-based and community organizations and
conducting outcome evaluations of all pilot programs. OMB and

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WHOFBCI award a green grade to agencies that meet all of the initiative’s
standards for success. In the first quarter of fiscal year 2006, three of the
five centers we reviewed received green status. OMB established two longterm goals for the initiative—greater participation by faith-based and
community organizations and improved participant outcomes—but data
limitations may hinder efforts to assess the initiative’s progress in
achieving these goals. Importantly, there are no criteria for what
constitutes a faith-based organization that all agencies must use to identify
FBOs, and FBOs are not required to self-identify, leaving individual
agencies and states to determine which organizations are faith-based.
Determining what elements constitute an FBO is challenging. Although no
method can ensure that all data collected are accurate, having consistently
applied criteria or requiring self-identification would provide greater
assurance that agencies are collecting accurate data than the current
method. Moreover, while the WHOFBCI has published data on trends of
FBO participation in providing federally funded social services, it has not
reported on the participation of community-based organizations—the
other group of organizations specified in the long-term goal. Consequently,
it is unclear whether the reported data by the WHOFBCI provides
policymakers with a sound basis to assess the progress of agencies in
meeting the initiative’s long-term goal of greater participation of faithbased and community organizations. Progress in achieving the initiative’s
long-term goal of improved participant outcomes is not yet known
because most agencies have not completed the OMB-required outcomebased evaluations of their pilot programs. Of the 15 pilot programs under
way, 1 outcome-based evaluation has been completed, 6 evaluations are
under way, and 6 are planned. Outcome-based evaluations are not planned
for 2 of the pilot programs. Outcome-based evaluations may involve
several years of data collection before the analysis can take place and
several of these pilot programs were initiated only a few years ago. OMB
also faces other challenges in measuring and reporting on how agencies
are progressing toward accomplishing the initiative’s two long-term goals.
To improve grantee understanding and federal agency oversight of the
equal treatment regulations for programs in which faith-based
organizations are eligible for federal funding, we recommend that the
Director of OMB ensure that all agencies with initiative-related centers
include information on the equal treatment safeguards in their grant
documents and direct agencies to include a reference to these safeguards
in their monitoring tools. To ensure that contractors for Justice’s
correctional programs understand the exception to the prohibition on
using federal funds for inherently religious activities, we recommend that
the Attorney General clarify the exception in Justice’s equal treatment

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regulations and include a clear explanation of the exception and its scope
in the contracts for its correctional programs. To improve accountability
of the Faith-Based and Community Initiative, we recommend that the
Director of OMB work with agencies to improve how federal agencies
identify which organizations are faith-based and develop a plan for
measuring and reporting on agency progress in achieving the long-term
goals of the initiative.
We received comments from Education, HHS, HUD, Justice, Labor and
OMB on a draft of this report. OMB officials stated that they generally
agreed with the report’s recommendations, although they had comments
pertaining to several of the recommendations. With regard to our
recommendation that program-specific single audit supplements include a
reference to the equal treatment safeguards, OMB stated that for some
programs that already have extensive audit requirements, expanding the
program-specific audit requirements could pose additional burdens to the
independent auditors conducting those reviews. In response, we modified
the recommendation to indicate that it might not be appropriate to include
a reference to the equal treatment safeguards in some program-specific
audit supplements. OMB officials raised issues with our recommendation
pertaining to getting better data, saying that while they agreed that
obtaining better data would be helpful, there are obstacles to obtaining
better data and that they are uncertain about the extent to which the data
could be further improved. While we acknowledge the challenges in
obtaining data, various agency centers or program offices are currently
applying criteria—whether explicitly or implicitly—that determine
whether they categorize an organization as an FBO, and we believe that
greater consistency in their use of criteria could improve the data. With
regard to our recommendation that OMB develop a plan to measure and
report out on long-term goals, OMB said it was reasonable for OMB to
report out on the results of agencies’ outcome evaluations of pilot
programs but that the White House was already reporting data on
participation of faith-based organizations. OMB proceeded to
acknowledge that there is a lack of clarity about how the two long-term
goals of the initiative are linked with OMB’s Standards for Success and
that it may be appropriate to clarify their connection as part of a
reassessment of the long-term goals. In response, we broadened the
wording of our recommendation to note that it may be appropriate to
clarify the connection of the long-term goals to the Standards for Success.
In its comments, Justice generally agreed with the two recommendations
we made to the Attorney General. Justice, Education, HHS, HUD, and
Labor raised various issues with the report, which we discuss and respond
to in the agency comments section of the report and appendix IV on

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GAO-06-616 Faith-Based and Community Initiative

Justice’s comments. Education, HHS, HUD, Labor and OMB also provided
technical comments, which we incorporated where appropriate.

Background

Citing the crucial role faith-based and community organizations play in
areas such as curbing crime and overcoming addiction, in 2001 the
President introduced the WHOFBCI with the goal of expanding
opportunities for these organizations and to strengthen their capacity to
provide social services. The President issued executive orders that created
the WHOFBCI, initiative-related centers in several federal agencies, and
rules to ensure that organizations are treated equally in government
programs.

Executive Orders
Establish Centers and
Responsibilities

Beginning in January 2001, the President issued several executive orders
to implement the Faith-Based and Community Initiative (see table 1).
These executive orders established a WHOFBCI and centers for faithbased and community initiatives in a number of federal agencies as well as
principles for ensuring equal treatment of faith-based and community
organizations in federal government programs.

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Table 1: Executive Orders Related to the Faith-Based and Community Initiative
Executive order

Purpose

Description

Executive Order 13199
January 29, 2001

Created the White House Office of FaithBased and Community Initiatives

The White House Office of Faith-Based and Community
Initiatives is given lead responsibility to establish policies,
priorities, and objectives for efforts to expand opportunities for
faith-based and community organizations to provide social and
community services

Executive Order 13198
January 29, 2001

Created Centers for Faith-Based and
Community Initiatives in five agencies:
Education, HHS, HUD, Justice, and Labor

To coordinate agency efforts to eliminate obstacles to the
participation of faith-based and community organizations in
providing federally funded social services

Executive Order 13280
December 12, 2002

Created centers for Faith-Based and
Community Initiatives in two additional
agencies: Department of Agriculture and
Agency for International Development

To coordinate agency efforts to eliminate obstacles to the
participation of faith-based and community organizations in
providing federally funded social and community services

Executive Order 13279
December 12, 2002

To provide, among other things, guidance
to federal agencies in formulating policies
regarding faith-based and community
organizations and to ensure equal
protection under the laws for these
organizations

Set out criteria on fundamental principles and policymaking that
designated federal agencies can use in establishing safeguards
applicable to FBOs providing services under federal programs

Executive Order 13342
June 1, 2004

Created centers for Faith-Based and
Community Initiatives in three additional
agencies: Departments of Commerce and
Veterans Affairs and the Small Business
Administration

To coordinate agency efforts to eliminate obstacles to the
participation of faith-based and community organizations in
providing federally funded social and community services

Executive Order 13397
March 7, 2006

Created Center for Faith-Based and
To coordinate agency efforts to eliminate obstacles to the
Community Initiatives in the Department of participation of faith-based and community organizations in
Homeland Security
providing federally funded social and community services
Source: GAO analysis of White House Office of Faith-Based and Community Initiatives Information.

These executive orders identify the key responsibilities for each center:
•
•
•
•
•

an agencywide audit of barriers to participation of faith-based and
community organizations in delivery of social services;
removal of barriers to these organizations’ participation in providing
federally funded social and community services;
a comprehensive effort to incorporate faith-based and community
organizations in department programs and initiatives;
development of pilot and demonstration programs to increase these
organizations’ participation in federal, state, and local initiatives; and
development and coordination of outreach efforts to disseminate
information more effectively to these organizations.

The executive orders also direct the centers to coordinate their activities
with the WHOFBCI. Centers do not award any federal funds to faith-based
and community organizations. However, they coordinate with agency

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program offices that are responsible for awarding federal funds and
monitoring grantees. For example they review program funding guidance
to ensure that the program does not contain barriers to these
organizations’ participation and interact with agency program offices to
develop and coordinate department efforts to disseminate information
more effectively to faith-based and community organizations with respect
to programming changes, contracting opportunities, and other department
initiatives.

Equal Treatment
Regulations Set Forth
Safeguards Applicable to
Direct and Formula
Federal Grants

As noted in table 1, Executive Order 13279 of December 12, 2002, directed
designated federal agencies to establish safeguards for the participation of
faith-based organizations in a broad set of federal social service programs,
including mentoring, housing, and job training programs. Congress had
previously enacted charitable choice provisions as part of the Temporary
Assistance for Needy Families (TANF) program, Community Services
Block Grant program, and the Substance Abuse Prevention and Treatment
Block Grant several years earlier.10
To implement this executive order, federal agencies with centers for the
faith-based and community initiative subsequently issued “equal
treatment” rules. These rules apply to project grants awarded by the
federal government to faith-based and community organizations, formula
and block grants awarded to states where funds are passed down to these
organizations, and other financial agreements.11 These rules state that
FBOs are eligible to participate in federal programs on the same basis as
other private organizations, and include safeguards to protect the interests
of FBOs, beneficiaries of social services, and government agencies
providing funds (see table 2). For example, FBOs are not permitted to use
direct federal funds for inherently religious activities such as prayer,
religious instruction, worship, or proselytization. If an FBO conducts such
activities, the activities must be separated by time or location from
federally funded services or programs and must be voluntary for the
beneficiary. However, they are allowed to retain religious art, icons, or

10

Charitable choice provisions were enacted for TANF as part of the Personal
Responsibility and Work Opportunity Reconciliation Act of 1996, in the 1998
reauthorization of the Community Services Block Grant program, and in the amendments
to the Public Health Service Act in 2000 affecting the Substance Abuse Prevention and
Treatment Block Grant Program.

11

The equal treatment rules also cover agency contracts and cooperative agreements.

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symbols in the facilities where they provide services. In addition, for the
programs in our review, FBOs generally are not prohibited under federal
law from making employment decisions based on religious grounds, even
after receiving federal funds.
Table 2: Equal Treatment Safeguards and the Key Parties They Are Designed to Protect
Government
entities

Safeguards
FBOs are eligible to compete for funding on the same basis as other nonprofit
organizations.
FBOs may not use direct government fundsa to support inherently religious activities
such as prayer, worship, religious instruction, or proselytization. Any inherently
religious activities must be offered separately in time or location from services
directly funded with government assistance and must be voluntary for participants.
FBOs retain control over their internal governance and do not have to remove
religious art, icons, and symbols.

FBOs
X

X

X

X

FBOs cannot discriminate on the basis of religion or religious belief in providing
services to clients.
FBOs generally retain the ability to make employment decisions on religious
b
grounds, even after receiving federal funds.

Beneficiaries

X
X

Source: GAO analysis.
a

This safeguard does not apply to federal funds provided indirectly to religious organizations. For
example, it does not apply to funds that a provider receives as a result of an independent choice of a
beneficiary, such as programs that provide vouchers to beneficiaries who then redeem the vouchers
for services at a provider of their choice. Providers may offer voluntary religious activities without
separation of time or location from the social service if beneficiaries are given a genuine choice
between faith-based and secular service providers as part of indirect funding, such as a voucher
program.

b

There are exceptions to this protection as some programs, such as Workforce Investment Act
programs and Head Start, currently contain statutory language that prohibits faith-based
organizations receiving funds from making employment decisions on religious grounds. In addition,
FBOs may be subject to state or local laws prohibiting discrimination in employment based on
religion.

Charitable choice provisions enacted by Congress for the TANF and
Substance Abuse Prevention and Treatment programs contain an
additional safeguard that entitles clients who object to the religious
character of a provider to receive services from an alternative provider to
which the client has no religious objection. However, this safeguard is not
part of the equal treatment rules agencies issued in response to the
President’s 2002 executive order and does not apply to other federal
programs.
During the federal rule-making process for the equal treatment regulations,
some interested parties expressed a need for greater clarity and

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safeguards in the proposed rules. For example, commenters stated that it
was unclear which activities would be considered “inherently religious.”
Agencies declined to clarify which activities would be considered
inherently religious apart from the general examples provided in the
agencies’ respective rules, noting the difficulty in establishing a list of such
activities and that the Supreme Court has not comprehensively defined
these activities.12 Of the agencies we reviewed, most cited the Supreme
Court decision of Mitchell v. Helms as support for the view that aid
provided to religious institutions does not necessarily advance the
institutions’ religious purposes and emphasized the secular nature of the
federally funded services.13 The regulations state that if a grantee engages
in religious activities such as prayer, such activities must be voluntary for
the beneficiary and the grantee must offer them separately in time or
location from the programs funded with direct federal financial
assistance.14
Some commenters on agencies’ equal treatment regulations also urged
agencies to adopt additional assurances to prevent funds from being
diverted for improper religious purposes.15 However, in their final rules,
agencies stated they found no basis for requiring additional assurances or
greater oversight and monitoring of FBOs, as all participants must comply
with all rules applicable to federal grants, including the equal treatment
rules. In addition, they stated that agencies’ current monitoring and
oversight practices for all grantees would be sufficient to ensure that
federal funds are used for eligible activities.

12
See,Participating in Justice Department Programs by Religious Organizations;
Providing for Equal Treatment for All Justice Department Program Participants,
(Department of Justice Final Rule) 69 Fed. Reg. 2832 (2004).
13

530 U.S. 793 (2000) (plurality opinion).

14

See, for example, the Department of Justice regulation at 28 C.F.R. §38.2(b)(1).

15

In her concurring opinion in Mitchell v. Helms, Justice O’Connor found private schools’
receipt of funding from the federal program at issue in that case (providing funds to state
educational agencies to be used for instructional and educational materials) to be
constitutionally acceptable in part because of the adequacy of the safeguards employed by
the federal, state, and local governments to prevent diversion of federal program funds to
religious purposes. These safeguards included signed assurances by the schools receiving
the program funds, monitoring visits by the state and local educational agencies, and
appropriate labeling of materials and equipment purchased with program funds.

