Detailed Information on the
Human Trafficking Assessment

Improve procedures for allocation of funds to organizations serving victims, to maximize effectiveness. Milestone: Restart national public awareness campaign that will also reinvigorate previously engaged coalitions, increase partnerships among service providers and law enforcement, and increase the number of organizations with capacity for outreach, victim discovery, and service provision.

Improve procedures for allocation of funds to organizations serving victims, to maximize effectiveness. Milestone: Restart national public awareness campaign that will also reinvigorate previously engaged coalitions, increase partnerships among service providers and law enforcement, and increase the number of organizations with capacity for outreach, victim discovery, and service provision.

Improve procedures for allocation of funds to organizations serving victims, to maximize effectiveness. Milestone: Conduct monitoring of intermediary contractors to ensure effective use of HHS funding.

Implementing new systems to more effectively shepherd and track identified victims through the certification process. Milestone: Institute new database for collection, tracking, and reporting of victim information, trends, and analysis.

Improve efficiencies in achieving program goals by increasing the number of victims certified and served by whole network of grantees per million dollars invested. Milestone: Provide for and support additional grants to build and maintain Rescue & Restore Coalitions, increasing capacity among community organizations to raise public awareness, help identify victims, and connect victims to service providers.

Improve strategic planning by systematically collecting information from practitioners about best practices for identifying victims of trafficking. Milestone: Development of dissemination plans and technical assistance regarding promising practices to the field, including new outreach grantees, intermediaries contractors and per capita services contractor.

Improve procedures for allocation of funds to organizations serving victims, to maximize effectiveness. Milestone: Restart national public awareness campaign that will also reinvigorate previously engaged coalitions, increase partnerships among service providers and law enforcement, and increase the number of organizations with capacity for outreach, victim discovery, and service provision.

Implementing new systems to more effectively shepherd and track identified victims through the certification process. Milestone: Create and implement victim identification pipeline to be used by grantees to be used as tool for tracking success of outreach activities.

Improve procedures for allocation of funds to organizations serving victims, to maximize effectiveness. Milestone: Conduct monitoring of street outreach grants to ensure effective use of HHS funding.

Improve strategic planning by systematically collecting information from practitioners about best practices for identifying victims of trafficking. Milestone: Begin to develop partnerships and connections within full Department to leverage HHS resources, including research and service grants, to increase knowledge and information about trafficking and identification of victims within larger HHS service population.

Improve strategic planning by systemically collecting information from practitioners about best practices for identifying victims of trafficking.

Improve procedures for allocation of funds to organizations serving victims, to maximize effectiveness. Milestone: Institute modifications to intermediary contract statements of work to increase speed of sub-award processes, including requiring approval of all sub-awards by HHS.

Improve efficiencies in achieving program goals by increasing the number of victims certified and served by whole network of grantees per million dollars invested. Milestone: Provide small amounts of funding to Rescue & Restore Coalitions to help fortify the coalitions by broadening membership and building capacity for raising public awareness, identifying victims, and serving and obtaining certification for victims.

Implementing new systems to more effectively shepherd and track identified victims through the certification process. Milestone: Conduct improvements to trafficking database to better track potential and verified victims as reported from multiple sources to ORR.

Measure: Increase the number of victims of trafficking certified per year to 600 by FY 2014.

Explanation:ORR's long term goal by FY 2011 is to achieve a level of victims' certification (800 per year) which would come closer to the congressionally imposed annual limitation of 5000 T-Visas (visas specifically set aside for victims of trafficking under the TVPA). Each year, ORR will report progress toward meeting that long-term goal, which will serve as a proxy for the program's desired outcome of rescuing victims of trafficking.

Measure: Increase number of victims certified and served by whole network of grantees per million dollars invested.

Explanation:This measure relates to certification, which is an outcome in and of itself but which also linked to the ultimate outcome of self-sufficiency. Since the Rescue and Restore campaign was instituted in April 2004, the program has already seen major efficiency gains on this measure. Although there were no apparent efficiency gains between FY 2003 and FY 2004, the program demonstrates large efficiency gains when comparing performance during the first twelve months after the inception of the Rescue and Restore campaign (April 2004 to March 2005) to performance over the prior twelve months (April 2003 to March 2003).

Measure: Increase the number of victims of trafficking certified per year.

Explanation:ORR's long term goal by FY 2011 is to achieve a level of victims' certification (800 per year) which would come closer to the congressionally imposed annual limitation of 5000 T-Visas (visas specifically set aside for victims of trafficking under the TVPA). Each year, ORR will report progress toward meeting that long-term goal, which will serve as a proxy for the program's desired outcome of rescuing victims of trafficking.

