PA 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. 

We contracted this audit with Cotton & Company LLP, which found FEMA did not ensure Collier County, Florida (the County) established and implemented policies, procedures, and practices to account for and expend Public Assistance (PA) program grant funds awarded in disaster areas in accordance with Federal regulations and FEMA guidance.  Specifically, the County could not provide documentation to support $4,602 in force account costs claimed.  Additionally, the subrecipient monitoring process needs improvement.  The State has not evaluated the risk of subrecipients’ noncompliance with Federal requirements, obtained subrecipient audit reports, or developed plans for monitoring subrecipients.  We made four recommendations that, when implemented, should improve Collier County, Florida’s management of FEMA PA funds.  FEMA concurred with our four 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

Weld County, Colorado did not always follow Federal procurement standards in awarding contracts for disaster work.  As a result of our review, we identified and discussed with FEMA various areas where it should review and adjust for cost reasonableness the funding amounts that a project and program management contractor charged related to Weld County.  FEMA agreed to review the costs for reasonableness, unless if FEMA disallowed all of the costs for procurement violations.  We subsequently reviewed FEMA’s cost analysis documentation for Weld County project closeouts related to this disaster.  We found that FEMA appropriately reduced final project amounts due to improper procurements and cost reasonableness concerns, including unreasonable contractor hourly rates.  Consequently, made no recommendations. 

At the time of our onsite work in July 2017, Box Elder County had not awarded any contracts under this grant. Therefore, we could not determine whether the County had complied with Federal procurement regulations. However, in reviewing Box Elder County’s written procurement policies and procedures we noted the County did not include procedures to ensure opportunities for small and minority businesses, women’s business enterprises, and labor surplus area firms to bid for federally funded work.  In addition, Box Elder County’s procurement policies did not require federally mandated provisions be incorporated in all contracts funded by Federal grants.  In response to our review, Box Elder County revised its procurement policies and procedures to include these Federal procurement requirements.  Consequently, we made no recommendations.

In two of the four areas – training and collaboration – Washington’s Emergency Management Division (EMD) and FEMA complied with applicable policies, procedures, and regulations.  In the third functional area – project execution, monitoring and oversight – we did not identify any significant deficiencies.  We found, however, EMD lacked position-specific guidance for all personnel with programmatic responsibilities.  In the last functional area – project and grant closeout – neither EMD nor its subrecipients submitted timely project closeout requests.  In addition, FEMA did not enforce compliance with its own guidance for processing closeouts.  We recommended FEMA ensure EMD complies with its State Administrative Plan by issuing and regularly updating desk manuals.  In addition, we recommended FEMA coordinate with EMD to initiate closeout on behalf of subrecipients for all open, large projects whose period of performance end dates exceed the 90-day regulatory requirement, and submit closeout requests to FEMA for projects exceeding the 180-day requirement.  We made five recommendations to strengthen EMD’s internal controls to improve its oversight of FEMA’s Public Assistance grant program.  FEMA concurred with all five of our recommendations.