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Agencies Monitor Grantees
Through Various Means,
Including Desk Audits, Site
Visits, and the Single Audit

Federal agencies monitor their grantees for programmatic and financial
compliance. OMB provides general guidance, through Circular A-110, on
the administration by federal agencies of grants to and agreements with
nonprofit organizations.16 OMB guidance also notes that the awarding
agency may make site visits part of its monitoring procedures, but it does
not require site visits or prescribe how many grantees should be visited or
how often.
Nonfederal entities (i.e., state, or local government, or a nonprofit
organization) that expend $500,000 or more annually in federal awards are
required to have a single audit conducted for that year. The Single Audit
Act, as amended, replaced multiple audits of separate grant awards with
one organizationwide audit.17 Federal awarding agencies are responsible
for such tasks as issuing a management decision on audit findings within
6 months after receiving the audit report and ensuring that the recipient
takes appropriate and timely corrective action.18 OMB Circular A-133
requires the auditor to report on compliance, and include an opinion by
the auditor as to whether the entity complied with laws, regulations, and
grant agreements. In addition, federal agencies provide specific audit
guidelines for selected programs that direct the auditor to check for
program-specific compliance requirements. For example, program-specific
compliance requirements include a section on allowable and unallowable
activities that detail what a grantee can and cannot do with federal funds
in a particular program. For those programs that do not have programspecific guidelines, an auditor is to use the more general single audit
guidance provided by OMB.

16

OMB Circular A-110 requires that the performance reports shall generally contain brief
information, such as (1) a comparison of actual accomplishments with the goals and
objectives established; (2) if appropriate, reasons why goals were not met; and (3) other
pertinent information, such as an explanation of cost overruns. It also provides guidance
on the type of information that should be included in the grantee’s financial report.

17

OMB Circular A-133 provides single audit requirements. It sets forth standards for
obtaining consistency and uniformity among federal agencies for the audit of states, local
governments, and non-profit organizations expending federal awards.

18

See OMB Circular A-133 for other federal agency requirements that pertain to single
audits.

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Centers Employ
Different Activities
and Resources to
Implement the
Initiative

The five centers for faith-based and community initiatives that we
reviewed employ a range of activities and resources to implement the
initiative, in part based on what activities center officials believed was
necessary to fulfill their responsibilities for the initiative and differences in
staffing levels and administrative costs. Initially, the centers’ activities
focused on identifying and eliminating barriers to the participation of
faith-based and community organizations in federally funded services. The
centers’ ongoing efforts include collecting data on FBOs’ participation in
agency programs, implementing pilot programs, and providing outreach
and technical assistance to these organizations. The centers adopted
different approaches to technical assistance training activities. The
centers’ future work will focus on encouraging partnerships between faithbased and community organizations and state and local governments,
according to center officials. The centers estimated that they have
cumulatively spent more than $24 million on administrative activities,
although their resource levels and administrative costs varied depending
on the number of staff members and rent and travel costs.

Centers Have Acted to
Remove Barriers to FaithBased and Community
Organizations, Collect
Data, and Tailor their
Outreach and Assistance
Efforts to Meet the
Agencies’ Needs

Initially, the centers set out to identify and eliminate barriers to the
participation of faith-based and community organizations in federally
funded services. These barriers included regulations, rules, and outreach
activities that either discriminated against or discouraged the participation
of these organizations in federal programs. To identify barriers, the centers
reviewed selected programs and gathered information on program
eligibility and program regulations, among other things. Each center
submitted a report to the White House with its findings, and in August 2001
the White House published the results of the centers’ efforts.19 Specifically,
the report found that the centers identified barriers such as programs that
excluded FBOs from applying for federal funds, confusion on the part of
agency officials and FBOs about the ability of FBOs to consider religion in
employment decisions, complex grant applications and agreements, and
limited accessibility of federal grant information. Each center then issued
equal treatment rules in 2004.20 These rules were intended to help ensure
that faith-based and community organizations could compete on the same
basis as other organizations for federal funds while retaining their

19

The White House. Unlevel Playing Field: Barriers to Participation by Faith-Based and
Community Organizations in Federal Social Service Programs (Washington, D.C., 2001).
20

HUD issued equal treatment rules for eight programs administered by the HUD Office of
Community Planning and Development in 2003; in 2004 HUD issued equal treatment rules
applicable to all HUD programs.

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independence and protecting the rights of beneficiaries of social services.
The adopted rules were largely identical across each agency.
Since 2003 the centers have collected data on, and WHOFBCI has reported
on, funds awarded to FBOs in direct grant programs that allow faith-based
and community organization participation.21 The White House published
the results for all five agencies for fiscal years 2003 through 2005,
characterizing the information as a snapshot of federal grants awarded to
FBOs. For the fiscal year 2005 data collection effort, the centers also
obtained these data from state and local governments administering
formula grants. The centers we reviewed each tracked funding to FBOs for
one formula grant program within their agencies. The White House notes
that because the majority of federal social service dollars are awarded
through formula grants, such a review is critical for understanding the
extent of FBO participation. Center officials noted that they do not have a
standard definition to identify FBOs, leaving each center, some working
with program offices, with the responsibility of identifying FBOs using a
combination of methods. For example, a nonprofit organization that
applies for federal funds may self-identify as a faith-based organization or
a community-based organization as part of a voluntary survey that is
included in grant application packages.22 In cases where an organization
elects not to complete this survey, center officials told us that program
and center staff applied a number of other methods to identify
organizations, including the review of information from grant applications,
information provided by program staff familiar with the organization,
Internet research, or name recognition.
Each center has also assisted in developing pilot programs within its
agency to strengthen the partnership between faith-based and community
organizations and federal agencies. In general, these programs provide
services related to the policy focus of each agency. For example, Labor
has pilot programs to build partnerships between faith-based and
community organizations and the workforce system. Similarly, Education
implemented a program to educate these organizations on how to become
providers of supplemental educational services. Most of Labor’s and HHS’s

21
Center officials told us that they are now collecting data on community-based
organizations. HUD and Justice officials stated that in 2005 they submitted data on
community-based organizations to the WHOFBCI, and Labor officials told us that they
reported this data to WHOFBCI several years ago.
22

OMB No.1890-0014, “Survey on Ensuring Equal Opportunity for Applicants.”

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pilot programs, as well as one of HUD’s two pilot programs, represent new
grant programs that either award funds directly to faith-based and
community organizations or to intermediary organizations that help these
organizations expand their services. In contrast, HUD’s second pilot
program and most of the pilot programs at Education and Justice do not
provide funds directly to faith-based and community organizations or
intermediaries. Education and HUD’s programs provide information and
technical assistance to these organizations to help them access federal
funds or provide services, while Justice’s pilot programs promote the
participation of faith-based and community organizations in areas such as
juvenile offender mentoring and fraud prevention.
In addition, the centers provide outreach and technical assistance
activities to enhance the opportunities of faith-based and community
organizations to compete for federal funding. To inform these
organizations about the resources available to them, the centers engage in
similar outreach activities such as posting grant and funding opportunities
on center Web sites and disseminating information to these organizations
via e-mail. However, the centers adopted different approaches to their
technical assistance training activities. In general, HUD’s and Education’s
centers help organizations learn how to apply for funds, while Labor’s
center helps grantees learn how to manage grants. Justice’s and HHS’s
centers coordinate with program offices that provide these services.
Center officials said their approaches to technical assistance were based
on what they determined would best meet needs within their agency and
fulfill their responsibilities to enhance opportunities for faith-based and
community organizations. For example, HUD’s center—citing the need to
educate faith-based and community organizations on how to access
resources to meet needs in their communities—has conducted a series of
free grant-writing seminars for faith-based and community organizations
since 2004. HUD has also designated staff in each of its regional and field
offices to serve as faith-based and community liaisons and to provide
outreach to these organizations. Education’s center sponsors technical
assistance workshops for faith-based and community organizations that
provide information on the agency’s grant opportunities as well as
information on how organizations can become approved providers of
supplemental educational services.
Labor’s center reported that the large size of Labor’s grant programs was
an obstacle that prevented small grassroots organizations, including those
that are faith-based, from participating in its programs. As a result, Labor’s
center officials said they tailored their outreach and technical assistance
efforts to focus on providing assistance to smaller organizations to build

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their capacity to manage grants and to encourage partnerships between
small grassroots organizations and the workforce system. For example,
the Labor center sponsors technical assistance training for small faithbased and community organization grantees on how to manage grants and
measure program effectiveness, among other things. In contrast to the
centers at HUD, Education, and Labor, the Justice and HHS centers
coordinate efforts with program offices that provide these services.
Among these services are grant-writing seminars provided through the
Substance Abuse and Mental Health Services Administration (SAMHSA) in
HHS and the Office of Juvenile Justice and Delinquency Prevention in
Justice. Center officials at the Justice and HHS centers told us that they
adopted this approach to take advantage of efficiencies from working with
program offices that provided these services prior to the creation of the
centers.
According to center officials, the next phase of the centers’ work will
focus on encouraging the establishment of state and local government
partnerships with faith-based and community organizations, as the
majority of federal social service funds are distributed through formula
grant programs administered at the state and local levels. OMB has
directed each center to help implement an action plan to enhance the
opportunities of faith-based and community organizations competing for
federal funds provided through state and local governments, and to
provide guidance to state and local officials on the equal treatment rules.
The President has also encouraged states to create offices or liaisons to
provide information and resources for faith-based and community
organizations interested in partnering with state and local governments to
provide social services. Thirty-two states have now established state
offices or liaisons for faith-based and community organizations, according
to the White House.

Five Federal Centers
Cumulatively Spent $24
Million since Fiscal Year
2002, but Their Funding
Sources, Staffing Levels,
and Administrative Costs
Varied

The five centers that we reviewed estimated that they cumulatively spent
more than $24 million on administrative activities related to the initiative
since fiscal year 2002, although the level of resources and their application
varied across the five centers. As shown in figure 1, centers in HHS, HUD
and Labor spent between $1 million and $2.3 million annually, while
centers in Education and Justice spent less than $1 million annually. HHS,
HUD and Labor’s centers also had more staff in fiscal year 2005 than
Education and Justice. In fiscal year 2005, HHS, HUD, and Labor had

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between 7 and 9 staff members, while Education and Justice had 5.5 and
3 respectively.23 In Labor, Education, and Justice’s centers, the majority of
the center staff members were appointed rather than career staff.
Figure 1: Estimated Expenditures of Centers for Faith-Based and Community
Initiatives, Fiscal Years 2002 through 2005
Dollars
2,500,000
2,250,000
2,000,000
1,750,000
1,500,000
1,250,000
1,000,000
750,000
500,000
250,000
0
Education

HHS

HUD

Justice

Labor

Total

$2,592,736

$5,679,490

$8,158,577

$1,689,731

$6,735,315

$24,855,849

Fiscal year 2002
Fiscal year 2003
Fiscal year 2004
Fiscal year 2005
Source: GAO analysis of Education, HHS, HUD, Justice and Labor data.

Note: Figures adjusted for inflation. Education’s fiscal year 2002 amount covers the period from May
19, 2002, to September 30, 2002.

In fiscal year 2005, salaries and benefits of center staff members
constituted the largest proportion of the funds spent in four of the
centers,24 ranging from 35 percent to 87 percent of their total

23

Labor’s center had 7 staff members for the first three quarters of fiscal year 2005; it
currently has 6 staff members, according to a Labor center official.

24

Justice could not provide a detailed breakdown of its center’s expenditures.

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expenditures.25 The centers’ remaining expenditures went toward such
administrative costs as rent, contractual services, travel, printing, and
supplies. The centers’ estimated expenditures, however, do not include
other federal initiative-related expenditures, such as the administrative
costs associated with program offices’ efforts to assist faith-based and
community organizations.26 For example, Justice’s Office of Juvenile
Justice and Delinquency Prevention has allocated $1.87 million since fiscal
year 2003 to fund federal grant application training for community-based,
faith-based, and other nonprofit organizations.
Funding for the centers comes from a variety of sources. Education’s
center receives its funding through the Office of the Secretary of
Education and HUD’s center receives its funding through HUD’s salaries
and expenses account, while Justice’s and HHS’s centers are funded
through internal agencies such as the Office of Justice Programs in Justice
and the Administration for Children and Families in HHS. Labor’s center
receives funds from both its agency’s departmental management account
and from program offices. In addition, although not required to, HHS has
included information on funding for its center as part of its congressional
budget requests for several years, while HUD and Labor have included
similar information in past budget requests. These agencies have in turn
received guidance from Congress in the past on the amount of resources
to allocate to their centers. In contrast, Education and Justice have
provided limited or no information on their centers’ funding to Congress
as part of their budget requests. In turn, these agencies have not received
guidance from Congress on the amount of resources to allocate to their
centers.
Differences in staffing levels and administrative costs account for, in part,
the differences in centers’ total expenditures. Staff compensation
represented the largest category of center spending, and the centers with
the largest number of staff spent the most on activities to implement the
initiative.27 Different administrative costs also accounted for some of the

25

See appendix I for a breakdown of estimated expenditures by the centers for fiscal year
2005.

26

Labor’s estimates did include funds expended for center activities done on behalf of
internal agencies.
27

Officials in the five centers we reviewed could not explain how initial staff and resource
allocations were made, as many of them did not work in the centers when they were
established in 2001.

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variation in the center resources. For example, in fiscal year 2005, HHS
spent more on rent, communications, and utilities than HUD’s center,
while centers in Education and Labor did not report any expenses for
these services.28 Centers in HUD and Education spent more in travel
expenses for fiscal year 2005 than the other centers we reviewed. These
higher travel expenses were likely associated with the training and
technical assistance workshops that these centers conducted across the
country for faith-based and community organizations.

Agencies Use Same
Grant Award
Procedures for FaithBased as Other
Organizations, and
Some New Grant
Programs Established
to Encourage More
Faith-Based and
Community
Organization
Participation

Federal and state officials administering the 10 programs we examined
told us that they do not treat FBOs any differently than other organizations
during the grant award process. They use standard criteria to assess all
applications for grant funds, and grant reviewers do not necessarily know
if applicants are FBOs because an organization is not generally required to
identify itself as an FBO when applying for funds. While the grant award
process was similar for all organizations in the competitive programs we
reviewed, since the beginning of the initiative, agencies have awarded over
$500 million through new competitive grant programs to provide training
and technical assistance to faith-based and community organizations and
to increase the participation of these organizations in providing federally
funded social services. In its fiscal year 2007 budget request, the
Administration requested increased funding for some of these programs.

28

HHS spent $310,000 on rent, communications, and utilities in fiscal year 2005; HUD spent
$10,400 in fiscal year 2005 for the same services.