Measure: Increase media impressions, hotline calls, and website visits per thousand dollars invested.

Explanation:

Is the program purpose clear?

Explanation: The program's purpose is to maximize the number of victims who are detected and rescued, so that they may receive benefits and services under the TVPA to regain their dignity and safely rebuild their lives in the U.S.. The Trafficking Victims Protection Act of 2000 (TVPA) provides a comprehensive and cooridinated federal approach to combating human trafficking by assigning specific responsibilities to HHS, including: (1) identifying and certifying victims to be eligible for federally-funded benefits to the same extent as refugees; (2) connecting victims with non-profit organizations that provide legal services, counseling, case management and benefit coordination; and (3) providing public information activities to combat trafficking through greater public awareness.

Evidence: TVPA, Trafficking Victims Protection Reauthorization Act of 2003 and the HHS website. frwebgate.access.gpo.gov/cgi-bin/useftp.cgi?IPaddress=162.140.64.88&filename=publ386.106&directory=/disk3/wais/data/106_cong_public_laws. frwebgate.access.gpo.gov/cgi-bin/useftp.cgi?IPaddress=162.140.64.88&filename=publ193.108&directory=/diskb/wais/data/108_cong_public_laws www.acf.hhs.gov/trafficking, Check Florida State University Human Trafficking Report, Tab 5. We used this report as background analysis for the designing of the Rescue and Restore Campaign, to have a better understanding of the human trafficking situation in the US.

Does the program address a specific and existing problem, interest, or need?

Explanation: According to the Central of Intelligence Agency, between 14,500 and 17,500 victims are trafficked into the U.S. annually. Human trafficking is a modern-day form of slavery. Victims of human trafficking are subjected to force, fraud, or coercion, for the purpose of commercial sex or labor exploitation. Victims of trafficking are drawn from a plethora of nationalities, ethnic groups, and faiths. Traffickers exploit their victims for a variety of reasons, including prostitution, pornography, sweatshop labor, involuntary domestic servitude, and migrant agricultural labor. As the TVPA states, "Existing legislation and law enforcement in the U.S. and other countries are inadequate to deter trafficking and bring traffickers to justice, failing to reflect the gravity of the offense involved. No comprehensive law exists in the United States that penalizes the range of offenses involved in the trafficking scheme."

Evidence: Trafficking Victims Protection Act, 2000. 2004 State Department Trafficking in Persons Report, Check Tab 1, Check Florida State University Human Trafficking Report, Tab 5

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: There are potentially five funding streams available to any city or other geographic entity to support anti-trafficking programs: 1. ACF/HHS Outreach & Service Grants; 2. Office of Victims of Crime (OVC/DOJ) Outreach and Service Grants; 3. Bureau of Justice Assistance (DOJ) Task Force Grants; 4. ACF Direct Outreach to Victims Grants. 5. ACF Local Anti-trafficking Coalitions. These programs do not excessively overlap, but rather provide a continuum of services. HHS is the only agency that can provide victims a continuum of care from the moment they are identified through HHS certification and, ultimately, self-sufficiency.

Evidence: Public Law 106-386. Sec. 105 (a), (b); HHS has recruited over 500 groups to participate in its coalition activities, including over 60 national organizations; Check Tab 5 MOU HHS-DHS-DOJ

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: There is no strong evidence that another approach or mechanism would be more efficient or effective to achieve the intended purpose. The TVPA was based on the premise that victims would leave their exploitive situations and self-identify themselves to law enforcement if the right benefits and services were provided. However, experience demonstrated that this is a type of crime where victims do not come forward because they are paralyzed with fear of law enforcement. Traditional service grants were an insufficient means for implementing the TVPA, therefore major changes in the program design were made to meet the statutory goals. For example, HHS implemented the public awareness campaign to increase the number of victims who come forward to receive TVPA assistance and report their cases to federal law enforcement. In addition, HHS is establishing a contractual relationship to provide services to any victim of human trafficking. ORR will provide a defined financial stipend, per capita based on the number of victims being served.

