A number of model community anti-drug coalitions lost their funding after the federal drug czar's office threw out peer-review scores typically used to award the Drug-Free Communities (DFC) grants, instead allowing a small group of in-house reviewers to use a different set of criteria to decide who got funded, prevention field leaders charge.
In a rare instance of public discord with the federal government, Community Anti-Drug Coalitions of America (CADCA) urged its members to write to President Bush and drug czar John Walters to object to a “flawed” process for selecting the most recent grantees under the Drug Free Communities Act.
Gen. Arthur Dean, president and CEO of CADCA, said that while all applicants underwent the standard peer-review process and received a score, the Office of National Drug Control Policy (ONDCP) — which directs the program in partnership with the Substance Abuse and Mental Health Services Administration's (SAMHSA's) Center for Substance Abuse Prevention — decided to throw out those scores.
ONDCP then established a small review group that judged the applicants based on a set of 10 criteria that CADCA officials said were not fully disclosed to the public. “We were told that SAMHSA did peer-review everyone, but when we saw that those scores weren't used to make the decisions … it led us to raise these serious concerns,” said Dean.
Jennifer DeVallance, an ONDCP spokesperson, said that the 2005 Drug Free Communities grant competition “was an extremely competitive process and one that was implemented with the highest levels of integrity.”
“To suggest otherwise is to highlight an ignorance of the facts and the unfortunate reality that resources are limited and not every applicant can receive funds,” she said.
However, ONDCP did not respond to repeated requests to explain why the grantee scoring was discarded in favor of the new criteria, to identify the makeup of the review committee that made the funding decisions, or to reveal the scores of the programs that were de-funded. SAMHSA referred all questions about the DFC process to ONDCP.
“Coalitions did not have the opportunity to respond to the specific administrative reasons determined by ONDCP to disqualify them,” said Dean. “Grantees still have not been told the specific reasons that their grants were determined ineligible for funding.”
John Carnevale, a former ONDCP planning and budget staffer and head of the policy consulting firm Carnevale Associates, said ONDCP's decision to involve itself in the grantmaking process went against the intent of Congress, which he said placed DFC in the juvenile-justice program office in the Justice Department to avoid have funding decisions colored by politics. “By being part of the grant review process, ONDCP has politicized the process,” said Carnevale. “ONDCP is not an expert on grants review — it's a policy shop.”
CADCA issued an alert to its membership on Sept. 23 saying that in the latest round of Drug-Free Communities grantmaking, announced by ONDCP on Sept. 21, “63 current grantees that were eligible for continuation funding were terminated without due process. Further, 88 other coalitions were placed on a high-risk (probationary) status with no prior notice, and only given 30 days to come into compliance.”
“The procedure that was used to determine who would receive funding in FY 2005 undermined the confidence in the administration to conduct a fair and impartial grant process,” CADCA said in its alert, adding, “CADCA believes that the grant process should have consistent and clear eligibility requirements and review scores relevant to the funding determination.”
CADCA urged members to write to the Bush administration to ask for a “fair and impartial appeals process to challenge the arbitrary nature of the decision-making process” and to ensure that “any future process used to determine DFC grantees is fair and equitable.”
Ten Criteria Instead of Scores
The 603 coalitions that applied for continuation funding were required to comply with a list of 10 standards set forth by Congress in the original Drug-Free Communities Act, said DeVallance, such as proving that they have nonfederal matching funds, support community-based coalitions as defined in the funding announcement, and are addressing federal goals for the program.
“These criteria were established by Congress in the Drug-Free Communities Act and are not new,” said DeVallance. “Each application was subjected to a competitive peer-review process. If a coalition did not demonstrate compliance with all of the criteria, they were not funded.”
DeVallance said that 90 percent of coalitions applying for continuation funding were able to demonstrate compliance; these coalitions were then evaluated to ensure that they met the federal requirement of using a maximum of 20 percent of federal funding for program implementation.
“Those coalitions that did not meet this criteria — 88 of them — were placed on “high risk” status and given 30 days to submit a budget that indicates compliance with the program's policy on this issue,” said DeVallance. “The “high risk” coalitions were notified in writing to this effect. No existing coalition — not one — was denied funding because of failure to meet this requirement.”
Addressing one of the key complaints of coalition leaders — that they were not given notice of deficiencies in their applications or time to correct them — DeVallance said that the application period had been extended and that coalitions had been offered technical assistance. “Additionally, those coalitions that did not receive continuation funds are able to apply next year without any prejudice and will have technical assistance available,” she said.
But CADCA officials said that only six of the 10 criteria were in the original legislation, and that some of the best coalitions in the country lost their funding for such minor infractions as having incomplete meeting minutes or spending one percent more than the 20 percent limit on program implementation — a standard they contend was loosely defined to begin with. “If they discontinued coalitions for administrative reasons and give the money to those with lower scores, our position is that that doesn't track,” said Dean.
Four Days from Penthouse to Outhouse
Harry Kressler, executive director of the Pima Prevention Partnership Coalition in Pima, Ariz., said his coalition passed a SAMHSA site visit with flying colors just four days before being notified by ONDCP that they were losing their $100,000 DFC grant. “To be told four days later that you're 'not a coalition' means those site visits were meaningless,” said Kressler, whose program was one of the original community partnerships established by CSAP in 1991, and has received DFP funding for the past seven years. “Why audit us when the findings are not used?” he asked.
Kressler said federal officials told him that Pima lost its funding because reviewers believed that meeting minutes submitted with the coalition's renewal application showed that the program was no longer community-based, but rather school-based, thus making it ineligible for funding. Kressler said reviewers may have misinterpreted discussions about a new charter school that the coalition founded for addicted adolescents. “The [ONDCP] criteria opened the process up to making decisions based on opinion and interpretation, not fact,” he said.
In a July 2004 letter regarding the transfer of the program from the Justice Department to CSAP, SAMHSA and ONDCP told DFC grantees that some changes might be put into place regarding accounting and data collection.
“However, we want to assure you that we are taking steps to ensure that there will be no lapse in your funds, that any new requirements due to this transfer will be minimal, that there will be no requirement to reapply or re-compete for funds already awarded,” said the letter, signed by SAMHSA Administrator Charles Curie, Mary Ann Solberg, deputy director of ONDCP, Keri-Lyn Coleman, ONDCP's acting administrator of the the Drug Free Communities program, and Robert Flores, administrator of the Office of Juvenile Justice and Delinquency Prevention in the Justice Department.
However, groups like the Pima partnership were later told they had to reapply for funding even though they had already been approved for multiyear grants. “HHS required and ONDCP agreed that all existing grantees reapply (this year only) for Year 2, 3, 4, or 5 funding,” said ONDCP's DeVallance.
Kressler called the concept of competitive continuation funding “an oxymoron.”
“We don't know what the agenda of ONDCP is,” he said, adding: “Decisions were made in a vacuum.”
The decisionmaking on DFC grants, combined with the Bush administration's proposals to eliminate the Safe and Drug Free Schools program and cut CSAP's budget, leads some observers to question the administration's commitment to drug prevention. “I'm concerned that the policy of the federal government is to get out of the prevention business,” said Carnevale.
ONDCP announced $72 million in Drug Free Communities grant awards on Sept. 21, including $17.1 million for matching grants in 176 new communities and $54 million in continuation grants to 535 existing community coalitions. Also, $1.7 million was awarded for 24 new Drug Free Communities Support Mentoring Programs, along with $929,470 in continuation funding for 13 existing mentoring programs.