(3) The Office of Academic Assistance (OAA), the National Criminal Justice Information and Statistics Services (NCJISS), and the National Institute of Law Enforcement and Criminal Justice (Institute) rely totally on the Audit and Inspection Division for audit service. The staffing of these three organizations (including the positions responsible for program review) during the time period covered by the question was as follows:

Of the numbers shown above, 6 were used to perform program and project reviews by the OAA, 9 by the NCJISS and 30 by the Institute. Program or project reviews consist primarily of site visits to project locations as time and travel budgets permit to monitor program or project performance. A copy of the review checklist used by the OAA during site visits is attached as Exhibit IV. If a need for audit arises, the program managers refer the matter to the Audit and Inspection Division. The Audit Guide used by the Audit and Inspection Division in reviewing the Law Enforcement Education Program is attached as Exhibit V.

(4) Page 6 of the 1970 Annual Report is not correct. At the outset, the Administrators of the LEAA decided that the Audit and Inspection Division should report directly to the Office of the Administration. At a later date, because of the Administrators' span of managerial control problems, it was decided that the Audit and Inspection Division should report through the Office of Administrative Management (OAM) on all matters except those relating to audits of OAM functions, which are reported directly to the Administration. The most recent organizational chart is attached as Exhibit VI.

(5) A copy of the "Delineation of Administrative Functions and Responsibilities" agreed to between the LEAA and the Administrative Division of the Department is attached as Exhibit VII. On April 24, 1970, the Attorney General assigned to the Administrator of LEAA the responsibility for audits of grants and contracts awarded by LEAA, however, the responsibility for internal audits of administrative and program functions of LEAA was retained by the Assistant Attorney General for Administration. The internal audit responsibility has been assigned to the Office of Internal Audit in the Department and includes review and monitoring of LEAA audits of contracts and grants.

(6) To comply with Section 303 (11) of the Act, the LEAA through the OLEP Financial Operations Unit has released the following guidelines:

a. Guide for Comprehensive Law Enforcement Planning and Action Grants-Exhibits VIII.

b. Financial Guide for Administration of Planning and Action GrantsExhibit IX.

c. Guide for Discretionary Grant Programs-Exhibit X.

These guidelines are supplemented as needed by directives. Section 303 (11) does not directly apply to audit, however, drafts of audit guidelines to be used by the LEAA Audit and Inspection Division, other Federal audit agencies, and State and local audit staffs have been drafted and are being tested by the LEAA auditors working in three states. Audit guide preparation and testing is in accordance with the principles of the Bureau of the Budget (now the Office of Management and Budget) as set out in Circulars No. A-73. A-87 and A-88. These circulars provide for the cooperation of all Federal, state and local auditors and encourages them to assist each other in accomplishing the task of auditing Federal-State programs. Drafts of the audit guidelines developed to date are attached as Exhibit XI.

(7) To date, the LEAA has not had a situation where it has been necessary to request funds from a grantee because of the failure of the grantee to make its legally required contribution of costs as provided under P.L. 90-351. However, in the event the grantee does not comply with the legal requirements, the LEAA's policy is to request the return of a corresponding share of Federal funds granted to the project.

The LEAA Guidelines state that "the full grantee matching share must be contributed by the end of the period that Federal funds are available for obligation or expenditure under a given grant or subgrant and in no event later than the date at which the complete Federal award has been expended." In view of the carryover provisions established by the LEAA (one year for planning funds and two years for action funds beyond the end of the award year), the required match for fiscal year 1969 planning and action block grants are not required until the end of the 1970 and 1971 fiscal year's respectively or the date at which the total block grant has been expended, whichever comes sooner. In view of the carryover provisions, the degree of audit coverage has been limited to date. The Audit and Inspection Division will assist LEAA in determining whether state and local units of government are meeting their legal requirements pertaining to the match.