Evidence: Check Ketchum Human Trafficking Report; Check Florida State University Human Trafficking Report, Tab 5

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: The program successfully created a national service mechanism by which victims of trafficking everywhere in the country could be served. HHS has utilized discretionary grants to create a network of service organizations available to assist victims of a severe form of trafficking. Since the inception of the Trafficking Program in FY 2001, ORR has awarded discretionary grants to twenty-eight organizations. The program evaluates the bi-annual reports of grantees in order to examine the caseload of victims being served, and has retained Calvin Edward & Associates to assist in this evaluation with site visits as well. A contract for a new per capita service support mechanism is to be awarded by September 30, 2005. The per capita service support mechanism will be operated under a single contract to an appropriate organization with national reach. Under this contract, the per capita benefit would be available to any qualified organization actually serving a victim of trafficking, essentially under a subcontract arrangement. The number of persons being served by grantees has increased,That is undoubtedly more a function of our other identification efforts. The authority provided in the Reauthorization Act closes a funded services gap, so that grantees are able to offer more comprehensive services at an earlier stage. While there is no specific evidence that grantees were turning away potential, pre-certified victims in the past, the program was concerned about the disincentive effect of the lack of funding to serve pre-certified victims. That now having been removed, HHS finds grantees more readily accepting pre-certified victims into programs.

Evidence: www.acf.hhs.gov/trafficking; Ketchum Human Trafficking Report; Florida State University Human Trafficking Report. RFP for the new contract mechanism. Half of these grants will be closing out on September 30, 2005 and the other half on March 30, 2006.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The two long term measures reflect the ultimate goal of the Human Trafficking program: to restore all victims of trafficking so that they may live productive, safe, and healthy lives. The data sources for the two proposed measures are: HHS database of trafficking victim certifications, based on information provided by the Department of Justice (DOJ), the Department of Homeland Security (DHS), and ORR Human Trafficking Program grantees; and data collected from HHS social and health providers network of grantees.

Evidence: Trafficking Victims Protection Act, 2004

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The long-term target and timeframe recognize DHS's capacity to process trafficking victims and the congressionally imposed annual limitation of 5000 T Visas for trafficking victims. The program intends to identify and certify 1600 victims by 2011. The annual rate of improvement on this measure accelerates from 30% improvement for FY 2006 to 50% improvement by FY 2011: FY03: 151 (53% increase over FY02) FY04: 163 (8% increase over FY03) FY05: 200 (23% increase over FY04) FY06: 260 (30% increase over FY05) FY07: 350 (35% increase over FY06) FY08: 490 (40% increase over FY07) FY09: 715 (45% increase over FY08) FY10: 1070 (50% increase over FY09) FY11: 1600 (50% increase over FY10) This long term target of 1600 is both ambitious and realistic. It is anticipated that the program will see fast growth in the next couple of years, with the success of the Rescue and Restore campaign and greater nationwide awareness of the phenomenon of trafficking. The proposed increases, with accelerating growth over time, reflect the hope that the identification and certification of trafficking victims will begin to approach the estimates for the number of victims entering the country annually. The program is constrained by the underground and criminal nature of trafficking activities, the difficulty of collaborating with law enforcement to effectively differentiate victims of trafficking from criminals and terrorists so that they can be helped, and the red tape that plagues the DHS when it comes to processing T Visas. Based on the proposed rate of growth shown above, the program anticipates that it will likely reach the 5000 T Visa limit around FY 2015 or 2016. There does not appear to be any Congressional intent regarding the date by which the 5000 T Visa limit ought to be reached; the limit emerged largely as a function of discussions between pro- and anti-immigrant advocacy groups. Upwardly adjusting the limit past 5000 annual T Visas would require Congressional action, either as part of reauthorization or through an amendment to an enacted version of the TVPA. The program also proposes that, by 2011, 79% of certified victims will require fewer than two years of help (of victims certified by FY 2009). This is also an ambitious and realistic target, and reflects an increase in the rate of self-sufficiency of 2% per year. This target if quite ambitious given the fact that many victims have low levels of education and skill, and are also recovering from the presumed trauma of their victimization. The current lifetime limit for TANF is 5 years; that a trafficking victim could be self-sufficient (not receiving cash assistance) only 2 years after being rescued sets a high bar for the program's effectivenes.

Evidence: Trafficking Victims Protection Act, 2004, Sec. 107 (n) (1) "The total number of aliens who may be issued visas or otherwise provided nonimmigrant status during any fiscal year under section 101 (a) (15) (T) may not exceed 5,000". http://frwebgate.access.gpo.gov/cgi-bin/useftp.cgi?IPaddress=162.140.64.88&filename=publ386.106&directory=/disk3/wais/data/106_cong_public_laws

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: Proposed Annual measure: Increase the number of victims of trafficking certified. This is a good proxy as it is considered a surrogate for the number of victims rescued. The efficiency measure shows increased victims rescued per dollar invested in identification-related activities. The efficiency measure is provided because the base of program appropriations is static, therefore the increase in victims identified implies a decrease in the cost per victim identified. Second Proposed Annual measure: Increase the number of victims or trafficking restored to self-sufficiency. In addition, annual efficiency measures are proposed related to the Rescue and Restore public aware

