FEMA Initiated the Hurricane Harvey Direct Housing Assistance Agreement without Necessary Processes and Controls

FEMA’s Intergovernmental Service Agreement (IGSA) with the Texas General Land Office (TxGLO) was appropriate to ensure direct housing assistance program compliance with applicable laws and regulations.  However, FEMA initiated the IGSA without first developing the processes and controls TxGLO needed to administer the program.  As a result, FEMA and the State had to develop and finalize implementation guidelines after signing the IGSA, delaying TxGLO’s disaster response.  In addition, FEMA disaster personnel had to prepare the necessary guidance, toolkits, and training resources while simultaneously responding to Hurricane Harvey.  Also, FEMA used workarounds and TxGLO set up a separate system, creating additional operational challenges and inefficiencies.  We made three recommendations to improve future state administered direct housing assistance efforts.  FEMA concurred with all three recommendations.