(8) The LEAA has not required specific minimum levels of audit resources within State Planning Agencies. The LEAA Guide for Comprehensive Law Enforcement Planning and Action Grants includes, under responsibilities, requirements for monitoring program progress and auditing expenditures. In addition, the financial guidelines state that "It is the intention of the Administration to conduct an annual audit of grant fiscal administration by each State agency, with major emphasis on evaluation of the State's grant accounting and control systems and limited sampling of individual grant programs at both the state and local level. State audit systems and post audit units, however, will be considered the primary resource for audit of subgrant projects supported with Title I funds." In addition, the guide itself was intended to provide minimum levels of regulations.

However, pursuant to statutory authority, the Administration will conduct a continuing program of audit of Title I planning and action grants. To the maximum extent possible, reliance will be placed on state audits pursuant to the general Federal policy established by Bureau of the Budget Circular A-73 (Appendix C). Accordingly, a primary audit objective will be continuing review and inspection of the adequacy of state systems and controls.

(9) The request made by the Department on behalf of LEAA to the Appropriation Committee for review resources cannot be determined precisely. As previously stated, the various positions in the different organizational elements of LEAA all have a certain degree of review responsibility.

The total requests made by the Department. with a specific breakdown of Audit and Inspection Division positions, were as follows:

1969 2 1970.

1971.

Proposed 1971 supplement.
Requested 1972..

1 Increase over prior year.

2 Although this amount was approved by the House and Senate, the total positions were administratively cut by the Department to 225 and 4 for total personnel and audit respectively.

Sincerely,

Enclosures.

RICHARD W. VELDE,

Associate Administrator.
CLARENCE M. COSTER,
Associate Administrator.

U.S. DEPARTMENT OF JUSTICE,

LAW ENFORCEMENT ASSISTANCE ADMINISTRATION,
OFFICE OF THE ADMINISTRATION,
Washington, D.C., September 2, 1971.

Hon. JOHN S. MONAGAN,

Chairman, Legal and Monetary Affairs Subcommittee of the Committee on Government Operations, Rayburn House Office Building, Washington, D.C. DEAR MR. CHAIRMAN: This is in response to your recent letter requesting a list of state planning agencies scheduled for audit under Project 50-21.

We are in the process of completing our survey and the States have for the most part been selected. The list is attached.

Audits are already underway in South Carolina, Indiana, and Utah. The audits in New Jersey, New Mexico and Nebraska are tentatively scheduled to begin September 13, 1971. We are currently operating with six audit teams. Priorities within the LEAA program elements have required us to drop the originally planned seventh team. For administrative efficiency, the 50-21 survey audit was initiated under the seven region organization rather than the new ten region breakdown.

At this time it is not possible to anticipate the starting dates of additional audits because future audits will be initiated upon completion of those currently underway. The completion date of current audits has not been determined. With kind regards.

APPENDIX G.-LETTER, DATED SEPTEMBER 27, 1971, FROM THE ADMINISTRATOR OF LEAA TO CHAIRMAN MONAGAN RELATIVE TO THE ADMINISTRATIVE RESOURCES OF LEAA FOR YEARS 1969 THROUGH 1972, INCLUSIVE

U.S. DEPARTMENT OF JUSTICE,

LAW ENFORCEMENT ASSISTANCE ADMINISTRATION,

Hon. JOHN S. MONAGAN,

OFFICE OF THE ADMINISTRATION, Washington, D.C., September 27, 1971.

Chairman, Subcommittee on Legal and Monetary Affairs, Committee on Government Operations, House of Representatives, Washington, D.C.

DEAR MR. CHAIRMAN: This is in response to your letter of September 13, 1971, requesting information on the administrative resources of the Law Enforcement Assistance Administration.

Enclosed is the information you requested. If I can be of any further assistance, please let me know.

With kind regards,

National Institute of Law Enforcement and Criminal Justice_
Reserve for proposed staffing of regions__.

Positions transferred (2, White House; 2, Department of Justice) ---