Evidence: Check Ketchum Human Trafficking Report, Assessment of US Government Activities to Combat Trafficking in Persons www.usdoj.gov/crt/crim/wetf/us_assessment_2004.pdf

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The proposed annual targets are both ambitious and realistic. We anticipate that the program will see fast growth in the next couple of years, with the success of the Rescue and Restore campaign and greater nationwide awareness of trafficking. The proposed increases, with accelerating growth over time, reflect the hope that the identification and certification of trafficking victims will begin to approach the estimates for the number of victims entering the country annually. The targets for the self-sufficiency measure are also ambitious and realistic targets as they reflect an increase in the rate of self-sufficiency of 2% per year. This target is quite ambitious given the fact that many victims have low levels of education and skill, and are also recovering from the presumed trauma of their victimization. The current lifetime limit for TANF is 5 years; that a trafficking victim could be self-sufficient (not receiving cash assistance) only 2 years after being rescued sets a high bar for the program's effectivenes.

Evidence: Trafficking Victims Protection Act, 2000

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: HHS has impacted the way that the federal and state governments are combating trafficking by emphasizing a "victim-centered" approach to trafficking cases. DOJ has embraced the region-by-region approach being implemented by the public awareness campaign by creating US Attorney Task Forces in the cities in which HHS created community-based coalitions, and it now welcomes the call for state anti-trafficking legislation and involvement by state and local law enforcement agencies. There is still room for improvement in the effort to get federal law enforcement to embrace a victim-centered approach to human trafficking. However, it should be recognized that ultimately law enforcement and HHS have a different priority and emphasis in their missions - the HHS mission is primarily to assist victims whereas the law enforcement mission is primarily to investigate and prosecute traffickers. Nonetheless, all partners seek to increase the number of victims identified and certified. The contractors embrace the short and long term goals of the program and have been provided a high-quality level of service. The intent and design of those grants is to advance the short- and long-term goals of the program. Since ACF has just established the goal of increasing the proportion of victims restored to self-sufficiency, data has not yet been collected through grantee reporting. However, the per capita support services contract will give HHS greater authority to require providers to furnish this performance information.

Evidence: Assessment of US Government Activities to Combat Trafficking in Persons, www.usdoj.gov/crt/crim/wetf/us_assessment_2004.pdf; Calvin Edwards & Associates (CEA) letter to new grantees (attached) as evidence of how performance measures are being imposed on new grantees.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The program uses several methods for evaluation: 1- Calvin Edwards & Associates asseses grantees' activities; 2- Site visits to grantees; 3- Monitors the Rescue and Restore Public Awareness Campaign; 4- Consultations: Monthly consultation with DOJ and annual consultation with grantees. Until now, the only outcome measure included in the requested grant report was the amount of victims certified, and we just recently set the new outcome "restore victims to self-sufficiency". In addition, the 2002 grants did not include a request to provide information about victims' evolution and progress in their restoration process. The new contract system will be changed to require service funds recipients to provide information about how victims are evolving and how the organization is helping them return to self-sufficiency. This new mechanism is expected to be in place by October 1.The new contract mechanism, since it will be centralized, will give the program easier access to data about the certification and self-sufficiency outcomes of victims of trafficking. With access to this data, HHS will be able to determine the program's success in restoring victims of trafficking to self-sufficiency. Program evaluations would be most useful insofar as they study program implementation, provide data on promising practices, perform case studies of programs and victims, and perhaps make suggestions for other ways to evaluate the program in the future.

Evidence: Public Law 106-386. Sec. 1003 (a),

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: Since FY03, ACF has spent the annual appropriation of $10 million less rescissions on trafficking related activities, and this program budget is focused on two long-term performance targets. The current budget request reflects ACF's focus on outreach activities, including the Rescue and Restore campaign and the hotline. We are spending around 70% of our budget in providing services and outreach through our grantees, and the other 30% in doing outreach and public awareness mainly targeting intermediaries, with some professional PR agencies. We are continually evaluating this ratio, and as you can observe, moving toward the investment of more funds in victim identification and eventual certification. Therefore, as the public awareness campaign begins to bear fruit and our active victim identification increases (a process which will be reflected through reporting on our annual and long-term performance targets), our budget requests will reflect a greater emphasis on victim identification, certification, and self-sufficiency.

