FEMA

As of October 2016, the Recovery School District in Louisiana (RSD) had received a $1.5 billion Public Assistance grant from Louisiana, a Federal Emergency Management Agency (FEMA) grantee, for damages resulting from Hurricane Katrina.  We examined $1.3 billion for a consolidated project as part of the total amount awarded.  In some instances, RSD accounted for and expended portions of the $1.3 billion in Public Assistance grant funds we reviewed according to Federal regulations.  However, FEMA improperly awarded $216.2 million to repair or replace more than 292 Orleans Parish school facilities in RSD.  We made eight recommendations to FEMA to de-obligate $216.2 million of ineligible costs; follow Federal regulations and FEMA guidelines; and re-evaluate documented proof of assessments for the 35 identified projects and reclassify them, as appropriate, to repair-eligible, and de-obligate the cost difference.  FEMA concurred with recommendations 2 through 7 but did not concur with recommendations 1 and 8.  We consider recommendations 2 through 7 resolved and open; recommendations 1 and 8 are unresolved and open.

The Federal Emergency Management Agency (FEMA) is not adequately managing severe repetitive loss (SRL) properties covered by the National Flood Insurance Program (NFIP).  FEMA has not established an effective program to reduce or eliminate damage to SRL properties and disruption to life caused by the repeated flooding.  Primarily, FEMA does not have reliable, accurate information about SRL properties.  Secondly, FEMA’s Flood Mitigation Assistance (FMA) program, which aims to mitigate flood damage for NFIP policyholders, provides neither equitable nor timely relief for SRL applicants.  We made three recommendations to FEMA to ensure the accuracy of the SRL list, as well as equitable and timely distribution of mitigation funding, and promoting the use of National Flood Insurance Program (NFIP) Increased Cost of Compliance coverage.  FEMA concurred with all three of the recommendations

The Federal Emergency Management Agency’s (FEMA) Individuals and Households Program (IHP) has no assurance of applicants’ eligibility for Small Business Administration (SBA) Dependent Other Needs Assistance (ONA) payments.  According to OMB Circular A-123, Appendix C, when documentation or verification is non-existent to support eligibility payment decisions it must be considered improper.  FEMA did not collect sufficient income and dependent documentation or verify self-reported information to determine whether applicants below the income threshold, known as Failed Income Test (FIT), were eligible for SBA Dependent ONA payments.  FEMA believed requiring documentation or verification would delay the disbursement of assistance and relied on an honor system to make eligibility and payment decisions.  We determined, according to FEMA-provided data, it has paid, and we are questioning, the more than $3.3 billion in improper payments to applicants deemed as FIT for SBA Dependent ONA since 2003.  Additionally, FEMA has not evaluated the program risk associated with not collecting or verifying income information.  Per Federal requirements, agencies must conduct risk assessments to determine whether programs are susceptible to improper payments.  Rather, FEMA assessed IHP at the overall program level and did not specifically evaluate each IHP form of assistance, such as SBA Dependent ONA.  These weaknesses have allowed applicants self-certifying income and dependent information to receive less oversight, despite posing the greatest risk for improper payments.  FEMA cannot assure Congress and taxpayers it is a prudent steward of Federal resources, and adequately assesses the risks of improper payments.  FEMA did not concur with all three report recommendations.  Therefore, these recommendations are considered unresolved and open.

We identified debris removal contract performance issues and concerns.  In the report, we discuss our observations regarding the use of pre-disaster debris removal contracts in Florida following Hurricane Irma.  We also emphasize how FEMA can benefit from implementing effective controls to track systemic issues after a disaster and ensure FEMA follows procedures for uploading required documentation to support debris removal costs for proper grant management.  The report contains no recommendations.

The Federal Emergency Management Agency did not properly award or oversee its contract with Corporate Lodging Consultants (CLC) to administer disaster survivors’ hotel stays.  These deficiencies occurred because FEMA officials did not ensure staff responsible for the Transitional Sheltering Assistance (TSA) contract award and oversight had the guidance and training they needed to be effective.  As a result, FEMA released personally identifiable information for about 2.3 million disaster survivors, increasing the survivors’ risk to identity theft.  We made six recommendations that when implemented should strengthen FEMA contracting and compliance with Federal Acquisition Regulations and DHS requirements.  FEMA concurred with all six of our recommendations.