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Faith-Based Organizations
Compete for Funds on the
Same Basis as Other
Organizations

In the funding programs we examined, federal regulations require federal
and state agencies to use the same processes to evaluate grant
applications from FBOs as they do applications from other organizations.29
When rating each application, reviewers for these programs used standard
criteria and assigned numerical scores or other ratings to assess how well
an application addressed the criteria.30 Funding decisions are primarily
determined by these rating scores, although other factors, such as
geographical dispersion, may be taken into account. For example,
selection criteria used to evaluate applications in one program included
factors such as the quality of the project design, quality of project
personnel, and quality of the project evaluation, with points assigned to
each criterion. None of the programs we reviewed awarded points
specifically for faith-based organizations. One of the programs in our
review, Education’s Mentoring Program, awarded five points to “novice”
organizations applying for mentoring funds in 2002. Novice organizations
were defined as ones that had never received a grant from the program
before and had not received a discretionary grant from any federal
program for 5 years.31 (See table 3 for a listing of the programs covered in
our review.)

29

For a discussion of Education’s Office of Innovation and Improvement’s grant award
process, see GAO, Discretionary Grants: Further Tightening of Education’s Procedures
for Making Awards Could Improve Transparency and Accountability, GAO-06-268
(Washington, D.C., Feb. 21, 2006). This review sampled all the grants in Education’s Office
of Innovation and Improvement and found that Education generally adhered to its policies
regarding competitions.
30

One of the programs we reviewed was a contracting program in which federal officials
review applications/bids—for the purposes of our discussion we treat it the same as the
other programs. The competitive process used by Justice’s Bureau of Prisons to award
community corrections contracts involves a selection board whose members rate
proposals submitted by bidders on specific factors; bidders whose proposals receive the
highest scores are awarded contracts. The equal treatment safeguards apply to contracts as
well as direct competitive and formula grant programs.

31

In Education’s 2004 Mentoring Program grant notice, the department announced that five
points would be awarded to a consortium of eligible applicants that included local
educational agencies, community-based organizations, or one private school that qualified
as a nonprofit community-based organization.

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Table 3: Selected Federal Programs Providing Funding to Various Organizations, Including Faith-Based Organizations
Program

Agency

Type of funding

Purpose of program

Mentoring Programs (Safe and
Drug-Free Schools and
Communities National Programs)

Education

Project grants

To promote mentoring programs for children of
greatest need

Community-Based Abstinence
a
Education Program

HHS

Project grants

To provide funding to public and private institutions
for community-based abstinence education project
grants

Mentoring Children of Prisoners
Program

HHS

Project grants

To award grants to organizations, including
community and faith-based entities, to provide
children of incarcerated parents with mentors

Microenterprise Development
Program (Refugee and Entrant
Assistance Discretionary Grants)

HHS

Project grants

To assist refugees in starting or expanding very
small businesses

Abstinence Education Program

HHS

Formula grant program

To enable states to provide abstinence education
and mentoring, counseling, and adult supervision to
promote abstinence from sexual activity

Substance Abuse Prevention and
Treatment Block Grant

HHS

Formula grant program

To provide financial assistance to states and
territories to support projects for the development
and implementation of programs directed at the
prevention and treatment of alcohol and drug abuse

Continuum of Care (set of three
programs: Supportive Housing
Program, Shelter Plus Care, and
Single Room Occupancy)

HUD

Project grants

To address the problems of homelessness in a
comprehensive manner

Emergency Shelter Grants
Program

HUD

Formula grant program

To improve the quality of emergency shelters and
transitional housing for the homeless, to make
additional shelters available, and to provide services
to the homeless

Competitive procurement
program

To provide assistance to inmates who are near
release and provide a structured, supervised
environment and counseling, job placement, and
other services

Project grants

To expand the access of faith-based and
community-based organizations’ clients and
customers to the services offered by local one-stop
centers

Community Corrections Contracting Justice

Small Grassroots Faith-Based and
Community-Based Organizations
Connecting with the One-Stop
Delivery System (Small Grassroots
Program)

Labor

Source: GAO analysis based on agency information.
a

In 2005, the Community-Based Education Program was moved from HHS’s Health Resources and
Services Administration to HHS’s Administration for Children and Families.

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Because applicants in most programs we examined are not required to
identify themselves as FBOs, the grant reviewers do not necessarily know
whether an applicant is an FBO.32 A voluntary survey that may be
submitted with the standard federal grant application asks the applicant,
among other things, to self-identify whether it is a faith-based/religious
organization or whether it is a nonreligious community-based
organization. However, federal officials told us that this survey, if
submitted by the applicant, is removed from the application, and is
unavailable to the reviewers. Nonetheless, an organization’s identity might
be reflected in its name, or the organization might disclose its identity in
its application, for example, when describing the history or mission of the
organization.

New Programs Established
since Initiative to Provide
Training and Technical
Assistance to Faith-Based
and Community
Organizations and Increase
Faith-Based and
Community Organization
Participation

In four of the agencies we reviewed, new programs have been created to
provide training and technical assistance to faith-based and community
organizations and to increase the participation of these organizations in
providing federally funded social services. Some of these programs are the
pilot programs established by the centers and program offices in response
to the initiative. Between fiscal years 2002 and 2005, over $500 million in
competitive grants has been awarded through these programs.33 Some of
these programs, such as Labor’s Prisoner Reentry Initiative, limit eligibility
to faith-based and community organizations, while others, such as HHS’s
Compassion Capital Fund Demonstration Program, fund intermediary
organizations that provide capacity-building assistance to faith-based and
community organizations. (See table 4 for a list and description of these
programs.)

32

The applications for the Continuum of Care programs ask a yes/no question on whether
the applicant is a religious or a religiously affiliated organization.

33

Funds awarded in fiscal year 2006 were not included because several agencies had not
made grant awards for fiscal year 2006 at the time of our review.

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Table 4: New Grant Programs Intended to Encourage Faith-Based and Community Organization Participation in Federally
Funded Social Efforts
Total funds
Start date awarded through Grantee/subgrantee
of program
fiscal year 2005 eligibility

Program

Agency

Access to
a
Recovery

Health and
Human
Services

2004

$198,000,000 States, District of
Columbia, territories,
and tribal organizations

To provide client choice among
substance abuse treatment and
support service providers, expand
access to an array of treatment and
recovery support options, and
increase substance abuse treatment
capacity.

Compassion
Capital Fund
(CCF)
Demonstration
Grantsa

Health and
Human
Services

2002

$125,594,965 Nongovernmental
organizations; Indian
tribal governmental
organizations; nonprofit
agencies, including
faith-based
organizations, public
agencies, state and
local governments,
colleges and
universities, and forprofit entities

To help smaller organizations
manage their programs effectively,
access funding, train staff, expand
programs in their communities, and
replicate promising programs.
Intermediary organizations receiving
CCF grants also provide subawards
to a diverse range of faith-based and
community organizations.

Mentoring
Children of
Prisonersa

Health and
Human
Services

2003

$100,047,432 States, localities,
private, nonprofit,
community and faithbased entities, and
coordinated networks of
such entities

To support the establishment or
expansion and operation of
programs to provide mentoring
services for children of incarcerated
parents.

Compassion
Capital Fund
Targeted
Capacity-Building
Programa

Health and
Human
Services

2003

$22,587,556 Nonprofit, faith-based,
and community
organizations

To increase the capacity of faithbased and community organizations
with a proven track record of serving
the needs of at-risk or low-income
individuals and families.

Ready4Worka

Labor/Justice

2003

$21,700,000 Public/Private Ventures
(non-profit organization)
provides subgrants to
lead agencies at
18 sites

To assist faith-based and community
programs that provide mentoring
and other transition services for men
and women returning from prison.

Prisoner Reentry
a
Initiative

Labor/Justice/
b
HUD

2005

$19,840,000 Faith-based and
community
organizations

To reduce recidivism and reincarceration by helping inmates find
work when they return to their
communities.

2002

$11,874,147 States

To increase the number of faithbased and community-based
organizations serving as committed
and active partners in the One-Stop
delivery system.

Grants for States Labor
for FBO/
Community-Based
Organization
Partnerships

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GAO-06-616 Faith-Based and Community Initiative

Program

Agency

Total funds
Start date awarded through Grantee/subgrantee
of program
fiscal year 2005 eligibility

Grant purpose

Grants for
Labor
Workforce
Investment Boards
for FBO/
Community-Based
Organization
Partnershipsa

2004

$10,706,389 Workforce Investment
Boards

To encourage the formation of longterm partnerships with faith-based
and community organizations that
meet community needs related to
hard-to-serve populations.

Grants for
Intermediaries for
FBO/CommunityBased
Organization
Partnerships

Labor

2002

$9,661,191 Nonprofit, community,
or faith-based
organizations with
connections to faithbased and community
grassroots
organizations

To increase the number of faithbased and community-based
organizations serving as committed
and active partners in the One-Stop
delivery system.

Helping Outreach
Programs Expand
(HOPE)

Justice

2002

$3,675,000 Faith-based and
community
organizations

To foster the development of
grassroots crime victim service
providers to expand both public
visibility and outreach to victims,
thereby increasing the number of
available service providers.

Faith and
Justice
Community-Based
Juvenile
Delinquency
Treatment
Initiativea

2003

$3,500,000 One grant awarded to
Florida Department of
Juvenile Justice

To establish a multifaceted faithbased initiative to provide positive,
caring adult relationships, and
greater supervision and moral
leadership as youthful offenders
transition back into their
communities.

Small Grassroots Labor
Faith-Based and
Community-Based
Organizations
Connecting with
the One-Stop
Delivery System
(Small Grassroots
Program) a

2002

$3,408,981 Local nonprofit social
service organizations
with $350,000 or less in
annual revenues or
fewer than six
employees

To provide workforce services to
specific populations or provide
particular services not currently
provided through the One-Stop
delivery system; expand the access
of faith-based and community-based
organizations’ clients and customers
to the services offered by the local
One-Stops; and establish methods
and mechanisms to ensure
sustainability of these partnerships.

Helping Outreach
Programs to
Expand II (HOPE
II)

2005

$3,000,000 Faith-based and other
community
organizations that will
provide subgrants to
grassroots, faith-based,
and community
organizations to serve
crime victims while also
building their capacity.

To increase the development and
capacity of faith-based or
community-based organizations to
respond to underserved victims in
high-crime urban areas.

Justice

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Program

Agency

Total funds
Start date awarded through Grantee/subgrantee
of program
fiscal year 2005 eligibility

Grant purpose

Rural Domestic
Justice
Violence and Child
Victimization
Enforcement
Grant Program
Special Initiative:
Faith-based and
Community
Organization Pilot
Programa

2005

$1,024,965 Community
organizations (nonprofit,
private entities) of rural
states and faith-based
organizations of rural
states (nonprofit, private
entities). Private entities
of nonrural states that
are members of or
central offices of
national organizations
may consider applying
through an affiliated
organization located
within a rural state.c

To increase the level of services
available to rural victims of domestic
violence by increasing the number of
first-time, grassroots faith—and/or
community-based organizations
receiving Office of Violence Against
Women funding and technical
assistance in rural America.

Enhancement of
HUD
Public Housing
HOPE VI
Communities
through Mentoring
Demonstration
a
Program

2005

$524,578 Public housing
authorities with HOPE
VI Revitalization grants
will partner with
grassroots, faith-based
and other communitybased organizations.

To determine if providing mentoring
services to residents already
participating in self-sufficiency
programs increases their likelihood
of achieving self-sufficiency.

Clergy Against
Justice
Senior Exploitation
a
(CASE)

2002

$273,614 One grant awarded to
Denver, Colorado,
district attorney’s office

To partner with faith communities in
addressing the issue of elder fraud
in Denver County.

Source: GAO analysis based on information on the White House Office of Faith-based and Community Initiatives Website and agency
documents.

Note: This table does not include programs that provide only technical assistance and not grant funds
to faith-based and community organizations, such as Education’s Supplemental Educational Services
and HUD’s Grant Writing Training program.
a

Denotes a pilot program identified as such by Centers for Faith-Based and Community Initiatives
staff.

b

As of April 2006, Justice and HUD had not disbursed any funding under the initiative.

c

Grantees act as intermediaries and offer subgrants and technical assistance to small, faith-based or
community organizations with less than 10 full-time employees, an annual domestic violence budget
less than $100,000, and an overall annual operating budget less than $350,000.

The President proposes $323 million in funds in his 2007 budget
submission—a 36 percent increase from what was enacted in fiscal year
2006—for five programs in order to foster faith-based and community
organization participation.34 The President’s budget proposes an increase

34

Compassion Capital Fund, Access to Recovery, Mentoring Children of Prisoners, Prisoner
Reentry Initiative, and the President’s HIV/AIDs Initative.

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in funding for the Compassion Capital Fund from $64 million to
$100 million and the Prisoner Re-entry Initiative funding from $26 million
to $60 million. In an effort to encourage more participation by faith-based
and community organizations in combating the spread of HIV and AIDS,
the President proposed new funding for an outreach program to the
African-American community.

Government Agencies
Generally Provide
Grantees with
Information on
Safeguards, but Most
Do Not Have
Procedures in Their
Monitoring Guidelines
for Assessing
Compliance

Most of the 10 federal program offices that we reviewed included an
explicit statement in their grant documents explaining that FBOs cannot
use direct federal funds for inherently religious activities 35 However, less
than half of program offices provided a similar statement explaining that
organizations may not discriminate against beneficiaries based on religion
or explaining the permissible hiring practices for FBOs. Most of the grant
documents related to these two safeguards provided only a reference to
federal or program regulations, and a few program offices provided no
information on the nondiscrimination and hiring safeguards. In general,
state and county offices in the four states we visited provided information
on the safeguards to their formula grant awardees, although in several
cases they provided incorrect information on whether FBOs may make
hiring decisions on the basis of religion. While officials in all 26 of the
FBOs that we visited told us that they understood that federal funds could
not be used for inherently religious activities, officials at several
organizations appeared to have misunderstood the safeguard that religious
activities may only be conducted at a separate time or in a separate
location from federally funded services. Few government agencies
administering the programs we reviewed monitor organizations to ensure
compliance with these safeguards, and the single audit, which is used to
monitor organizations receiving a certain level of federal funding,
generally does not include checks for these safeguards.

35

We reviewed a program’s latest grant announcement and grant application for references
to the safeguards on inherently religious activities, nondiscrimination of program
beneficiaries, and FBOs’ permissible hiring practices. We also requested from agency
officials any additional guidance that they provided to applicants or grantees related to the
use of grant dollars.