Evidence: " Assessment of US Government Activities to Combat Trafficking in Persons, www.usdoj.gov/crt/crim/wetf/us_assessment_2004.pdf Human Trafficking Program ACF Logic Model (draft)"

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The program has implemented new annual and long-term performance measures (outcome and efficiency) with ambitious and realistic targets, in order to improve strategic planning. In addition, the program realized that the premise that victims would come forward was wrong. To correct this, the program launched the Rescue and Restore Public Awareness Campaign, which is targeted to victims and persons most likely to come in contact with victims. In addition, the program is correcting the grantees networks flaws by putting into practice a new contract mechanism to provide services to victims. The mechanism will be in place by October 1, 2005 and is expected to yield the following benefits: (1) Universally Available Funding: The contractor will provide financial support to public or private non-profit agencies anywhere in the United States that are providing services to one or more victims of human trafficking as defined by the Act, provided that the organizations meet such qualifying criteria as deemed necessary by ORR; (2) More Rational Resource Allocation: The services contract will increase the efficiency of the trafficking program's resource allocation by making service funding available only to organizations which are actually serving victims of trafficking, and by allowing ORR to invest funds in services only to the extent such investments are justified by the victim caseload; (3) Increased Accountability: The services contract will to increase the accountability and responsibility of the social service process by requiring potential recipients of financial support to report the size of the trafficking victim client caseload, and to provide basic characteristics of that caseload so that appropriate system-wide monitoring of resource utilization can occur; (4) The design of the new per capita service support mechanism has been a significant undertaking. ) Reduction in Per Victim Service Costs: The anticipated per capita cost of the proposed contract is considerably less than the amortized per victim cost of the current grant program for services.

Evidence: Statement of Work for the Public Awareness Campaign contract, State of Work for the Per Capita Contract/ Announcement of the Outreach Grants; www.acf.hhs.gov/trafficking; Documentation to the Program Support Center (PSC) for procurement action

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The program receives performance information from all of the key partners, grantees, and contractors: 1) DHS: provides real-time notices of awards of "continued presence" statuses, receipt of "bona fide" T visa applications, and T visa awards. This information triggers issuance of HHS certifications. 2) DOJ Office of Victims of Crime and Bureau of Justice Assistance: these two entities award trafficking grants, and monthly consultations are conducted to exchange information about grantee performance, service coverage, coordination of multiple grantees and multiple funds streams in metropolitan areas, and separate initiatives. 3) DOJ, Civil Rights Division: HHS forwards to DOJ/Civil Rights leads received by the HHS Trafficking hotline. HHS confers with DOJ/Civil Rights on an as-needed basis concerning particular cases. 4) DOJ US Attorneys and Staff: HHS has embraced the role of ombudsman on behalf of victims and their advocates and seeks to build lines of communication between them and Assistant US Attorneys and federal law enforcement personnel who will be responsible for investigating and prosecuting specific trafficking cases. 5) Public Awareness Campaign Contractors: HHS holds weekly status meetings with representatives of the prime contractor and key subcontractors responsible for implementation of the public awareness campaign. Next day reports of all news articles concerning human trafficking are collected in order to monitor coverage of the "Rescue and Restore" campaign. 6) Grantees: provide financial and programmatic reports semi-annually. 7) Covenant House, operator of the Trafficking Information and Referral Hotline: provides monthly reports on the number and profile of calls to the hotline; and sends email notices on specific cases of trafficking. 8) ACF Web Team: provides traffic information on the Trafficking website.

