Public Assistance Grant

This report provides a summary of our previous findings and recommendations, which may inform future disaster response efforts.  Based on our prior work, we identified a pattern of internal control vulnerabilities that negatively affect both disaster survivors and disaster program effectiveness that may hinder future response efforts, including shortcomings in acquisition and contracting controls, interagency coordination challenges, and insufficient privacy safeguards that affect disaster survivors.  Additionally, FEMA did not adequately oversee disaster grant recipients and subrecipients, manage disaster assistance funds, or oversee its information technology environment.  This report discusses these vulnerabilities and the correlating recommendations we previously made that, if implemented, would better prepare FEMA to respond to future disasters.  We made no new 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 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 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. 

The Federal Emergency Management Agency (FEMA) Missouri, and Joplin Schools did not properly manage and oversee this disaster award.  Specifically, FEMA and Missouri did not provide proper grant management and oversight of Joplin’s subgrant activities.  Joplin Schools disregarded Missouri’s authority as the grantee and did not always comply with Federal requirements and FEMA policies as required.  This occurred because Joplin Schools heavily relied on the advice of its grant management contractor.  As a result of the grant management and oversight issues, Joplin Schools did not follow Federal procurement standards when it awarded $187.3 million in non-exigent disaster-related contracts, including $609,676 in ineligible contractor direct administrative costs.  We provided five recommendations to help improve FEMA and Missouri’s grant oversight and management process.  We also included four recommendations for FEMA to disallow or not fund $187.3 million in ineligible contract costs.  FEMA determined approximately $56 million, the net obligated amount, was eligible for reimbursement.  FEMA concurred with all nine recommendations and completed actions to close recommendations 1 to 4 and 8.  Recommendations 5 to 7 are resolved and open with a target completion date of June 1, 2020. Recommendation 9 is considered unresolved and open

Harris County, Texas needs additional technical assistance and monitoring to ensure grants management comply with Federal procurement regulations.  The County’s procurement policies, procedures, and business practices were not adequate to expend disaster grant funds in accordance with Federal procurement regulations and Federal Emergency Management Agency (FEMA) guidelines.  We recommended FEMA disallow $2.7 million in ineligible costs and require Texas to work with the County to incorporate Federal procurement regulations when using Federal funds, and review procurement activities before the County awards future contracts.  We made three recommendations that will help improve the procurement capability of Harris County, Texas.  FEMA concurred with all three recommendations. 

FEMA needs to continue providing technical assistance to and monitoring of California’s Public Assistance grant funding management.  This helps avoid the risk of exposing millions of taxpayer dollars to fraud, waste, or mismanagement and violating the Robert T. Stafford Disaster Relief and Emergency Assistance Act. In doing so, FEMA can assist California in providing reasonable, but not absolute assurance that Public Assistance subgrant funds are spent in accordance with Federal regulations and FEMA guidelines.