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Most of the Federal
Programs We Reviewed
Provided Grantees with a
Statement on
Nonallowable Activities,
but Fewer Provided
Information on Other
Safeguards

Seven of the 10 programs that we reviewed provided grantees with an
explicit statement in one or more of their grant documents that federal
funds for that program could not be expended for “inherently religious
activities.” Most statements noted that organizations receiving direct
federal funds cannot engage in inherently religious activities, such as
worship, religious instruction, or proselytization as part of program
services directly funded with federal funds. For example, Labor sent state
workforce agencies a guidance letter in July 2005 reiterating its equal
treatment rules and directing the agencies to develop policies and
procedures to implement the safeguards. HUD also issued a memorandum
to state agencies reiterating its equal treatment rules pertaining to
Emergency Shelter program grantees. Table 5 summarizes the extent to
which information on each of the safeguards was included in programs’
grant documents.

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Table 5: Extent to Which Safeguards Are Included in Program Grant Documents

Safeguards stated In federal
a
documents to grantee

Prohibition on inherently religious
activities unless separate in time Prohibition on
or location from federally funded discrimination against
programs or services
clients based on religion

Provision explaining
permissible hiring by
FBOs

Agency/program
Federal Project and Contract Grants
Education/Mentoring Programs

●

●

●

HHS/Community- Based Abstinence
b
Education Program

■

●

●

HHS/Mentoring Children Of Prisoners

■

●

●

HHS/Microenterprise Development
Program

■

□

□

HUD/Continuum of Care Programc

■

■

■

d

●

●

■

■

■

HHS/Abstinence Education Program

■

■

□

HHS/Substance Abuse Prevention and
Treatment Block Grant Program

●

●

●

HUD/Emergency Shelter Grants

■

■

■

Justice/Community Corrections
Contracting
Labor/Small Grassroots Program
Formula Grants

Key: document
■ = provides statement in one or more of the following documents: grant application, announcement,
or guidance documents
● = cites regulations
□ = makes no reference to these safeguards
Source: GAO analysis based on review of agency documents.
a

Documents include grant announcements, applications, award letters, and any additional guidance
sent to grantees.

b

Safeguards were stated more clearly in HHS’s Health Resources and Services Administration’s 2003
and 2004 applications, which included an advisory memo and a questions and answers section.
Advisory and question section was not included in HHS’s Administration for Children and Families’
2006 application package. However, the program’s application and grant award letter include a
reference to the prohibition on inherently religious activities.

c

HUD’s notice to agency and field office directors providing guidance to Continuum of Care grantees
covered by HUD’s 2003 equal treatment regulations expired September 2005.
d

Justice officials told us that this safeguard does not apply to Community Correction Contracting
programs and therefore the agency did not include it in the program’s contract documents. See
discussion below.

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We found no reference to the prohibition on inherently religious activities
in Justice’s Community Corrections Contracting program.36 Justice
officials advised us that, under their equal treatment regulations, they
believe that FBOs providing services in Community Corrections Centers
(also referred to as halfway houses that allow inmates to leave the centers
for religious services) are exempt from the prohibition related to
inherently religious activities and therefore the agency does not include
any reference to the prohibition in the contract documents for this
program. The regulations provide that the restrictions on inherently
religious activities do not apply where funds are provided to chaplains or
organizations assisting chaplains in certain settings such as community
correction centers.37 According to these officials, given the duty to
accommodate inmates’ rights to religious exercise, all FBOs providing
services are essentially viewed as “assisting chaplains” and fall within the
exception. Accordingly, Justice officials believe it is appropriate not to
include any reference to the restriction on inherently religious activities in
the contract documents for community correction centers.
We believe that the failure by Justice to include any reference to this
restriction could create uncertainty for FBOs. For example, the omission
could be read as allowing all providers of social services in these settings
to engage in worship, religious instruction, or proselytization, regardless
of whether the services assist chaplains or whether the religious activities
are voluntary on the part of the participant. In other words, the scope of
the exception for assisting chaplains is left uncertain and FBO program
staff may not understand whether, to what extent, or under what
circumstances, they may engage in religious activities using federal funds.
As table 5 shows, 4 of the 10 programs that we reviewed included an
explicit statement in grant documents that grantees must not discriminate
against beneficiaries on the basis of their religion. In contrast, most of the
other programs refer applicants and grantees to either their agency’s equal
treatment regulations or program regulations that contain this safeguard.
For example, HHS’s Community-Based Abstinence Education program

36
Community Corrections Contracting includes both Community Corrections Centers and
Comprehensive Sanctions Centers. Bureau of Prison officials told us that while the
Comprehensive Sanctions Centers have a more structured system for granting inmates
access to the community, the process of contracting for and monitoring of these two
programs is the same. Our interviews with FBOs included one that operated a Community
Corrections Center and another that operated a Comprehensive Sanctions Center.
37

See 28 C.F.R. 38.1(b)(2).

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refers the applicant to the agency’s equal treatment regulations,and
SAMHSA’s Substance Abuse Prevention and Treatment Block Grant
Program refers states to its charitable choice regulations. The Mentoring
Children of Prisoners Program added a reference to HHS’s equal treatment
regulation in its June 2006 announcement. However, we found that in
some instances, the cited regulations contained out-of-date information on
this safeguard. For example, HHS’s Mentoring Children of Prisoners and
Microenterprise Development Programs’ Standard Terms and Conditions
(attached to the grant award) cited a Web address for 2003 regulations that
did not contain the equal treatment safeguards.
Programs provided the least information on whether FBOs are permitted
to make hiring decisions based on religion. Of the 10 federal program
offices that we reviewed, only 3 provided information in grant documents
about religious organizations’ hiring of employees that share their religious
beliefs. Five other programs referred applicants or grantees to the equal
treatment regulations, and 2 provided no reference to FBO hiring in their
grant documents. In addition, Justice’s contract for its Community
Correction Centers contains a reference to a clause that cites an executive
order that does not apply to FBO contractors and thus provides incorrect
information on FBO hiring.38 The one program in our review—Labor’s
Small Grassroots Program—that is governed by statutory language
prohibiting FBOs from making employment decisions on religious
grounds, includes information in its program grant documents explaining
the prohibition.39
The 7 competitive project and procurement grant programs differed with
respect to whether they provided any training for new grantees on the
safeguards. Five program offices provided training to grantees that
included a discussion of the safeguards, while two did not. Officials from
2 of the formula grant programs in our review explained how some state
officials received training on the safeguards. An HHS official with the
Abstinence Education formula grant program told us that state officials
attended the February 2006 conference offered to new grantees for the

38
Executive Order 13279 amends section 202 of Executive Order 11246 so that the
prohibition on religious hiring does not pertain to a government contractor or
subcontractor that is, among other entities, a religious corporation.

39

Labor’s Small Grassroots Program is governed by statutory language prohibiting FBOs
from making employment decisions on religious grounds for positions that administer or
are connected with the program or activities that receive Workforce Investment Act
assistance.

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Community-Based Abstinence program and were given the opportunity to
attend breakout sessions that focus on compliance with the equal
treatment safeguards. SAMHSA officials told us that they hold sessions
during the semiannual conference that directly discuss charitable choice
regulations. Applicants and grantees interested in learning about the
safeguards could also obtain access information on an agency’s Center for
Faith-Based and Community Initiatives Web sites.

State and County Agencies
Provide Grantees
Information on Allowable
Activities and
Nondiscrimination of
Clients, but Several
Provided Grantees with
Incorrect Information on
FBO Hiring

For the three formula grant programs we reviewed, the grant program
documents that state and county agencies provide to applicants and
grantees contain information on allowable activities and
nondiscrimination of beneficiaries and, in general, provide more explicit
information on these two safeguards than the federal agencies. In addition,
like federal program offices, state and county program offices in the four
states we visited provided little information on FBO hiring, or in several
cases, provided incorrect information. For example, we found that state
and county offices in two states that administer the Substance Abuse
Prevention and Treatment Block Grant and Abstinence Education
program provided documents to grantees that included incorrect
information on whether FBOs could hire based on religion. In one case,
county officials acknowledged that they provided documents that
contradicted one another on FBO hiring. They explained that one
provision of their state contract says that organizations cannot
discriminate in hiring, while another provision cites charitable choice
hiring rules.

Some FBOs We Visited Did
Not Appear to Understand
the Requirement for
Separation in Time or
Location for Religious
Activities and the
Safeguard Pertaining to
Hiring by Religious
Organizations

Four of the 13 FBOs that we visited that provided voluntary religious
activities for beneficiaries did not appear to adhere to the requirement to
separate in time or location religious activities from program services
funded with direct federal funds. In addition, 13 of the 26 did not
understand the safeguard that pertained to permissible hiring on the basis
of religion. On the basis of our discussions with FBO officials, we did not
find any indications that FBOs did not serve a beneficiary based on a
beneficiary’s religious beliefs.
While officials in all 26 FBOs that we visited told us that they understood
the prohibition on providing inherently religious activities with direct
federal funds, 4 described engaging in activities that appear not to be
permissible with federal funds under the equal treatment rules. For
example, officials from 2 of these FBOs told us that that they would pray
with beneficiaries at the beneficiary’s request. While voluntary prayer is

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permissible as long as it is offered separately in time or location from
program activities conducted with direct federal funds, these officials
indicated that they conducted prayer at the same time and location as
their federally funded services.40 In addition, an official from another FBO
said that he began each program session, which provided services to
children, with a nonsectarian prayer that at times included a brief reading
from the Bible. Finally, one FBO program manager told us that she
discussed religious issues during the same time and at the same location
as federally funded services if requested by a participant and no other
participants objected.
One program office has taken action to better define the separate in time
or location requirement. Included as part of the settlement of a lawsuit
that arose from the agency’s funding of a faith-based sexual abstinence
education program was a set of “Safeguards Required” drafted by HHS’s
Community-Based Abstinence Education Program office for the grantee.
This document was intended to provide guidance to the grantee for
operation of the program in compliance with existing law and regulations,
and included a detailed explanation of ways in which the grantee’s
activities might be separated in time or location. As of March 2006, HHS
was considering providing similar information to all grantees to more
clearly delineate how an organization could separate its religious activities
from those provided with federal funds, according to the abstinence
education program director.
Some FBOs are also confused about the safeguard related to hiring by
religious organizations. Only half of the 26 FBOs that we visited correctly
understood whether they could take religion into account when hiring
staff. In general, FBOs that were prohibited by program legislation or state
law from considering religion when making employment decisions
understood the hiring safeguard. For example, 8 of the 9 FBOs that we
visited in Ohio understood that the state had a statute that prohibits
discrimination in employment based on religion.41 In addition, Labor’s
Small Grassroots Program is governed by statutory language that prohibits

40
The preambles to most agencies’ published equal treatment regulations note that while
the Supreme Court has not comprehensively defined inherently religious activities, the
Court considers prayer and worship to be inherently religious. See, for example, the
Department of Justice’s final rule at 69 Fed. Reg. 2832, 2834.
41

See Ohio Rev. Code Ann. sec. 4112.02 (2006). The Ohio statute does not specifically
include an exemption for religious organizations.

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organizations from hiring based on religion. Program officials with 3 FBOs
that had received funding from this program told us that they do not hire
based on religion, and 2 of the 3 noted that the hiring safeguard was
discussed during Labor’s grantee training. Most of the 13 FBOs that did not
correctly understand the hiring safeguard were unaware that they could
consider religion when making employment decisions.

Program Offices Are Not
Required to Monitor FBO
Grantees Differently than
Other Grantees, and Few
Program Offices in our
Review Include References
in their Monitoring
Guidelines on Compliance
With Safeguards

Federal and state program offices are not required under federal
requirements to monitor FBO grantees any differently than secular
organizations, and in our review, few program offices use monitoring tools
that include checks for compliance with these safeguards. Federal
agencies monitor grantees for compliance with program regulations
primarily through such monitoring activities as desk audits, site visits, and
single audit compliance reviews. However, many faith-based and
community organizations may not be covered by the single audit because
they do not expend $500,000 or more in federal funds in a given year.
Further, for those FBOs that do meet this financial threshold, single audit
guidelines do not generally instruct auditors to check for compliance with
the equal treatment safeguards.

Program Offices Monitor
Grantees Primarily through
Desk Audits and Site Visits

Federal program offices monitor grantees by reviewing financial reports
(standard reports that collect data on grantee disbursements) and
performance reports that grantees submit. Program officials told us that
they review these reports to identify any financial or programmatic issues
that may require them to do additional follow-up with the grantees.
Performance reports focus on programmatic issues and collect
information on the number of beneficiaries served and program outputs.
None of the reports that we reviewed contained any questions related to
compliance with the safeguards.
Program offices also monitor grantees for compliance with program rules
through site visits. Many federal officials told us that they use a risk-based
approach when determining which sites to visit. Several program officials
told us that they do not single out FBOs for site visits and do not consider
them at higher risk for noncompliance than other organizations. Grantees
often selected for visits include ones that receive high dollar grants, novice
grantees, grantees that have had prior problems, and grantees with high
staff turnover. Program officials typically use written monitoring
guidelines or site visit protocols when conducting site visits.
We found that only 2 of the 7 federal direct programs had monitoring
guidelines that contained any reference to the equal treatment safeguards,

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and one program—established in 2002—had not yet developed a
monitoring tool. HHS’s Community-Based Abstinence Education Program
recently developed a monitoring tool that includes a question on whether
the project is being implemented “in a manner consistent with all other
Federal requirements (e.g., faith-based issues, civil rights, etc.)” and
whether the grantee is “aware of the regulations regarding the use of
federal funding for inherently religious activities.” Similarly, Labor’s
monitoring handbook contains a general reference to avoiding client
discrimination, but does not include a discussion of compliance with the
safeguards. An HHS Mentoring Children of Prisoners program official told
us that the program office had not yet developed a monitoring tool for its
mentoring program.
The number of site visits conducted by program offices varied widely.
Officials noted that the number of grantees in a given program affects how
frequently their staff can conduct site visits. A Labor official in a field
office told us that Labor officials try to visit all Small Grassroots Program
grantees at least once during the span of the grant. HUD officials noted
that visiting 10 percent of all grantees annually amounted to about 600
visits in 2004, and an Education official noted that visiting 5 percent of
grantees had become increasingly difficult as the number of grantees grew
each year. Since its move to HHS’s Administration for Children and
Families from the agency’s Health Resources and Services Administration
in 2005, the Community-based Abstinence Education program has
conducted two site visits. The program’s director said he hopes his office
will complete around 20 in 2006, but that he would like to visit all grantees
at least once during their 3-year grant period.42
State and county agencies are responsible for monitoring grantees of
federal formula grants. Similar to federal agencies, state and county
officials in the four states we visited conduct desk audits of grantees and
conduct site visits to a limited number of organizations. Many use risk
assessment to determine which grantees to visit while others attempt to
visit all grantees within a certain time frame. Only 5 of the 13 state or
county program offices we visited included a reference to the prohibition
on using direct federal funds for inherently religious activities or services.
Georgia’s monitoring tool for its Emergency Shelter Grants program states
that housing and services are to be provided in a “manner that is free from

42

According to Health Resources and Services Administration officials, their office did not
conduct any site visits during the 4 years they administered the program.