Evidence: Check documents under Tabs 2 and 4: Calvin Edward Report and the Semi-annual Program Progress Report by USCCB.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Contractor performance is closely monitored with regard to timing and cost, and evaluated in light of the management plan established at the beginning of the contract. Grantees are also monitored. The program put in place a policy of not rolling-over unobligated grant funds at the end of the grant year, so that greater discipline will be imposed on grantees with regard to the implementation of their programs. Unobligated grant funds are captured and applied to other purposes. Regarding the findings of the Calvin Edwards report that grantees did not meet their goals: At the inception of the Human Trafficking program, grants were awarded under the assumption that victims would come forward on their own, and that grantees should be prepared to provide services to these victims. The grants were therefore awarded to organizations whose core skill set was service provision to traumatized individuals (they were not skilled in outreach, collaboration with law enforcement, or the special needs of vulnerable populations). To a large degree, grantees were unable to meet their goals due to a mismatch between their skill sets and the skills actually needed for the task at hand (outreach to vulnerable populations, work with law enforcement, and public awareness/coalition building). Since the grants were awarded, grantees have been encouraged to build their skills in these other tasks, and their efforts have also been supplemented by the public awareness campaign. Ultimately, grantees will be supplanted by the per capita service contract, which will increase the ease with which the program can manage the program and hold service providers accountable. We are also currently establishing specific performance measures for the new category of outreach grants, which begin May 1, 2005. Federal managers: Throughout ACF, Federal managers are held accountable for results through the inclusion of relevant program performance measures in their performance plans and evaluations. For example, the ACF Assistant Secretary and the Director of ORR (where the Human Trafficking Program is housed) both have specific performance measures included in their performance plans (The Assistant Secretary's Performance Contract is provided as evidence). In addition, a summary of the Administration's priorities and ACF's performance measures is attached to each ACF employees annual performance plan (See FY 2005 Performance Contract for the Director of ORR, as well as the FY 2005 Performance Contract for the Assistant Secretary, which contains the targets and performance goals contained in the Agency's performance budget. These cascade throughout the Agency to all Commissioner and Associate Commissioner performance contracts, all SES performance evaluation standards, and throughout all Employee Performance Management System (EPMS) personnel review standards for all ACF employees. In specific program areas, the performance standards and targets are carried through as they appropriately apply for that specific program. The EPMS for the ACF performance manager contains all the same elements, targets, and performance goals as the Assistant Secretary's performance contract. ). Federal Managers are also held accountable for internal accounting and administrative controls under the Federal Managers Financial Integrity Act (FMFIA) (P.L. 97-255). Heads of each executive agency must report annually regarding compliance with the provisions of FMFIA. ORR has never reported a material weakness in these areas.

Evidence: "Check documents under Tabs 2 and 4: Calvin Edward Report and the Semi-annual Program Progress Report by USCCB. Assistant Secretary's Performance Contract"

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: In FY03 and FY04, the program fully obligated our appropriation (99.9% and 99.5% respectively). All funds have been spent to advance the purposes of the program. As mentioned in question 1.5 and 2.5, the program successfully created a national service mechanism by which victims everywhere in the country could be served. HHS has utilized discretionary grants to create a network of service organizations available to assist victims of a severe form of trafficking.

Evidence: Trafficking Administration CAN Report; Trafficking Grants CAN Report; Trafficking Salaries and Benefits CAN Report

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program has proposed two efficiency measures which will indicate whether the program is achieving improved efficiency. 1 - Increase number of victims certified and served by whole network of grantees per million dollars invested; 2 - Increase Media Impressions, Hotline calls, and Website Visits per thousand dollars invested. Certification is a long process requiring a high level of services from ORR and its partners; therefore, it is believed that an efficiency measure focused on certification and related services would not create perverse incentives to provide services at a lower cost. Efficiency gains would come largely from having a greater number of victims and benefiting from the resulting economies of scale. Data Source: Media Outreach: Public Awareness Campaign Contractors, the prime contractor and key subcontractors responsible for implementation of the public awareness campaign, provide next day reports of all news articles concerning human trafficking in order to monitor coverage of the "Rescue and Restore" campaign. Hotline: Covenant House, operator of the trafficking hotline, provides monthly reports on the number and profile of calls to the hotline. Covenant House also sends e-mail notices of information received concerning specific cases of trafficking. The Hotline reports includes the amount of calls received every month, the date, the call number, the call start time, the language, the city, the state, the Caller's gender, the Caller's age group, a brief description of the type of call (like homeless, child abuse, immigration statues, domestic violence, etc), to which it was referred, and information about if the hotline counselors set a conference call with grantees. Website: ACF Web Team provides traffic information on the Trafficking website. This includes how many visitors check the website, the average time per visit, the origin of the visit, and the how many hits per day.

Evidence:  

Does the program collaborate and coordinate effectively with related programs?

Explanation: The program undertakes regular and frequent consultations with our federal partners. These include the monthly consultations with DOJ trafficking grantor entities and DOJ enforcement. Communications with Homeland Security's Citizenship and Immigration Services and Immigration and Customs Enforcement are also frequent. HHS is also an active participant in the Senior Policy Operating Group (SPOG) process and the President's Interagency Task Force on Trafficking. The goal of these consultations is to insure shared responsibilities are efficiently and effectively discharged in a collaborative manner. HHS entered into a Memorandum of Understanding with DHS and DOJ to facilitate information-sharing between federal partners. The program also builds bridges at the local (metropolitan area) level between federal law enforcement entities (FBI, ICE and the US Attorneys' staff) and community organizations, for the purpose of increasing referrals of trafficking cases for investigation and prosecution. An element of the detection and rescue strategy is to create at the local level a second mechanism of victim identification based on community activism by intermediaries, as opposed to law enforcement actions.

