By Amanda Kass and Philip Rocco
Since 2021, the Biden administration has encouraged state and local governments to invest dollars from the State and Local Fiscal Recovery Funds Program (SLFRF) – part of the American Rescue Plan Act – in novel programs to address gun violence. These programs range from community-based violence intervention programs (CVIs) to long-term violence prevention strategies. Importantly, community violence intervention is, according to the Bureau of Justice Assistance, “an approach that uses evidence-informed strategies to reduce violence through tailored community-centered initiatives.” CVI strategies target a specific type of violence: community violence, which is interpersonal violence that occurs outside the home and excludes nonlethal and nonphysical forms of violence. Within the U.S. context, community violence often takes shape as hyper-localized patterns of gun violence.
Over the last year, we have been analyzing how governments around the country are using SLFRF dollars to support CVIs, as well how officials build support for launching these policy innovations at the local level.
As part of the SLFRF program governments must report their planned and actual spending to the Treasury Department. Governments report spending at the project level, and every project must be assigned to a spending category. The Treasury Department created the spending categories, and one of the spending categories is “Community Violence Interventions.” That spending category is for projects aimed at preventing and responding to violence (see p. 15 of this Treasury document).
In aggregate, state and local investments of SLFRF dollars to the CVI spending category have been limited. As of the end of 2022, states, territories, metropolitan cities, and the District of Columbia reported spending $229 million on projects coded with the CVI spending category, less than 0.1% of their total SLFRF allocations. Adopted budgets for that spending category – a figure that represents all planned spending that will take place over the course of the SLFRF program’s lifespan – totaled to $1.6 billion, which is roughly 0.5% of the total SLFRF allocations for these governments.
| Gov Tier/Type | Total Allocation | CVI Adopted Budget as of Q4 2022 | CVI Expenditures as of Q4 2022 | Budget as % Total | Expenditures as % Total |
| States/DC | $195,809,942,817 | $811,640,337 | $82,097,907 | 0.4% | 0.0% |
| Territories | $4,547,688,548 | $13,415,515 | $23,349 | 0.3% | 0.0% |
| Tier 1 & 2 City/County Governments | $100,898,399,824 | $763,121,994 | $147,125,776 | 0.8% | 0.1% |
| Total | $301,256,031,189 | $1,588,177,846 | $229,247,024 | 0.5% | 0.1% |
Note: This table contains information only for the 1,962 governments that were included in the SLFRF dataset that covers the January 2023 reporting cycle. Data as of March 31, 2023 Local governments in tiers 1 and 2 include metropolitan cities and counties with populations of at least 250,000 as well as governments which have been allocated at least $10 million in CSLFRF are in reporting tiers 1 and 2. We exclude “Tier 5” local governments—cities and counties with populations less than 250,000 and receiving less than $10 million in CSLFRF aid––because they are not required to report projects on a quarterly basis and were not included in the dataset the Treasury Department released for the fourth quarter of 2022.
While the Treasury Department category is labeled as “community violence intervention”, governments may be interpreting it as being inclusive of any spending tied to preventing and responding to any form of violence. As a result, projects in the CVI spending category may not actually be community violence intervention tactics. In fact, $56 million of expenditures classified by state and local governments under the CVI spending category went to support measures connected to traditional law enforcement agencies and programs, including the purchase of shot spotters and sniper rifles.
The Fiscal Classification Problem
As we have noted in our analyses over the past year, the Coronavirus State and Local Fiscal Recovery Funds program is designed to give state and local governments an extraordinary level of flexibility to respond to numerous health, economic, and fiscal problems. Yet this flexibility, as our prior blog posts note, entails difficulties for monitoring the use of funds.
Arguably the most important difficulty is that of classifying how dollars are spent.
Under the initial Treasury regulations, all governments have to account for how they spend SLFRF dollars using specific expenditure categories created by the Treasury Department (see our first blog post for more on this classification system). Under the interim rules, which were in place for the spending data that covers March 2021 through December 31, 2021, there were 67 specific categories (starting in April 2022, the list has been expanded to 83 categories). Every project that recipient governments report has to be assigned to one, and only one, of the expenditure categories. Hence, a project can only be assigned to one expenditure category even if it could fall into multiple, and it is up to the recipient governments to assign an expenditure category to a project.
The distinction between some types of expenditures is obvious. One could hardly confuse expenditures on storm drains for an investment in a vaccination campaign. But not all classification decisions are so easy to make. Community violence interventions (CVIs) provide a case in point.
As mentioned above, CVI is a specific type of approach to addressing a particular form of violence. CVI initiatives involve engaging “individuals and groups to prevent and disrupt cycles of violence and retaliation, and establish relationships between individuals and community assets to deliver services that save lives, address trauma, provide opportunity, and improve the physical, social, and economic conditions that drive violence.”
Yet classifying projects as CVIs is difficult for at least three reasons. First, CVIs are internally heterogeneous. While the focus of these interventions is almost exclusively stopping gun violence before it happens (as opposed to other forms of violence), these efforts can range from “violence interrupters” such as the Cure Violence model to hospital-based interventions designed to identify and reduce risk factors for violence.
Second, community-based strategies for violence intervention are often weakly institutionalized at the state and local level. While the practice of community-based work to reduce violence has a long history, CVIs have—until recently––struggled to find enduring institutional support in local government.
