A. PURPOSES:
1. Purpose of This Study:
Bradford County Alliance for Democracy (BCAD) conducted this study in order to determine whether or not this faith-based organization was meeting its legal and contractual responsibilities and its fiduciary obligations in the expenditure of public tax monies. This is also a study of the required oversight of this faith-based program by the responsible government units and local agencies.
  An overview of federal and state funding regulations for religious organizations is provided in Appendix A1.
  No public money was used in conducting this study. Laura H. Blain did the research, she and Clark Moeller wrote this report, and Jane Moeller was the principal editor. This study was conducted between April and July of 2004.

2. Purpose of The Firm Foundation of Bradford County:    According to the website of The Firm Foundation of Bradford County on April 13, 2004 , it is "a Faith based, non-profit organization committed to assisting prison over crowding, and lowering recidivism through innovative programming, community support, and partnering with other organizations, churches, and individuals."
  Under "Our belief," the website of Firm Foundation of Bradford County states, "This program is based on the belief that lives are changed as hearts become open to Faith. The administration, trainers, and staff have committed their lives to this belief and are examples of Jesus Christ the Lord."

3. Purpose of Bradford County Alliance for Democracy (BCAD):    BCAD is an informal group of citizens who have worked to improve the quality of life, civil rights, responsible newspaper reporting, church-state separation, and governance in our county.
  Among the policies adopted by BCAD in 1996 was the policy: "BCAD will work to educate and inform citizens about sectarian and political groups, public officials, or political candidates who attempt to impose religious ideology on community, state, or federal government and educational institutions in a manner that violates the separation of church and state."

B. METHOD OF STUDY

The method and organization of this study were driven by three questions:

1. What were the legal performance standards that should have been guiding Firm Foundation's activities? These include the First Amendment of the Constitution of the U.S., legislative or administrative regulations, contract specifications, stated standards, goals, and objectives relevant to the contracts of Firm Foundation of Bradford County. These were reviewed by BCAD. 2. How did Firm Foundation's performance conform to these standards? BCAD examined all of the relevant documentation of performance and fiscal reporting we could obtain from Firm Foundation and other relevant agencies, and collected information obtained in interviews. 3. Who and what agencies had oversight responsibilities for protecting the public's interest in regard to Firm Foundation's activities? The Executive Director of Firm Foundation was Wayne Blow until July 15, 2004. He has had the direct responsibility for the performance of Firm Foundation. He is responsible to a volunteer Board of Directors who include Les Bresee, Bill McBratney, Richard Friend, and Wayne Blow himself, who is listed as a Board Member.   In regard to the oversight of Firm Foundation, the principal elected officials with responsibility for Firm Foundation are the Bradford County Commissioners Nancy Shrader, Janet Lewis, John Sullivan (through 12/2003), and now Doug McLinko. The local agencies which have oversight responsibility of Firm Foundation program are the Bradford County Correctional Facility, Warden Kevin Losinger; Northern Tier Regional Planning and Development Commission (NTRPDC), Executive Director Kevin Abrams; and at the state level, the Pennsylvania Commission on Crime and Delinquency (PCCD), Executive Director Carl J. Anderson.

This study is based on the answers to these questions. We compared Firm Foundation's contract obligations (#1 above) to the records of Firm Foundation's performance (#2 above), and identified which government agencies were responsible for monitoring (#3 above) Firm Foundation's performance.
  Although we have tried to be thorough in our collection and review of relevant laws, regulations, contractual agreements, and documents of performance of Firm Foundation, we have not seen all the performance related documents of Firm Foundation that should exist and which we requested as noted in Appendix A2. Nor have we had every interview we requested, as noted in Appendix A2. We are not sure that the performance documents we requested even exist.
  In addition, our method of study did not provide answers to a number of questions about why organizations behaved the way they did, and we do not speculate on these issues in this report. Our study was limited to an analysis of the discrepancies between the laws, regulations, standards and contract obligations on one hand; and on the other hand, the performance of Firm Foundation and other agencies with oversight responsibilities of Firm Foundation.

C. ORGANIZATION
Findings of fact are presented in Sections One through Four. In Section One, B and C, and Sections Four and Five, the material is organized to compare specific "performances" of Firm Foundation and other organizations to the relevant laws, agency regulations, and contract obligations which we use as "criteria." The criteria is listed first, and our documentation of performance follows.
  Conclusions and recommendations are presented in Section Six.
  Appendix A includes the few items we felt should accompany the text report. Appendix B includes all of the other supporting documentation, which includes copies of contracts, Firm Foundation reports and finances, relevant federal and state regulations. Appendix B runs about 220 pages and is bound separately.
  Cross references in the text to supporting documentation in the appendices are shown, for example, as < A1-1>, indicating page 1 in Appendix A1 at the end of this report, or < B2-101> for page 101 of Appendix B2.

Abbreviations:
  AA Alcoholics Anonymous
  BCA Bradford County Action
  BCAD Bradford County Alliance for Democracy
  BCC Bradford County Commissioners
  BCCF Bradford County Correctional Facility
  DCSI Drug Control and System Improvement
  DOJ Department of Justice
  DOL Department of Labor
  FF Firm Foundation
  HUD Housing and Urban Development
  NA Narcotics Anonymous
  NLC New Life Church
  NLM New Life Ministries
  NTRPDC Northern Tier Regional Planning and Development Commission
  PCCD Pennsylvania Commission on Crime & Delinquency
  RFP Request for Proposals
  WIB Workforce Investment Board