Evidence: MOU HHS-DOJ-DHS provided. HHS/DOJ grantee consultation agenda provided. Sample agenda from the HHS/DOJ monthly consultation provided.

Does the program use strong financial management practices?

Explanation: The program maintains precise control over program funds. Because of the modest size of the program, financial monitoring is maintained with frequent cross-reference to the accounting status reports generated by the Department's system (GATES). This practice allows for a precise control of budget status. One of the policies the program implemented to improve financial management of grantees is to deny the carry-over of unspent funds, so that a grantee applying for a continuation grant would be eligible for at most the amount of the original grant, not the original amount plus unobligated funds from previous grant years. In FY03 and FY04, over 99% of appropriated funds were obligated for trafficking related activities.

Evidence: Trafficking Administration CAN Report; Trafficking Grants CAN Report; Trafficking Salaries and Benefits CAN Report

Has the program taken meaningful steps to address its management deficiencies?

Explanation: The program has demonstrated aggressive management response to the realization the program had been managed under the incorrect assumption that victims will generally self-report. This response includes initiation of the "Rescue and Restore Victims of Human Trafficking" public awareness campaign, the creation of a new grant program for direct contact outreach to victims, and the shift of funding of services from a discretionary grant mechanism to a contract mechanism, among other steps. With regard to the lack of quantitative measures of grantee performance (identified through a review and analysis of current grant management practices), the program is currently establishing specific performance measures for the new category of grants, which begin May 1, 2005. In addition to the grantee performance measures which are being established, the program has implemented, as part of the PART and performance budget process, performance outcome and efficiency measures with ambitious targets. With regard to resource allocation inefficiencies inherent in the grant mechanism for providing services to victims, the program is pursuing a new contractual funding mechanism, which will provide greater ease of management that will allow for a more direct relationship between ORR and the provider of the services.

Evidence: Check document under Tabs 2: Calvin Edward Report; Check Ketchum Human Trafficking Report

Are grants awarded based on a clear competitive process that includes a qualified assessment of merit?

Explanation: Grants are awarded through a competitive process, in which the program office seeks to advertise widely the grant opportunity, in addition to publication in the Federal Register and web postings. Evaluations are made by an external (non-Federal) panel of practitioners and experts. Grant review panels were convened utilizing exclusively non-federal personnel (persons with expertise in trafficking or other aspects of direct contact outreach). Panelists reviewed the proposals and assessed them according to the published criteria of the grant announcement. Scores for each criterion from each panelist were entered onto a spreadsheet and averaged. The average score for each proposal was standardized by panel. The resulting standardized score for all applicants was rank ordered, and in general the highest ranking applicants were funded, except that multiple projects from a single applicant nor redundant projects by geographic area and target population were funded. In addition to publishing the announcement in the Federal Register and posting notices on ACF websites, notices were emailed to a list of Faith-Based organizations maintained by the HHS Office of Faith-Based and Community Initiatives, to internal contacts lists, and to several "listserves" on trafficking, operated by the Salvation Army, and individual issue activists.

Evidence: Check Document "Office of Refugee Resettlement Grants for Outreach To Target Populations Under Trafficking in Persons Program" published at the Federal Register. It is under the Tab 3

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: The program engages in significant monitoring activities of all partners. In addition, the program retained a firm to conduct a systematic analysis of all reports provided by grantees, and to conduct some site visits. The product of that analysis is a comprehensive guide to the activities, strengths and potential weaknesses of grantees. The greatest material weakness identified by this analysis is the frequent lack of quantitative measures of grantee performance, a weakness the program has moved to address through consultations and negotiations with the class of new grantees, so that clear, quantifiable performance measures will be in place from the outset of the grant (other grants were put in place prior to the tenure of the current program management). The program holds an annual consultation with grantees in Washington, to provide information sharing opportunities and to enhance grantee performance. The program conducts monthly consultations with grant offices at DOJ, to share information about common grantees and to talk through other grant issues. The program participates frequently in trainings conducted by grantees, and so has the opportunity of monitoring their public education activities. The program engages grantees in the "Rescue and Restore" launch cities to play a substantial role as the first-responder for victim services and as the convener of the local anti-trafficking coalitions. This entails close collaboration between the program, the contractors, and the grantees, during which grantee performance is closely observed.

Evidence: Calvin Edward Report/ Grantees Consultation/ On site Visits

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: While reports from all grantees are received semi-annually, they are not made available to the public in a transparent and meaningufl manner. As the structure of the program evolves (going from grants to contracting mechanisms), the program will prepare annual reports regarding the participation of new organizations in the service providing system.