Third, the Treasury Department’s guidance documents and videos for the SLFRF program do not clearly define what CVIs are and are not. In the absence of this guidance or a strongly institutionalized definition of CVIs, it is reasonable to suspect that recipient governments may have, possibly unintentionally, applied the CVI expenditure category too broadly, including both spending on traditional policing and community-based approaches.
How We Analyzed Spending Classifications
As we previously reported, states, territories, and metropolitan city and county governments spent a combined $229 million in SLFRF dollars that they categorized as CVI as of the end of 2022. Collectively, those governments also reported adopting roughly $1.6 billion in budgets for CVIs.
To see how accurate those figures really are, we performed a content analysis of the project names and descriptions for each of the 555 projects governments assigned to the CVI spending category (which covers spending between the start of the SLFRF program and end of 2022). Specifically, we noted whether project descriptions met at least one of two criteria, developed through consultation with subject-matter experts.
First, we assessed whether each project classified as “Community Violence Intervention” (Expenditure Category 1.11) proposed investing in community-driven strategies that involve at-risk or high-risk populations to reduce the incidence of violence and in an alternative to traditional policing. These strategies could include, but were not limited to, group violence interventions, community-based violence interrupters, and hospital-based interruption programs.
Second, we determined whether projects could be classified under the broader heading of community violence prevention (CVP) rather than CVI. CVP could include changes to the physical environment (e.g. Crime Prevention Through Environmental Design (CPTED), treatments such as Trauma-Focused Cognitive Behavior Therapy ®(TF-CBT) and Multisystemic Therapy®, strengthening economic supports through job training or summer youth job programs, connecting youth to caring adults and activities such as mentoring and after-school programs, as well as general income support programs.4
For those projects we did not meet our criteria for inclusion in the CVI-CVP category, we developed additional descriptive categories to capture projects aimed at supporting law enforcement agencies, support for criminal courts and individuals convicted of crimes, and victim services.
Finally, we also took note of all instances in which the project description was too vague to classify. In addition to having discretion over how to categorize projects, governments also have latitude in how much of a project description they provide. Some governments included details about the program they were using SLFRF aid for, rationale for that program, and the policy aim. Others, in contrast, gave vague descriptions and/or little information; for example, one city’s project description was simply “To be determined”.
What We Found
Our analysis suggests that state and local governments are likely incorrectly classifying a substantial number of projects as CVI (see table below). Of the 555 projects, 167 could be clearly classified as CVI or CVP. Those 167 projects have a combined budget of $761 million, which accounts for 48% of the total $1.6 billion in planned spending that governments designed as CVI. Of the $771 million in planned spending for CVI or CVP programs only 13% had been spent as of the end of 2022.
Among the projects that did not meet our criteria for either CVI or CVP, we classified 103 (representing 14% of planned spending) under the heading of victim services. This included, for example, the state of Maryland’s provision of funding to the Victims of Crime Act (VOCA) program, which “works to improve the treatment of victims of crime by providing them with the assistance and services necessary to aid their restoration after a violent criminal act, and to support and aid them as they move through the criminal justice process.” Victim services may have some ties to, or be supportive of CVI efforts; however, for the purposes of our analysis we separated these initiatives from CVI and CVP programs.
171 projects (representing 26% of total adopted budgets) were focused on support for law enforcement agencies and law enforcement activities, as the table below suggests.
| Group | # Projects | Adopted Budgets ($ Millions; As of 12/31/2022) | Total Expenditures; $ Millions (as of 12/31/2022) |
| Courts | 15 | $30.9 | $1.5 |
| CVI-CVP | 167 | $761.4 | $95.5 |
| Law Enforcement | 171 | $352.2 | $59.6 |
| Victim Services | 103 | $220.8 | $49.6 |
| Other | 78 | $105.4 | $21.6 |
| Unclear | 21 | $117.5 | $1.6 |
Making Sense of the Numbers
Again, we want to emphasize that our analysis does not necessarily point to any deliberate misreporting of data by recipient governments. Rather, the data could just as easily have emerged due to genuine confusion about how to classify spending on the part of the recipient government officials who are charged with submitting Project and Expenditure Reports. For example, jurisdictions new to CVI work occasionally use the terms prevention and intervention interchangeably, despite meaningful differences between the two types of work.
In other instances, officials may simply be classifying spending on police departments and sheriff’s offices as community violence intervention because they do not understand what CVI is. As we noted above, Treasury’s compliance documents contain no formal definition of CVIs that would help recipients distinguish spending on a narrow set of programs that address root causes of and interrupt community violence from traditional public safety measures.
In the absence of clear guidance, it is reasonable to expect governments will misclassify a nontrivial level of spending in reports to the Treasury Department, especially when, as in the case of CVIs, the boundaries of the spending category are not well defined.
The upshot of this analysis is that efforts to monitor SLFRF implementation must, at a minimum, drill beneath the surface of Treasury-provided categories to analyze what recipient governments are actually proposing to do with federal funds.
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One response to “How Have State and Local Governments Invested SLFRF Dollars in Community Violence Interventions Over the Last Two Years? ”
[…] the projects these cities classified as CVI, the picture changes. Using the methodology described here, we assessed whether each project governments classified as “Community Violence Intervention” […]
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