Publicly Released: October 7, 2021
The objective of this audit was to determine whether the Department of Defense Education Activity (DoDEA) was verifying that grantees met the terms and conditions of grants. We also determined whether DoDEA was verifying that grantees met the grant interim goals.
The U.S. Senate Committee on Finance requested that we conduct this audit. The U.S. Senate Committee on Finance received allegations that DoDEA conducted little to no monitoring of its grants and did not maintain adequate grant records to allow proper oversight. DoDEA plans, directs, coordinates, and manages pre-kindergarten through 12th grade educational programs and schools located on select military installations.
DoDEA’s Education Partnership and Resources Division (Partnership) executes the DoDEA grant program with assistance from the DoDEA Procurement Division. DoDEA Partnership required assistance from contractors, currently Safal Partners, Inc. (Current Contractor), with the preaward through closeout phases of the grant process. Additionally, the contractors provided the grantees support in building the grantee’s capacity to serve the military student population throughout the grant and to sustain those activities after the grant ended.
The DoDEA grant program supports research-based programs to increase student achievement and ease the challenges that military dependent children face due to their parents’ service. Between FYs 2016 and 2020, the DoDEA Procurement Division awarded 186 grants, with a total award value of $186.3 million.
DoDEA did not verify that, on a projected 70 of 186 grants, grantees were meeting the grant terms and conditions. This occurred because DoDEA did not have an adequate process to hold grantees accountable for submitting late performance and financial reports. Additionally, of the 186 grants in our universe, we project that 139 completed at least one implementation year that would require it to achieve interim goals. DoDEA did not verify, on a projected 100 of 139 grants, whether grantees met the interim goals. This occurred because DoDEA did not thoroughly review the annual performance reports to determine whether grantees met interim grant goals and take action to assist grantees that did not meet interim grant goals. As a result, we project that DoDEA potentially wasted $49.9 million from FY 2016 through FY 2020 provided to grantees that did not meet the grant terms and conditions, did not meet the interim goals and are not on track to meet all overall goals by the end of the grant, or both.
We recommend that the Assistant Secretary of Defense for Manpower and Reserve Affairs, Office of the Under Secretary of Defense (Personnel and Readiness) require DoDEA officials to:
- establish a process to inform grantees that DoDEA will withhold grant funding when required reports are submitted late, and retain a history of grantees that submitted late reports and had funding withheld for use in evaluating the risk assessments for future DoDEA grant awards;
- review the 186 active DoDEA grants, determine if the grantee is meeting interim goals and is on-track to meet the overall goal by the end of each grant, and coordinate to develop a plan with those grantees that are not meeting the interim goals;
- clarify the performance work statement to include the requirement and due date for the Current Contractor to provide a list of grantees that did not submit required reports after the close of each reporting cycle and to require the Current Contractor to evaluate all grantees’ annual reports;
- develop a process to verify that grantees meet future interim goals in each implementation year. If grantees are not meeting interim goals, DoDEA officials should require the grantee to submit a corrective action plan detailing what it will do to meet the interim goals in the future. If grantees continue to miss interim goals, DoDEA officials should withhold funding to the grantee until the grantee proves it is meeting the interim goals; and,
- establish a process that tracks when grantees are not meeting interim goals or overall grant goals for use in evaluating the risk assessments for future DoDEA grant awards.
Management Comments and Our Response
The Management Official Performing the Duties of the Assistant Secretary of Defense for Manpower and Reserve Affairs agreed with the recommendations. The Management Official stated the following:
- DoDEA follows the Code of Federal Regulations, which enables it to exercise judgment in remedies for noncompliance if the grantee fails to comply with any grant terms or conditions. DoDEA first uses direct engagement and case-by-case strategies to increase compliance, then moves to more punitive measures, such as withholding funding, until corrections are made and approved.
- DoDEA has reviewed all active grants for terms and conditions compliance, and grantees not meeting their interim goals will receive technical assistance and be offered a monitoring plan solution.
- DoDEA will modify the current contract to add the contractor due date for submitting the list of late grantees to DoDEA, and will revisit the current contract for further clarification related to verifying that the Current Contractor provides a written narrative that evaluates all grantees’ annual reports.
- DoDEA will develop monitoring plans that include technical assistance specific to reporting requirements and surveillance of interim goals for all awarded grantees beginning FY 2021.
- DoDEA uses a tracking spreadsheet and the annual dashboards to monitor grantees who are currently not on target with interim goals, and considers this in future risk assessments.
We will close the recommendations once we verify that the agreed-upon actions are complete.
This report is a result of Project No. D2021-D000AT-0089.000.