Evidence: Calvin Edward Report/ Grantees Consultation/ On site Visits

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: Number of victims certified: FY02: 99; FY03: 151; FY04: 163. The above data for number of victims certified indicates that the program has already made strides toward achieving greater numbers of victims certified. By the measure of victim certifications, the program is on track to double the number of victims being served, current fiscal year versus last fiscal year (fiscal year through March '05 certifications are 109 versus 163 for FY04, and we have already equaled last year's number of juvenile victims being enrolled for services). In addition, since April 04, when we launched the Rescue and Restore Campaign we more than doubled the number of victims found and certified, compared to the previous year. We identified 228 victims from April 04 to March 05, compare with only 108 from April 03 to March 04.

Evidence: Check Ketchum Human Trafficking Report

Does the program (including program partners) achieve its annual performance goals?

Explanation: "See the response to 4.1 above. During FY04 and FY05 year-to-date, we have fully met our goals for the implementation of the "Rescue and Restore" awareness campaign. Actually, in terms of outputs, this campaign has either met or substantially exceeded our initial expectations. In the previous 12 months (which coincides with the initiation of the "Rescue and Restore" campaign, May 04-April 05), 224 victims were certified, which exceeds the FY06 target and represents a doubling of the number of victims certified over the previous 12 month periods. The current percentage of victims achieving self-sufficiency within a year is at the FY06 target level - there was no FY05 target articulated because this outcome measure is newly imposed. "

Evidence: Check Ketchum Human Trafficking Report

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: Number of victims certified: FY03: 151; FY04: 163; April 03 - March 04: 108; April 04 - March 05 (Rescue and Restore begins): 224. Using the method of calculation for the efficiency measure: FY03 efficiency = 151 victims/$10 million in program funding = 15 victims per million dollars invested. FY04 efficiency = 163 victims/$10 million in program funding = 16 victims per million invested. Efficiency between April 2003 and March 2004 = 108/$10 million in program funding = 11 victims per million invested. Efficiency between April 2004 and March 2005 (period since inception of Rescue and Restore Campaign) = 233 victims/ $10 million in program funding = 22 victims per million invested. Since the Rescue and Restore campaign was instituted in April 2004, the program has already seen major efficiency gains. The calculation above using the number of victims certified in the twelve months before and after the Rescue and Restore Campaign began demonstrates that the program has made significant efficiency gains.

Evidence: Statement of Work for the Public Awareness Campaign contract, State of Work for the Per Capita Contract/ Announcement of the Outreach Grants

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The most analogous programs which involve the identification, rescue and assistance for victims of a major crime are domestic violence and child exploitation. Yet these programs are much older, better established, and consist of huge networks of participating agencies and entities. The human trafficking program is dissimilar from these programs because it is still in a start-up phase. However, a comparison of the histories of these programs would show the human trafficking program is off to a much faster start in terms of generating broad societal visibility and involvement in the effort. The program received the Silver Anvil, which is awarded by the Public Relations Society of America (PRSA), and is one of the most respected awards in the public relations industry as well as the SABRE Award, which is given by The Holmes Group in recognition of superior achievement in public relations efforts that demonstrate excellence in innovation, integrity and effectiveness.

Evidence: PART for Family Violence Prevention Program. "Campaign to Aid Victims of Human Trafficking Wins Award" {www.acf.hhs.gov/news/press/2005/SABRE.htm} "Public Relations Society of America Silver Anvil Awarded to HHS Awareness Campaign on Human Trafficking" {www.acf.hhs.gov/news/press/2005/Silver_Anvil.htm}

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: In general, the role of an independent evaluation is to determine program effectiveness and impact. In the case of Human Trafficking, progress on the two outcome measures proposed above would indicate whether the program is effective in meeting its goals of certification and self-sufficiency. In addition, progress on the certification efficiency measure would indicate a streamlining of processes. Potential independent evaluations would therefore only be useful to the program insofar as they studied program implementation or long-term program outcomes for participants, but would likely not provide any greater understanding of program impacts, effectiveness, or efficiency. This is not to say that evaluations would be useless in the future. The Calvin Edwards evaluation, for example, assisted the program greatly in strategizing about better service delivery models and management practices. The report indicated that the Human Trafficking program had achieved positive results throughout the country, and pointed to generalizable best practices. Program evaluations at this point would be most useful insofar as they study program implementation, provide data on promising practices, perform case studies of programs and victims, and perhaps make suggestions for other ways to evaluate the program in the future.

Evidence: Calvin Edward Report/ Grantees Consultation/ On site Visits