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religious influence,” and its abstinence education performance and
outcome scorecard has a space for organizations to indicate that their
“curriculum does not teach or promote religion.” Similarly, Texas’
abstinence education on-site evaluation report includes as one of its
review criteria a check to ensure that direct federal funds are not used for
sectarian worship, instruction, or proselytization. In addition, the
monitoring manual for Sacramento County, California, includes a check to
ensure that grantees include in their program policies and procedures
information on the requirement that FBOs certify that they will comply
with all the requirements of SAMHSA’s charitable choice provisions and
implementing regulations.

Single Audits Are Also Used to
Monitor Grantees, but
Guidelines Do Not Consistently
Reference Safeguards

Program offices also use the single audit to monitor recipients that expend
$500,000 or more in federal funds in a fiscal year. OMB provides specific
audit guidelines for some programs. While three programs we reviewed—
the Substance Abuse Prevention and Treatment Block Grant Program,
Emergency Shelter Grants, and the Continuum of Care Supportive
Housing Program—have program-specific guidance, they varied on
whether and how they included information on the equal treatment
regulations.43 For example, single audit guidance for the Substance Abuse
Prevention and Treatment Block Grant Program provided the auditor with
audit steps related to the equal treatment provision prohibiting
organizations from expending direct federal funds on inherently religious
activities, while Emergency Shelter Grant guidance refers the auditor to
the program regulations that discuss what faith-based organizations can
and cannot do with direct federal funds. In contrast, the single audit
guidance on HUD’s Supportive Housing Program contains no reference to
the prohibition on using direct federal funds for inherently religious
activities.
The other 7 programs we reviewed do not have OMB program-specific
audit guidelines. OMB’s single audit guidelines used for programs that do
not have program-specific guidelines also contain no reference to the
prohibition on using direct federal funds for inherently religious activities.
Instead, OMB’s general guidelines direct auditors to refer to grant
documents or laws and regulations to determine which activities are

43
We also reviewed all the programs cited in the White House Faith-Based and Community
Initiatives Report Grants to Faith-Based Organizations FY 2004 to ascertain how many of
these programs had program-specific single-audit compliance guidelines. Out of the
81 programs that are administered by the five agencies in our review, we found that 12 had
program-specific guidelines.

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allowed or unallowed with federal funds. We interviewed three
independent auditors, who told us that unless these safeguards were
referenced in the single audit guidelines or included in grant documents—
which typically outline the key provisions of the grant—an auditor would
not likely test for compliance with these provisions. Two auditors we
interviewed noted that they did not check for the safeguards because the
safeguards were not referenced in the single audit guidelines for HUD’s
Continuum of Care and, at that time, SAMHSA’s Substance Abuse
Prevention and Treatment Block Grant Program, the two programs
administered by the FBOs they audited. The other auditor, who had
recently audited an FBO that had received an Abstinence Education grant,
told us that he had developed his own audit plan by reviewing the grant
application package. He explained that because he readily found a
reference in the application to the prohibition on providing inherently
religious activities, he was able to discuss with the program manager how
this issue was conveyed to program staff and reviewed written feedback
from the students to ascertain whether any religious discussions had
occurred while staff were providing federally funded services.44

44

The auditor did not find any indication that the FBO had violated the prohibition on
inherently religious activities.

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OMB and WHOFBCI
Assess Agencies’
Progress in
Implementing
Initiative, but Data
Limitations and a
Lack of Information
May Hinder Ability to
Measure Progress
toward Achieving
Initiative’s Long-Term
Goals

OMB and the White House Office of Faith-Based and Community
Initiatives (WHOFBCI) assess agencies’ progress in implementing the
initiative and highlight this progress through a number of published
vehicles.45 However, the federal government’s efforts to assess the
initiative’s progress in achieving its long-term goal of greater participation
may be hindered by the accuracy of data collected on the number of FBOs
receiving federal grants because the government has not established
consistently applied criteria for what constitutes a faith-based organization
and has not required organizations to self-identify as such. Moreover, little
information is available to assess agencies’ progress toward the long-term
goal of improving participant outcomes because outcome-based
evaluations for most pilot programs have not yet been completed. In
addition, OMB faces other challenges in measuring and reporting on
agencies’ progress in meeting the two long-term goals of the initiative.

OMB and WHOFBCI Grade
Agencies’ Progress in
Implementing the Initiative
by Assessing Their
Progress on Several
Activities

Through the President’s Management Agenda (PMA) issued in 2001, OMB
identified expected short-term, intermediate, and long-term results or
goals for the initiative.46 OMB and WHOFBCI assess and track agencies’
implementation of the initiative by using the Executive Branch
Management Scorecard, a traffic-light system showing agencies’ grades on
their efforts to carry out activities in accordance with the initiative’s
Standards for Success. Developed in 2003, the initiative’s Standards for
Success describe expectations on the progress agencies are making in
implementing certain responsibilities for the initiative, such as collecting
accurate data on the participation of faith-based and community
organizations and conducting outcome-based evaluations of pilot
programs. Center officials at the agencies that we reviewed told us that
they are focusing their efforts on implementing the standards for success
and achieving the short-term goals of the initiative. Specifically, they are
working on “leveling the playing field” for faith-based and community

45

In May 2006, OMB published on its Web site the Standards for Success used to gauge the
progress agencies are making in implementing the initiative.
46

Through the PMA, OMB has emphasized improving government performance through five
governmentwide goals and a number of agency-specific initiatives, one of which is the
Faith-Based and Community Initiative.

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organizations to compete for federal funds. Table 6 specifies OMB’s green
and yellow standards for success for the initiative, and appendix III lists
the best practices that are referenced in the Standards for Success.
Table 6: OMB’s Green and Yellow Standards for Success for Executive Agencies with Centers for the Faith-Based and
Community Initiative
GREEN Standards for Success
Agency:
1. Has implemented a comprehensive outreach and technical assistance strategy for enhancing opportunities of faith-based and
community organizations (FBCO) to compete for federal funding, including working with state and local officials to expand access to
Federal funding awarded through them. This strategy employs 12 of 15 best practices;
2. Regularly monitors compliance with the equal treatment regulations at the State and local levels, promptly addresses violations
once they are detected, and has a process in place to ensure that compliance information is used to inform future funding.
Compliance monitoring activities include 10 of 13 best practices;a
3. Collects accurate and timely data on participation of FBCO and other applicants, including government entities, in selected Federal
non-formula grant programs and has taken steps to expand data collection efforts to formula grant programs and make them a
routine part of program administration. Programs are working to make this information accessible to the public;
4. Implements pilot programs to strengthen the partnership between FBCO and the Federal government to deliver services and inform
implementation of the Initiative, and expands the use of pilots to test new strategies when appropriate; AND
5. Undertakes outcome-based evaluations of its pilot programs where FBCO participate, provides quarterly progress reports and
interim results to the WHOFBCI throughout the life of the program, and builds an evaluation component into new pilots.
Incorporated FBCO component into broader program evaluations when appropriate.
YELLOW Standards for Success
1. Has developed a comprehensive outreach and technical assistance strategy for enhancing opportunities of faith-based and
community organizations (FBCO) to compete for federal funding, including working with state and local officials to expand access to
Federal funding awarded through them, and has begun to implement the plan. This strategy employs 8 of 15 best practices;
2. Has taken steps to ensure barrier free access for FBCO to the Federal competitive grants process. These steps include 7 of
15 best practices;
3. Has established procedures to collect data on participation of FBCO in selected Federal programs;
4. Has implemented pilot programs to strengthen the partnership between FBCO and the Federal government to deliver services;
AND
5. Has undertaken outcome-based evaluations of its first set of pilot programs and has provided progress reports to WHOFBCI.
Source: OMB.
a

For compliance monitoring activities, only 3 of the best practices pertain to monitoring whereas the
other 10 best practices involve activities to inform faith-based and community organizations, state and
local officials, and others about the regulations.

OMB and WHOFBCI grade agencies both on current status and on
progress in implementation. OMB and WHOFBCI award an agency with a
green status if it meets all of the yellow and green standards for success,
yellow if it has achieved the yellow but not all of the green standards for
success, and red if the agency fails to meet any one of the yellow
standards. OMB and WHOFBCI assess each agency’s progress on a

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quarterly basis, and according to OMB officials, they use this performance
information to identify problems and to develop corrective actions.
Of the five agencies that we reviewed, three agencies have a green status
(Education, Justice, and HUD), and two have a yellow status (Labor and
HHS) for current status during the first 2006 rating quarter. These agencies
received a green status for progress in implementation for the rating
quarter except HUD, which was downgraded to a yellow status from the
previous rating quarter. OMB and agencies publish these summary scores
in a number of places, such as in OMB and agency budget and
performance documents as well as on their respective Web sites.
According to OMB and some center officials, OMB negotiates with the
agencies on a quarterly basis to set milestones that agencies must meet to
maintain their green status.
The OMB Web site contains the Standards for Success for achieving the
PMA’s five governmentwide goals,47 as well as the standards for the
initiative. It lists the agencies that have performed best in meeting the
individual standards for success (i.e., getting to green) for the goals.

Efforts to Measure
Agencies’ Progress toward
Achieving Initiative’s Longterm Goals Is Hindered by
Data Limitations and Lack
of Information

Although OMB’s scorecard highlights agency progress in implementing the
initiative, there are difficulties in assessing progress towards the two longterm goals for the initiative specified in the PMA. Efforts to assess the
progress in achieving the initiative’s long-term goal of increasing
participation of faith-based and community organizations is hindered in
part by difficulties agencies encounter in attempting to determine whether
or not an organization is faith-based. Further, assessing achievement
toward the other long-term goal of improving participant outcomes is
hindered because agencies have not completed most of the OMB-required
outcome-based evaluations of their pilot programs. In addition to the
issues already noted, OMB and the WHOFBCI face other challenges in
measuring and reporting on agencies’ progress in meeting the broad longterm goals of “greater participation of faith-based and community
organizations” and “improved participant outcomes.”

47
The five governmentwide goals under the PMA are (1) strategic management of human
capital, (2) competitive sourcing, (3) improved financial performance, (4) expanded
electronic government, and (5) budget and performance integration.

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Data Issues Affect Efforts to
Measure Progress of Agencies
in Meeting Long-Term Goals

As set forth in the PMA, one of the long-term goals of the initiative is for
federal agencies to facilitate greater participation of faith-based and
community organizations in providing federally funded social services.
Although the Administration has not defined a “faith-based and community
organization” or a “faith-based organization,” it directs the centers for
faith-based and community initiatives to collect data on federal grants
awarded to FBOs and community-based organizations. The WHOFBCI has
published data on FBOs for all five agencies for fiscal years 2003-2005. In
March 2006, the WHOFBCI reported that in fiscal year 2005 the federal
government awarded, through seven federal agencies, more than
$2.1 billion in competitive social service grants to FBOs—an increase of
7 percent over the previous year. The WHOFBCI also reported that
between fiscal years 2003 and 2005, grants to FBOs increased by 38
percent and funding increased by 21 percent.
The WHOFBCI’s report states that federal agencies make good-faith
efforts to collect accurate data on grants awarded to FBOs, and we also
found that agencies are making significant efforts to collect this data.
However, they face constraints in collecting accurate data. Specifically,
the government has not established criteria for what constitutes a faithbased organization that all federal agencies must use, and federal agencies
do not require organizations to self-identify as faith-based. Although no
method can ensure that all data collected are accurate, having consistently
applied criteria or requiring self-identification would provide greater
assurance that agencies are collecting accurate data than the current
method.48 In addition, the WHOFBCI has not reported on grants awarded
to community-based organizations. Consequently, it is unclear whether the
reported data provide policymakers with a sound basis to assess the
progress of agencies in meeting the initiative’s long-term goal of increasing
participation of faith-based and community organizations.
As we’ve previously reported, a long-standing challenge for the federal
government has been producing credible data on outcomes achieved
through federal programs. Policymakers need credible data to make
resource allocation decisions on what programs to fund. Concerns about

48

Accuracy includes both validity and reliability. Validity means that we are measuring what
we think we are measuring. Reliability is the likelihood that a measurement procedure will
obtain the same results if repeated. Thus, reliable data would largely be free from random
error components. Without a single clear definition, there is the risk that individuals are
using different definitions inconsistently to identify different organizations. Therefore, the
FBO data may not be valid or reliable.

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the accuracy of the data collected on FBOs have previously been raised by
others. For example, during a June 2005 House hearing on the centers for
faith-based and community initiatives, two former officials from the
WHOFBCI and a former HHS center director questioned the accuracy of
the data.49 In short, they questioned the methods used to collect data on
which organizations are faith-based and the credibility of the reported
data.
In 2001, the Administration noted that a lack of a standard definition for
what constitutes a faith-based organization was an obstacle to federal
agencies in determining how much federal funding FBOs receive.50
Without using consistently applied criteria across federal agencies or
requiring organizations to self-identify, each center is responsible for
determining which grantees in selected programs are faith-based. One
vehicle the centers use for identifying FBOs is a voluntary survey that is
sent to all grant applicants and which asks, among other questions,
whether the applicant is a “faith-based/religious” organization. However,
the extent to which applicants return the survey varies across the centers,
and several center officials reported that the response rate for this survey
has been low.
In cases in which applicants do not complete the voluntary survey,
agencies rely on other methods of identification, such as administrative
reports, Web sites, and phone inquiries by center and program staff.
Moreover, a variety of agency staff collects this data without consistently
applied criteria. Some agencies rely on center officials to collect this data,
while others rely on either program staff or contractors. For example, one
center official said that because there is no established definition of an
FBO, officials are careful not to direct the program office staff on what
characteristics to look for when identifying these organizations. Such
methods involve considerable work on the part of program and center
officials and, in some cases, discretion in determining which organizations
are faith-based. Another document that collects information on
organizations’ characteristics is OMB’s mandatory application for federal

49

For a discussion of congressional oversight of the Faith-Based and Community Initiative
and data issues, see H.R. 1054 Authorizing Presidential Vision: Making Permanent the
Efforts of the Faith-Based and Community Initiative, hearing before the House
Committee on Government Reform, Subcommittee on Criminal Justice, Drug Policy, and
Human Resources, 109th Cong. (June 21, 2005).
50

White House (2001). Unlevel Playing Field: Barriers to Participation by Faith-Based
and Community Organizations in Federal Social Service Programs. Washington, D.C.