The Puerto Rico Electric Power Authority (PREPA) complied with Federal procurement requirements for its noncompetitive procurement of the Whitefish contract.  However, the contract costs may not have complied with Federal cost principles that costs must be reasonable to be eligible for Federal awards.  PREPA’s oversight of the Cobra contract did not comply with PA program guidelines.  Finally, FEMA’s Public Assistance grant to PREPA for the Cobra contract did not fully comply with PA program guidelines.  We made two recommendations for FEMA to provide technical assistance to Puerto Rico to ensure compliance with Federal regulations and PA program guidelines.  We made two other recommendations for FEMA to develop guidance to verify its subrecipients’ oversight of time and material contracts and determine the reasonableness and eligibility of time and material contract costs.  FEMA concurred with three of the recommendations and did not concur with one recommendation.

We contracted this audit with Cotton & Company LLP, which found that FEMA did not ensure the Florida Department of Emergency Management (FDEM) monitored the Polk County School Board (PCSB) to ensure it established and implemented policies, procedures, and practices to account for and expend PA grant funding in accordance with Federal regulations and FEMA guidance.  For example, PCSB was unable to support $46,168 in food spoilage costs; requested and received funding through a Florida Public Assistance grant for ineligible contract costs incurred under Project 2658 for debris removal and related costs; and charged $897 in unallowable costs associated with ineligible fringe benefits for substitute employees.  We made 13 recommendations that, when implemented, should improve PCSB’s management of FEMA Public Assistance funds.  FEMA concurred with our 13 recommendations.

We contracted this audit with Cotton & Company LLP, which found that FEMA did not ensure Monroe County, Florida (the County) established and implemented policies, procedures, and practices to ensure it accounted for and expended Public Assistance program grant funds awarded to disaster areas in accordance with Federal regulations and FEMA guidance.  Specifically, the County did not allocate anticipated and actual insurance proceeds totaling $5 million to reduce FEMA’s share of disaster costs; charged $265,928 for ineligible stand-by time and other ineligible expenses; and requested $84,681 in unsupported and ineligible costs for multiple tasks including clearing emergency access and costs related to flooding.  Additionally, the County overstated $34,378 in force account labor costs that were unreasonable and therefore ineligible for grant funding; overpaid a debris removal contractor, resulting in $2,403 in ineligible costs; and charged $1,080 to PW 1512 for security costs that were unsupported and are therefore ineligible for grant funding. We made 18 recommendations that that, when implemented, should improve Monroe County, Florida’s management of FEMA Public Assistance funds.  FEMA concurred with our 18 recommendations.

We contracted this audit with Cotton & Company LLP, which found that FEMA did not ensure Lee County, Florida (the County) established and implemented policies, procedures, and practices to ensure it accounted for and expended PA program grant funds awarded to disaster areas in accordance with Federal regulations and FEMA guidance.  Specifically, the County requested FEMA funding for $994,425 in unsupported force account labor, equipment, and materials; was unable to provide supporting documentation for $16,210 in costs incurred to operate an emergency shelter; did not maintain adequate documentation to support $267,452 in costs incurred for road repair services; did not include all required provisions in its contracts to obtain disaster recovery services related to Hurricane Irma; and had not evaluated the risk of subrecipients’ noncompliance with Federal requirements, obtained subrecipient audit reports, or developed plans for monitoring subrecipients.  We made nine recommendations that, when implemented, should improve Lee County, Florida’s management of FEMA Public Assistance funds.  FEMA concurred with all nine recommendations.

We determined that the city of Houston has adequate policies, procedures, and business practices that comply with Federal procurement regulations and FEMA guidelines to expend FEMA grant funds.  We found Houston may have inappropriately included the $73.8 million cost of Houston First Corporation’s (Houston First) disaster damages in its damage estimate, even though it was not an eligible applicant for them.  We did not examine procurement policies and procedures related to Houston First because the entity was outside the scope of our audit.  During the audit, FEMA acknowledged it would reiterate in writing to the City of Houston the importance of proper oversight for all procurements executed by Houston First.  This report contains no recommendations.