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financial assistance that all applicants must complete. Although the
application instructs applicants to identify themselves from a list of
organizational categories, no category for faith-based organization is
included.51
Some center officials told us that they believed that many FBOs may be
reluctant to identify themselves as such on the voluntary survey because
of concerns that being labeled faith-based might work against them in the
grant process. However, it is unclear the extent to which FBOs are
reluctant to self-identify. Some FBOs may not be concerned as indicated
by the fact that they have religious organizational names and their mission
statements include religious references. In addition, according to HUD
officials, since 1997 HUD has asked organizations applying for Continuum
of Care programs to self-identify whether or not they are “a religious
organization, or a religiously-affiliated or motivated organization.” HUD
officials reported a high response rate from its applicants on this question
and noted that for this program, they rely on these data rather than the
voluntary survey to identify grantees that are FBOs. Finally, most of the
26 FBOs we visited said they filled out the voluntary survey, and almost all
said they would not be hesitant to self-identify as faith-based if asked.
Developing criteria for what constitutes an FBO is a challenging task.
Some organizations have a historical religious connection but only provide
secular social services, while other organizations are churches where faith
permeates the nonfederal services provided. The problem of determining,
without consistently applied criteria across federal agencies whether an
organization is faith-based or not is illustrated by one center official telling
us that his agency considers all of the local Young Men’s Christian
Association (YMCA) and the Young Women’s Christian Association
(YWCA) entities to be FBOs on the basis of the religious affiliation
contained in their organizational names and mission statements of the
national organizations. Meanwhile, an official at another agency said that
his agency looked beyond the national organization to see if the local
entities consider themselves to be faith-based.
An official at one local YWCA in Texas told us that the organization does
not consider itself to be an FBO. Similarly, several California organizations

51

One of the types of applicant categories available for applicants to check is “not for profit
organization.” However the application does not contain any further breakdown of this
category.

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listed by the WHOFBCI as FBOs told us that despite their religioussounding names, they did not consider themselves to be FBOs. This issue
will also be a concern as centers seek to collect additional data on FBOs
receiving state-administered formula grant programs. Several state
officials said that they believed that having a standard definition for FBOs
would help them if they are asked to collect data on which of their
grantees are FBOs.
Other attempts have been made to develop criteria for what constitutes an
FBO for collecting data on federal funding to FBOs. A February 2006 study
by the Roundtable on Religion and Social Welfare Policy sought to assess
the extent of federal support of faith-based social service providers by
examining the direct recipients of discretionary grant awards made by the
federal agencies that have initiative-related centers. Drawing on past
research on key characteristics of the faith character of organizations, the
study developed five characteristics by which to define an organization as
an FBO. These characteristics include whether the organization used overt
religious words or symbols in its name and whether religious or spiritual
references were contained in the organization’s mission or value
statement.52

Outcome Evaluations of Many
Pilot Programs Have Not Begun

Progress in achieving the initiative’s second long-term goal of improved
participant outcomes cannot yet be determined because agencies have not
completed most of the outcome-based evaluations for their ongoing pilot
programs. OMB’s Standards for Success for the initiative requires agencies
to undertake outcome-based evaluations of their pilot programs and build
an evaluation component into new pilots. Outcome-based evaluations may
involve several years of data collection before the analysis can take place,
and several of these pilot programs were initiated only a few years ago.
Generally, pilot programs help agencies demonstrate actual benefits that
may be achieved using a particular approach. While outcome evaluations
are an important component of program management in that they assess
whether a participant is achieving an intended outcome—such as
obtaining employment or completing high school—they cannot measure
whether the outcome is a direct result of program participation. Other
influences, such as the state of the local economy, may affect an

52
See Montiel, Lisa M., and David J. Wright Getting a Piece of the Pie: Federal Grants to
Faith-Based Social Service Organizations, The Roundtable on Religion and Social Welfare
Policy, February 2006, Washington, D.C.

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individual’s ability to find a job as much as or more than participation in
an employment and training program. Many researchers consider impact
evaluations—a form of outcome evaluation—to be the best method for
determining the effectiveness of a program; that is, whether the program
itself rather than other factors leads to participant outcomes. However,
impact evaluations can be time-consuming and expensive and may not be
appropriate in all circumstances.53
As shown in table 7, an outcome evaluation was completed or evaluations
were under way for 7 of the 15 pilot programs for faith-based and
community organizations. Justice completed an outcome-based evaluation
for the Clergy Against Senior Exploitation pilot program in Denver. The
evaluation suggests that the participants who completed the survey
believe that they were more knowledgeable about types of fraud and fraud
prevention and were better prepared to report fraud after completing the
program than prior to the program. While such results are promising, the
evaluation design does not allow for complete confidence that the pilot
achieved its intended outcome of helping participants avoid becoming
victims of fraud. For one of the six evaluations underway, we could not
determine from the design plan provided to us on the Faith and
Community-Based Juvenile Delinquency Treatment Initiative whether the
evaluation would be outcome-based. While officials at Justice provided us
with a list of research questions related to the process and outcome
evaluation under way, no specific information about the research design
was provided.

53

For further information about the different types of program evaluations, including
process, outcome, and impact evaluations, see GAO, Performance Measurement and
Evaluation: Definitions and Relationships, GAO-05-739SP (Washington, D.C.: May 2005).

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Table 7: Most Required Outcome Evaluations Not Completed, and Some Design Plans May Not Support an Evaluation of
Program Outcomes
Outcome
Evaluation
evaluation completed underway

Agency

Pilot and date established

Justice

Life Connections-2002

X

Faith and Community-Based
Juvenile Delinquency Treatment
Initiative–2003

X

CASE–2003

No outcome
evaluation planned

X

Rural Domestic Violence and Child
Victimization Enforcement Grant
Program: Special Initiative FaithBased and Community
Organizations Pilot Program–2005
Labor

Intend to conduct
outcome evaluation

X

Small Grassroots Program–2002

X

Ready4Work–2003

X

Grants for Workforce Investment
Boards–2004

X

Prisoner Reentry Initiative–2005

X

Education

Supplemental Educational Services2004

X

HHS

Compassion Capital Fund
Demonstration Program–2002

X

Compassion Capital Fund Targeted
Capacity-Building Program–2003

X

Mentoring Children of Prisoners–
2003

Xa

Access to Recovery–2004

X

HUD

Unlocking Doors Initiative–2005

X

Mentoring Pilot Project–2005

X

Total

1

6

6

2

Source: Education, HHS, HUD, Justice, and Labor program documents and interviews with agency officials.
a

Center officials at HHS said they intend to conduct an impact evaluation of the Mentoring Children of
Prisoners program that includes outcome data and analysis.

Of the six pilot programs in which center officials said they intend to
conduct outcome-based evaluations, HHS and HUD provided to us a total
of five design plans. Three of the five design plans appear to support

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outcome-based evaluations.54 However, for two of the five design plans, we
could not determine whether the evaluations would be outcome-based
because the plans lacked clarity and specificity about how the agency
would conduct these evaluations. Specifically, for HHS’s Access to
Recovery and Mentoring Children of Prisoners pilot programs, the written
materials did not describe the methodology or research plans for the
evaluations. With regard to the sixth pilot program, Labor did not provide
us with any written materials with which to assess whether the evaluation
for the Small Grassroots Program would be outcome-based or not. For the
two pilot programs in which agencies do not plan to conduct an outcomebased evaluation, HUD completed a non-outcome-based evaluation, and
Labor officials told us they have no plans to conduct an evaluation for the
Grants for Workforce Investment Boards pilot program.
Our previous work has shown that it is important for agencies to
collaborate with OMB to increase the likelihood that evaluations will meet
OMB’s needs. As agencies move forward with their design plans for
evaluating pilot programs, it will be important for agencies to discuss the
expectations for the scope and purpose of evaluation designs with OMB so
that these evaluations will meet the intended need. Evaluations designed
for internal audiences, such as agency officials, and others designed for
external audiences, often have a different focus. Evaluations that agencies
initiate typically aim to identify how to improve the allocation of program
resources. Studies requested by program-authorizing or oversight bodies,
such as OMB, are more likely to address external accountability—to judge
whether the program is properly designed or is solving an important
problem.
Although determining whether or not FBOs are more effective than
secular organizations in helping program participants is not an explicit
goal of the initiative, this issue has been part of the discussion since the
initiative’s inception. In the five agencies we reviewed, we identified only
one program evaluation, by Education, that will seek to compare the
effectiveness of FBOs with that of secular organizations.55 Judging from

54

The three pilot programs in which design plans appear to support outcome evaluations
are HHS’ Compassion Capital Fund Demonstration Program, the Compassion Capital Fund
Targeted Capacity-Building Program, and HUD’s Mentoring Pilot Project.
55

Education stated that it plans to compare the performance of faith-based and community
organizations to non-faith-based and community organizations in certain departmentfunded programs by asking questions such as if the quality of programs funded by the
department increased from 2001 to 2004 as a result of the participation of faith-based and
community organizations in the grant application process.

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our literature review of independent, nongovernmental studies, very few
studies attempt to make this comparison. We identified four studies
comparing the effectiveness of faith-based organizations with that of
secular organizations and determined that three of these studies lack
methodological rigor. The fourth study did not find a statistically
significant difference in the ratings made by people with low income of the
effectiveness of faith-based organizations compared with nonsectarian
organizations. However, the results of this study are not generalizable
because the study’s sample of respondents is for only two counties in
Pennsylvania.56

OMB Faces Challenges in
Measuring and Reporting on
Progress in Meeting Long-Term
Goals of Initiative

Agencies are tasked by OMB to achieve the two long-term goals of the
initiative:
•

greater participation by faith-based and community groups because
of regulatory and statutory reform, streamlined contracting
procedures, and improved coordination and outreach activities to
disseminate information more effectively at the grassroots level to
faith-based and community organizations; and

•

improved participant outcomes by placing a greater emphasis on
accountability and by making federal assistance better tailored to
local needs through the use of faith-based and community groups.

Some center officials stated that achieving green status on OMB’s
scorecard did not necessarily mean that an agency had accomplished
these long-term goals, but rather indicated the extent to which agencies
had implemented OMB’s Standards for Success.
OMB has not fully assessed or reported on agencies’ progress toward
achieving the two long-term goals of the initiative and is likely to
encounter challenges in doing so. For example, with regard to the first
goal of greater participation by faith-based and community groups, we
have already noted that although the WHOFBCI has reported annually on
the numbers and amounts of federal competitive grants awarded to FBOs,
there may be issues of accuracy with these data. Moreover, this data
reporting effort has focused on FBOs, not on community-based
organizations—the other group of organizations specified in the long-term

56

See, Wuthnow, Robert, “The Effectiveness and Trustworthiness of Faith-based and Other
Service Organizations: A Study of Recipients’ Perceptions,” Journal of Scientific Study of
Religion. 43:1, (2004).

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goal. In addition, OMB also faces the challenge of translating the general
goal of greater participation into measurement standards that do not
create perverse incentives or unreasonable expectations for agencies. The
general goal of greater participation could be measured in various ways,
such as through the number or percentage of these groups among federal
grant applicants, the number or percentage of grants awarded to these
groups, or the amount or percentage of grant funds awarded to these
groups.
With regard to the second long-term goal of improving participant
outcomes, OMB is also likely to face challenges in assessing agencies’
progress. For example, OMB has tasked agencies with performing
outcome-based evaluations of the pilot programs in their faith-based and
community initiative, but as we have noted, most of these evaluations have
not been completed. In addition, it is unclear whether the outcome-based
evaluations of pilot programs that eventually will be completed will
provide sufficient information for assessing progress towards the second
long-term goal—in part, because the goal of improved participant
outcomes could be measured in different ways. Finally, it is unclear
whether assessing agencies’ progress toward this long-term goal would
also take account of participant outcomes in some of the other nonpilot
programs in which faith-based or community organizations receive grants,
and if so, whether sufficient data would be available for these programs.
These varied challenges do not undercut the importance of moving from a
focus on processes to long-term results in assessing agencies’ performance
in implementing the faith-based and community initiative. GAO has
previously reported that results-oriented agencies continuously strive to
improve their strategic planning efforts and do not view strategic planning
as a static or occasional event.57

Conclusions

The Administration’s efforts to expand opportunities for faith-based and
community organizations to provide federally funded social services have
garnered support from many parties while at the same time prompting
concerns from others about whether federal funds should be used to
support the activities of FBOs and whether adequate measures are in place
to ensure that these organizations are not using federal funds to support
religious activities. Most of the programs that we reviewed provided some

57
See GAO, Agencies Strategic Plans under GPRA: Key Questions to Facilitate
Congressional Review, GAO/GGD-10.1.16 (Washington, D.C.: May 1997).

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guidance to applicants and grantees on the requirement that federal funds
for their programs not be used for religious activities, although some
federal and state offices did a better job than others in clearly presenting
information on this requirement to their grantees. We found instances
where FBOs did not appear to understand the nuances associated with the
equal treatment rule that prohibits FBOs from engaging in inherently
religious activities while providing services supported with direct federal
funds. We also found that Justice’s exemption to the restrictions on
inherently religious activities for certain programs, including the
correctional program we reviewed, lacks needed specificity and does not
provide FBOs with clear guidance on what religious activities they can and
cannot engage in with federal funds in correctional settings.
We also found that many program offices only provided citations to
federal or program regulations in their grant documents for the rules
related to nondiscrimination against beneficiaries and permissible hiring
by FBOs and that several provided outdated information. In many of the
programs we reviewed, government agencies are not systematically
monitoring for compliance with the equal treatment safeguards. While
government agencies are not required by federal regulation to specifically
monitor grantees for compliance with these safeguards, without some
written guidelines—including those used in single audits—that require a
discussion and check of these safeguards during monitoring, the
government has little assurance that the safeguards are protecting
beneficiaries, government agencies, and FBOs as intended. Furthermore,
one of OMB’s Standards for Success that agencies must meet to receive a
green grade is to monitor grantees for compliance with the equal
treatment safeguards.
In addition to monitoring, program accountability can be facilitated
through sound performance management and reporting, including reliable
performance data. Collecting credible data on FBOs receiving federal
funds is a difficult and time-consuming task, and the centers and program
offices have made good-faith efforts to develop estimates for FBOs
receiving federal grants. Nonetheless, without standard criteria across all
agencies of what constitutes a faith-based organization or a requirement
that FBOs self-identify, the data that the agencies collect may limit the
ability of policymakers to assess the extent to which the initiative is
progressing toward achieving its long-term goal of greater faith-based and
community participation. While some have voiced concerns about
requiring FBOs to self-identify, it is important to note that the surveys with
this information are included in grant applications but are not considered
when independent grant reviewers evaluate grant applications. In addition,

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FBOs may not be concerned about identifying themselves as faith-based as
indicated by the fact that they have religious organizational names and
their mission statements include religious references that are often seen
by grant reviewers.
Since 2001, agencies and OMB have emphasized progress toward the
initiative’s short term goals. Now that many agencies have achieved green
status for their work on eliminating barriers and undertaking outreach and
technical assistance to local organizations, it will be important for OMB to
ensure that the initiative’s strategic, long-term goals clearly articulate what
OMB intends to measure so that it can assess whether agencies are
achieving these goals and demonstrate whether agencies are using
taxpayer dollars effectively. As with other strategic planning efforts,
updating and revising long-term goals every several years is considered an
effective performance management practice. Clarifying and fine-tuning
strategic goals can help center officials manage their efforts toward
achieving appropriate and realistic long-term goals.

Recommendations for
Executive Action

To improve grantee understanding and federal agency oversight of the
equal treatment regulations for programs in which faith-based
organizations are eligible for federal funding, we recommend that the
Director of OMB:
1. ensure that all agencies with initiative-related centers include
information on the equal treatment safeguards in program grant
documents for which faith-based organizations are eligible, and
2. direct federal agencies and, where appropriate, state agencies, to
include a reference to the equal treatment safeguards in their
monitoring tools the agencies use to oversee federally funded grantees,
and
3. ensure that program-specific single audit supplements, where
appropriate, include a reference to these safeguards.
To ensure that contractors for Justice’s correctional programs understand
the exception to the prohibition on using federal funds for inherently
religious activities, we recommend that the Attorney General:
1. clarify the scope of the exception for chaplains and organizations
assisting chaplains to the general prohibition against using federal
funds for religious activities, and

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2. include a clear explanation of the exception and its scope in the
contracts for Justice’s correctional programs.
To improve accountability of the Faith-Based and Community Initiative,
we also recommend that the Director of OMB:
1. Work with the Secretaries of Education, HHS, HUD, and Labor, and
Justice’s Attorney General, to develop a consistently applied method
that will provide more accurate data on which organizations receiving
federal funds are faith-based. This effort could consider options such
as developing consistently applied criteria of what constitutes a faithbased organization, making the voluntary OMB survey of grant
applicants mandatory, or modifying OMB’s mandatory grant
application form to include a category for faith-based organizations.
2. Develop a plan for measuring and reporting on progress in achieving
the long-term goals of the faith-based and community initiative. This
effort may involve reassessing the two current long-term goals to
determine whether they should be revised and clarifying their
connection to the Standards for Success.

Agency Comments

We received comments from Education, HHS, HUD, Justice, Labor, and
OMB on a draft of this report. Comments from Education, HHS, HUD,
Justice, and Labor are contained in appendixes IV through VIII. Education,
HHS, HUD, Labor and OMB also provided technical comments, which we
incorporated where appropriate.
On May 31, 2006, we met with OMB officials to obtain their comments on
our draft report. OMB officials stated that they generally agreed with the
report’s recommendations to OMB. They agreed that our
recommendations that OMB take action to help ensure that agencies
include information on the equal treatment safeguards in program grant
documents and in program monitoring tools were reasonable. OMB
officials noted that these efforts would build upon agencies’ existing
efforts to ensure that grantees are aware of these important safeguards.
In regard to our recommendation that OMB ensure that agencies include a
reference to the equal treatment safeguards in program grant documents,
Education and HHS stated that they already provide sufficient information
in their grant documents on these safeguards. Our report documents in
table 5 which programs in our review include references to specific
safeguards in their grant documents. While a few programs provide

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information on all three safeguards we examined, most do not.
Education’s Mentoring program that we reviewed provided only citations
to the equal treatment regulations and did not, for example, explicitly state
in its grant documents that grantees cannot provide inherently religious
activities with direct federal funds. One of HHS’s programs included in our
review did not provide any information on 2 of the 3 safeguards we
examined. We believe that including information on the safeguards in one
or more key grant documents will provide greater assurance that grantees
are aware of and understand the safeguards designed to protect the
interests of FBOs, beneficiaries, and the government.
Education, HHS, HUD, and Labor took issue with our recommendation
that agencies be required to include a reference to the equal treatment
safeguards in their monitoring tools. They stated that such a requirement
would involve singling out faith-based organizations for greater oversight
and monitoring than other program participants on the basis of presumed
or confirmed religious affiliation. However, we are not recommending that
that they monitor FBOs more frequently or any differently than they
monitor other organizations. The equal treatment regulations are
potentially applicable to all grantees providing federally funded services.
While these regulations may have more relevance to FBOs and their
activities, we do not believe that having agencies ensure compliance with
all applicable regulations, including the equal treatment regulations,
results in any improper unequal treatment of FBOs. In our view, creating a
level playing field for FBOs does not mean that agencies should be
relieved of their oversight responsibilities relating to the equal treatment
regulations. In addition, as noted in our report, several of the 10 program
offices in our review included such a reference to equal treatment
regulations in their monitoring guidelines, and officials from 2 other
program offices told us that they intend to include information on these
regulations as they revise their monitoring guidelines. For example, Labor
officials stated in their comments that they have drafted detailed revisions
to their monitoring tools that will enhance their efforts to ensure
compliance with all facets of the equal treatment regulations.
HHS officials provided an additional comment on their efforts to ensure
that their program staff understand the equal treatment regulations. They
stated that HHS provides training to HHS program staff and state and local
officials who administer federal program funds. We agree that such
training can provide an important means for ensuring appropriate
monitoring, but we believe that including information on these safeguards
in program monitoring tools, as several programs covered in our review
currently do, is a prudent approach to ensuring that program staff will
consider these safeguards when monitoring grantees.

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OMB officials noted that grant-monitoring efforts could be strengthened
governmentwide and that our recommendation that OMB ensure that
program-specific single audit supplements include a reference to these
safeguards would need to be considered in the context of grant-monitoring
requirements overall. They stated that for some programs that already
have extensive audit requirements, expanding the program-specific audit
requirements could pose additional burdens to the independent auditors
conducting those reviews and might not be implemented uniformly. OMB
also questioned the potential usefulness of this recommendation since
smaller programs do not have a program-specific supplement and many
faith-based and community organizations receiving federal grants do not
expend $500,000 or more in federal funds and therefore would not be
subject to a single audit.
We agree that a governmentwide review of grant monitoring requirements
would be valuable and we acknowledge that adding a reference to
program-specific single audit supplements would add another audit step
for independent auditors and that agencies need to balance the additional
requirement with the added assurance it would give providers. While we
modified the recommendation to indicate that it might not be suitable to
include a reference to the equal treatment safeguards in some programspecific supplements, we continue to believe that including these
references wherever appropriate based on facts, circumstances, and risk,
would help assure interested parties that grantees are using federal funds
appropriately. It is noteworthy that two of the three programs in our
review that had a 2006 program-specific audit required auditors to check
that funds were not expended for inherently religious activities. We agree
with OMB that many programs do not have program-specific supplements
and that many faith-based and community organizations may not be
subject to the single audit because of the $500,000 threshold. However,
including a reference to the safeguards in these supplements would
provide an additional check for compliance with these safeguards when
independent auditors conduct a single audit of larger organizations.
Moreover, our recommendation that agencies include information on the
safeguards in their program grant documents takes on increased
importance for those organizations not subject to a single audit. As noted
in our report, one of the independent auditors we spoke with said that he
developed his own audit plan by reviewing the grant application package.
Regarding our recommendation that OMB work with agencies to develop
more accurate data on FBO grantees, officials at OMB said that they agree
that having better data on the types of organizations applying for and
receiving federal grants would help agency and Administration efforts to

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gauge the success of the initiative. They said that federal agencies have
been improving the quality of the data they collect, and which the White
House reports annually, on FBOs receiving federal grants. However, OMB
officials said that there are obstacles to obtaining better data and that they
are uncertain about the extent to which the data could be further
improved. They noted that agencies are concerned about the practical and
legal difficulties inherent in developing a uniform definition for what
constitutes an FBO. OMB officials stated that OMB and agencies have
discussed making the voluntary survey mandatory, but that this step has
not been taken because of agency concerns that some FBOs would not be
comfortable self-identifying and that mandatory self-identification might
discourage participation. HHS also questioned our recommendation to
improve the data that the centers collect on federal grants awarded to
FBOs. HHS stated that our recommendation suggests the need to establish
a uniform definition of an FBO, which HHS stated would be problematic
and provide questionable benefit.
We acknowledge in our report that developing criteria on what constitutes
an FBO is a challenging task, and our recommendation does not dictate
that agencies establish a uniform definition. However, in cases where an
organization chooses not to self-identify, the various agency centers or
program offices are currently applying criteria—whether explicitly or
implicitly—that determine whether they categorize an organization as an
FBO. We believe that greater consistency in their use of such criteria could
help improve the accuracy of data on funds received by FBO grantees. In
addition, the extent to which FBOs are reluctant to self-identify is unclear.
HUD includes in its Continuum of Care grant application a request for
programs to self-identify, and HUD officials reported a high response rate
from its applicants on this question. In addition, some FBOs have religious
names and their mission statements include religious references. Without
evidence that FBOs are reluctant to self-identify, we believe that agencies
should explore the possibility of making the voluntary survey mandatory
or modifying the mandatory application form to include a category for
FBOs. We believe that if one of the stated long-term goals of the initiative
continues to be greater participation of faith-based and community
organizations in providing federally funded social services, then it is
critical to systematically explore options for obtaining more accurate data
on participation.
With regard to our recommendation to OMB to develop a plan for
measuring and reporting on progress in achieving the two long-term goals
of the faith-based and community initiative, OMB officials had a different
response for each long-term goal. For the long-term goal of improving

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participant outcomes, OMB officials agreed that it is reasonable for OMB
to publish the results of the outcome-based evaluations that agencies are
required to conduct on their pilot programs. However, OMB officials said
they did not see a need for OMB to develop a plan for measuring and
reporting on progress with respect to the other long-term goal of greater
participation of faith-based and community organizations. They noted that
the White House is already reporting on the numbers of FBOs receiving
federal grants and the amounts of these grants in selected programs and
trends in these areas. However, OMB officials acknowledged that there is
a lack of clarity about how the two long-term goals of the initiative are
linked with OMB’s Standards for Success and that it thus may be
appropriate to clarify their connection as part of a reassessment of the
long-term goals. We agree with OMB that the long-term goals might need
to be better aligned with the interim goal of expanding opportunities for
faith-based and community organizations to compete on an equal basis for
federal funding and we modified our recommendation to reflect this point.
We also agree with HHS’s comment that it would be inappropriate to
establish arbitrary participation goals.
Our draft report had included a recommendation that OMB make publicly
available the Standards for Success for the FBCI. OMB posted these
standards on its Web site in late May and we accordingly deleted this
recommendation in our final report.
Justice agreed with our recommendation that the Attorney General clarify
the scope of the exception contained in Justice’s equal treatment
regulations for chaplains and organizations assisting chaplains. With
regard to our other recommendation to the Attorney General, Justice
stated that the Department’s Federal Bureau of Prisons is open to
discussing possible changes to its contract language to further clarify the
scope of the exception to community corrections centers. See appendix IV
for our annotated responses to each of the comments Justice made in its
letter.
In several instances, agencies commented that our report omitted
important information. For example, HUD stated that we do not define
what safeguards are designed to protect FBOs, beneficiaries, and the
government. However, this information is outlined in table 2 and the
safeguards are discussed in detail on pages 29-36. HUD also took issue
with our characterization of the initiative’s goals. HUD stated that we do
not acknowledge the Administration’s stated goals for the initiative of
removing barriers, leveling the playing field, and providing technical
assistance. However, we discuss these goals in table 1 and on page 40.

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Labor also stated in its comments that the object of the initiative is to level
the playing field. While our report notes that this is a stated goal of the
initiative, our report also cites the stated long-term PMA goals of the
initiative of greater participation of faith-based and community
organizations and improved participant outcomes. Labor also commented
that our report overlooks the data that Labor collects from grantees on
outcome measures, such as employment and earnings. Our report
discusses the long-term goal of improved participant outcomes and
provides information on the status of the outcome evaluations for the
15 pilot programs for faith-based and community organizations. The scope
of our work did not include reporting the data being collected for
individual outcome measures in the various programs. Finally, Education
stated in its comments that we did not find any indication of unallowable
activity. This is true except with regard to the prohibition pertaining to
inherently religious activities. We found that a few of the FBOs included in
our review described engaging in activities that appear not to be
permissible with respect to this prohibition, as noted on pages 34-35.

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As agreed with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days from its
date. At that time, we will send copies of this report to the Secretaries of
HHS, HUD, Education, and Labor; the Attorney General; the Director of
OMB; appropriate congressional committees; and other interested parties.
We will also make copies available to others upon request. In addition, the
report will be available at no charge on GAO’s Web site at
http://www.gao.gov.
Please contact me at (202) 512-7215 if you or your staff have any question
about this report. Other major contributors to this report are listed in
Appendix IX.

Cynthia M. Fagnoni
Managing Director, Education, Workforce,
and Income Security Issues

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Appendix I: Centers’ Estimated Expenditures
by Category, Fiscal Year 2005

Appendix I: Centers’ Estimated Expenditures
by Category, Fiscal Year 2005

Labor

HUD

HHS

Education

0

10

20

30

40

50

60

70

80

90

100

Percent
Salaries/benefits
Other administrative costs
Contractual services
Travel
Source: GAO analysis of Education, HHS, HUD, and Labor data.

Note: Justice was not able to provide a breakdown of its center’s expenditures.

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Appendix II: Selected Characteristics of
Faith-Based Organizations GAO Visited

Appendix II: Selected Characteristics of
Faith-Based Organizations GAO Visited

Provide
voluntary
religious
services for
clients

Received
federal
funding prior
to FBCI

Believes FBCI
changed
opportunities
for their
organization

Annual
Annual
overall
program
budget
budget
(dollars in (dollars in
thousands) thousands)

Percentage of
federal funds in
program budget

Religious
affiliation

Federal funding
program(s)

Christian

Community-Based
Abstinence
Education, HHS;
Abstinence
Education Program,
HHS

No

No

No

1,500

104

83

Christian

Community-Based
Abstinence
Education, HHS

No

Yes

No

632

378

100

Christian

Community-Based
Abstinence
Education, HHS

No

Yes

Yes

1,500

680

100

Jewish

Microenterprise
Development
Program, HHS

No

Yes

Yes

4,615

300

100

InterFaith

Grants for Small
Yes
Faith-Based and
Community Nonprofit
Orgs., Labor

No

Yes

50

50

50

Christian

Grants for Small
Yes
Faith-Based and
Community Nonprofit
Orgs., Labor

No

No

225

150

17

Christian

Grants for Small
Yes
Faith-Based and
Community Nonprofit
Orgs., Labor

No

Yes

250

250

10

Baptist

Mentoring Children of No
Prisoners, HHS

No

Yes

550

270

75

Lutheran

Continuum of Care,
HUD; Emergency
Shelter Grants
Program, HUD

No

Yes

No

41,000

5,550

20

Pentecostal Continuum of Care,
HUD

Yes

Yes

No

3,200

525

40

Interfaith

Microenterprise
Development
Program, HHS

No

Yes

Uncertain

950

325

60

Evangelical

Community
Corrections
Contractor with
Bureau of Prisons,
Justice

Yes

Yes

No

3,000

825

100

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Appendix II: Selected Characteristics of
Faith-Based Organizations GAO Visited

Provide
voluntary
religious
services for
clients

Received
federal
funding prior
to FBCI

Believes FBCI
changed
opportunities
for their
organization

Annual
Annual
overall
program
budget
budget
(dollars in (dollars in
thousands) thousands)

Percentage of
federal funds in
program budget

Religious
affiliation

Federal funding
program(s)

Christian

Abstinence
Education Program,
HHS

No

No

Yes

313

313

100

Christian

Abstinence
Education Program,
HHS

No

Yes

No

100

100

92.5

Catholic

Continuum of Care

No

Yes

No

36,000

1,300

Less than 50

Protestant

Emergency Shelter
Grants Program,
HUD

Yes

Yes

No

1,500

244

26

Christian

Emergency Shelter
Grants Program,
HUD

No

Yes

No

300

300

25

Christian

Continuum of Care,
HUD

Yes

Yes

No

1,900

310

25

Christian

Substance Abuse
Prevention and
Treatment Grants,
HHS

Yes

Yes

No

22,000

4,000

55

Christian

Continuum of Care,
HUD; Emergency
Shelter Grants
Program, HUD

Yes

Yes

No

9,000

1,000

50

Christian

Substance Abuse
Prevention and
Treatment Grants,
HUD

Yes

Yes

No

1,400

873

80

Protestant

Community-Based
Abstinence
Education, HHS;
Abstinence
Education Program,
HHS

Yes

Yes

Yes

1,281

439

83

Protestant

Department of
Education Mentoring
Programs

Yes

No

Yes

300

103

99

Catholic

Community
Corrections
Contractor with
Bureau of Prisons,
Justice

Yes

Yes

Yes

1,500

1,500

100%

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Appendix II: Selected Characteristics of
Faith-Based Organizations GAO Visited

Provide
voluntary
religious
services for
clients

Received
federal
funding prior
to FBCI

Believes FBCI
changed
opportunities
for their
organization

Annual
Annual
overall
program
budget
budget
(dollars in (dollars in
thousands) thousands)

Percentage of
federal funds in
program budget

Religious
affiliation

Federal funding
program(s)

Christian

Continuum of Care,
HUD; Emergency
Shelter Grants
Program, HUD

No

Yes

No

1,354

260

38%

Christian

Department of
Education Mentoring
Programs

No

No

No

250

106

80-85%

Source: GAO analysis of information obtained from interviews with officials from the 26 FBOs.

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Appendix III: Best Practices for the
Initiative’s Standards for Success

Appendix III: Best Practices for the
Initiative’s Standards for Success
Best Practices for
Outreach and Technical
Assistance
Federally Administered
Grant Programs

1. reviews agency programs to identify those of particular interest to
faith-based and community organizations,
2. implements a strategic outreach and technical assistance plan
(through White House regional conferences and workshops),
3. creates a database of faith-based and community organizations and
maintains grant solicitation mailing lists,
4. produces informational materials in consultation with the White House
Office of Faith-Based and Community Initiatives (WHOFBCI)
5. organizes technical assistance workshops,
6. provides Web-based outreach and technical assistance,
7. participates in interagency conferences on the Faith-Based and
community Initiative,
8. incorporates Faith-Based and Community Initiative outreach goals into
agencywide events.

State and locally
Administered Grant
Programs

9. implements an action plan in consultation with WHOFBCI to enhance
opportunities of faith-based and community organizations to compete
for federal funds at the state and local levels (through White House
regional conferences and workshops),
10. Creates a database of faith-based and community organizations
interested in state and locally administered grant programs,
11. provides targeted Web-based outreach and technical assistance,
12. distributes written outreach materials approved by WHOFBCI,
13. coordinates with state and local agencies through regional offices on
outreach activities,
14. adopts successful outreach and technical assistance practices of other
agencies,

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Appendix III: Best Practices for the
Initiative’s Standards for Success

15. coordinates with regional offices to provide technical assistance
workshops.

Best Practices for
Implementation of Equal
Treatment Regulations
Education

1. posts a notice of the regulation on its center for faith-based and
community initiative Web site,
2. posts a notice of the regulation on Web sites of agency program
offices,
3. sends a program memo to state and local administrators of agency
funds, alerting them to the final rule and asking them to ensure that
their own processes and policies reflect the rule,
4. develops materials such as questions and answers, PowerPoint
presentations, and easily accessible explanations of the rule in
consultation with WHOFBCI to educate internal and external
stakeholders about the regulations,
5. educates agency grant staff, including field offices, that manage
formula grants on the requirements of the regulation,
6. arranges training for state and local officials who administer funds
under the regulation (through White House regional conferences and
workshops),
7. educates governors’ offices and mayors’ offices about the
requirements of the regulation (through materials to be provided at
White House regional conferences and workshops),
8. discusses the regulations at conferences,
9. encourages organizations that represent grantees to highlight the
regulations in constituent newsletters,
10. sends a more detailed policy notice or guidance document to state and
local officials on how to implement the rule.

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Appendix III: Best Practices for the
Initiative’s Standards for Success

Compliance

11. enforces existing procedures when monitoring uncovers a violation,
12. conducts a representative survey in consultation with OMB and
WHOFBCI by program or by state to examine indicators of progress in
complying with the regulations,
13. reviews existing mechanisms to determine whether they include
sufficient monitoring to ensure compliance with the equal treatment
regulations.

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Appendix IV: Comments from the Department
of Justice

Appendix IV: Comments from the
Department of Justice
Note: GAO comments
supplementing those in
the report text appear at
the end of this appendix.

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Appendix IV: Comments from the Department
of Justice

See comment 1.

See comment 2.

See comment 3.

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Appendix IV: Comments from the Department
of Justice

See comment 4.

See comment 5.

See comment 6.

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Appendix IV: Comments from the Department
of Justice

See comment 7.

See comment 8.

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Appendix IV: Comments from
the Department of Justice

The following are GAO’s comments on the Department of Justice’s letter
dated May 22, 2006.

GAO Comments

1. The statement that Justice cites does not refer to the mission of the
Administration’s Faith-Based and Community Initiative but to funds
awarded since 2001 through new grant programs. (The goals of the
initiative are discussed on pages 11 and 40.) On page 25, we state that
these new programs were created to provide training and technical
assistance to faith-based and community organizations and to increase
the participation of these organizations in providing federally funded
social services. As shown in table 4 (pages 26-28), eligibility for
several of these grants is specifically targeted to faith-based and
community organizations and the stated purpose of many of these
grants is to increase participation of faith-based and community
organizations in providing federally funded social services. For
example, the stated purpose of Justice’s HOPE II program is to
“increase the development and capacity of faith-based and/or
community based organizations” to respond to victims in high-crime
areas. In addition, as noted in HHS news releases, HHS’s Compassion
Capital Fund awards are “designed to help grass roots, faith-based and
community organizations enhance their ability to provide a wide range
of social services.” We revised our statement on the highlights page
and on page 22 to more fully reflect the purpose of these new grant
programs.
2. We fully explain the safeguard related to inherently religious activities
in Table 2, p. 13. In regard to the point that this safeguard relates to
direct and not indirect federal funding, table 2 notes that this safeguard
refers to “direct” government funds. For further clarification, we
added a footnote to this table to explain that this safeguard does not
pertain to providers offering services through indirect funding, such as
vouchers, and clarified throughout the report that inherently religious
activities cannot be offered unless separate in time or location from
direct federally funded program activities.
3. GAO understands the authority of the government to provide chaplains
and other spiritual accommodation for inmates in custody. However,
as we discussed with Justice officials during our exit meetings, we
believe that the scope of the exception for community corrections
centers stated in Justice’s equal treatment regulations (28 CFR 38.1 (b)
(2)) needs to be clarified and that an explanation of this exception
should be contained in community correction program contracts.
Justice currently does not include a discussion of this exception in its

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Appendix IV: Comments from
the Department of Justice

contracts and we maintain that community corrections staff may not
understand whether or under what circumstances they may engage in
religious activities using federal funds. Our report also recommends,
and Justice agreed that the Attorney General should clarify the scope
of the exception in its equal treatment regulations. We did not include
any FBOs administering the Community Corrections program when we
stated that four of the FBOs we visited appeared to violate the
safeguard related to the prohibition on inherently religious activities
unless separated in time or location from federally funded services.
4. GAO does not recommend that departments use a “bright line”
definition of an FBO when collecting data on grantees. Our report
acknowledges the efforts federal agencies make to collect accurate
data on grants awarded to FBOs, including the voluntary survey used
by all the agencies in our review (see page 44). However, as we note in
the report, producing credible data on outcomes achieved through
federal programs has historically been a challenge for the federal
government. Various parties, including former officials from the White
House Office of Faith-Based and Community Initiatives, have raised
concerns about the accuracy of, and the methods used to collect, data
on FBOs. Our report calls for efforts among federal agencies to
develop an improved method for identifying which organizations are
faith-based. We note that this can be achieved through several options,
including ones that do not require that agencies define what
constitutes an FBO. Justice also raises the possibility that the
initiative’s progress can be measured as long as the department
distinguishes between public agencies and nongovernmental
organizations. However, this is not how the initiative is currently being
measured. The PMA lays out the long-term goals of the initiative, one
of which specifically cites greater participation by faith-based and
community organizations. The White House published data on the
number of FBOs receiving direct federal grants for selected agencies in
2003-2005 but has not published data on the number of grants received
by government versus non-governmental organizations.
5. We revised the text on page 8 to reflect our findings in the report on
the number of pilot program evaluations under way or completed. We
believe that table 7 on page 48 accurately reflects the status of the
evaluations to the extent possible based on the limited information
provided by some of the departments on many of these evaluations. In
addition, we added a sentence on pages 8 and 46 that acknowledges
the time it may take to collect outcome-based data and the fact that
many of the pilot programs began recently.

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GAO-06-616 Faith-Based and Community Initiative

Appendix IV: Comments from
the Department of Justice

6. We discussed with Justice officials various competitive programs
before deciding to review the Community Corrections Contracting
program. We requested and Justice officials provided to us detailed
information on several competitive grant programs, including
information on the Community Corrections Contracting program. We
chose this program because, in 2004, at least three times as many
FBOs received grants from this program than any other Justice
program in that same year.
7. Appendix II of the draft report provided information on the grant
program and department from which each of the 26 FBOs received its
award or contract and table 3 (see page 24) shows whether the grant
was a project grant, formula grant, or contract.
8. GAO believes that including information on these safeguards in grant
documents will improve grantee understanding of the equal treatment
regulations. Given that Justice’s equal treatment regulations contain an
exception to the safeguard related to the prohibition on organizations
providing inherently religious activities unless separate in time or
location from federally funded services, we believe that an explanation
of this exception should be included in the contracts for Justice’s
correctional programs. We do not recommend that an explanation of
this exception be included in every program document, as Justice
asserts. Rather, our recommendation clearly states that an explanation
of the exception should be included in the contracts for Justice’s
correctional programs. Justice states that the Bureau of Prisons is
open to discussing possible changes to its contract language to further
clarify the scope of the exception for community corrections centers.

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Appendix V: Comments from the Department
of Education

Appendix V: Comments from the Department
of Education

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GAO-06-616 Faith-Based and Community Initiative

Appendix V: Comments from the Department
of Education

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GAO-06-616 Faith-Based and Community Initiative

Appendix VI: Comments from the Department
of Health and Human Services

Appendix VI: Comments from the
Department of Health and Human Services

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GAO-06-616 Faith-Based and Community Initiative

Appendix VI: Comments from the Department
of Health and Human Services

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GAO-06-616 Faith-Based and Community Initiative

Appendix VII: Comments from the Department of Housing and Urban Development

Appendix VII: Comments from the
Department of Housing and Urban
Development

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GAO-06-616 Faith-Based and Community Initiative

Appendix VII: Comments from the Department of Housing and Urban Development

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GAO-06-616 Faith-Based and Community Initiative

Appendix VIII: Comments from the
Department of Labor

Appendix VIII: Comments from the
Department of Labor

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GAO-06-616 Faith-Based and Community Initiative

Appendix VIII: Comments from the
Department of Labor

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GAO-06-616 Faith-Based and Community Initiative

Appendix IX: GAO Contacts and Staff
Acknowledgments

Appendix IX: GAO Contacts and Staff
Acknowledgments
GAO Contact

Cynthia M. Fagnoni (202) 512-7215, FagnoniC@gao.gov

Staff
Acknowledgments

In addition to the contact named above, Andrew Sherrill, Assistant
Director, and Elizabeth Morrison, managed this assignment.
James Whitcomb, Lauren Jones, and Robert Sampson made significant
contributions to this review. Richard Burkard and Jim Rebbe assisted in
the legal analysis, Jean McSween provided methodological support, and
Jonathan McMurray assisted in report development.

(130451)

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GAO-06-616 Faith-Based and Community Initiative

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