Public Assistance Grants

FEMA did not use its SFM initiative to ensure that Public Assistance (PA) funds were obligated in accordance with Federal, Department, and component requirements.  Specifically, FEMA obligated PA funds for 83 projects from fiscal years 2017 through 2019 that we reviewed, even though the subrecipients did not need the funding until after 180 days, which made them eligible for incremental obligation under SFM.  This occurred because FEMA did not provide adequate oversight to its Regions.  FEMA relied on the Regions’ decisions to determine whether subrecipients’ projects were eligible for SFM funding, without ensuring there was sufficient supporting documentation to validate the determinations.  This increases the risk of projects being over obligated.  As a result, FEMA is not meeting the intent of SFM, which is to better manage resources in the Disaster Relief Fund to fulfill present and future disaster funding requirements.  We made two recommendations that, when implemented, should improve FEMA’s management and oversight of the Disaster Relief Fund.  FEMA concurred with the recommendations. 

FEMA did not ensure Louisiana adequately managed and provided oversight of PA grants to make certain they complied with Federal regulations.  Specifically, Louisiana had a backlog of 600 incomplete projects beyond their approved completion dates.  We attributed this to the State not conducting regular site visits to assess subrecipients’ ongoing projects, identify and resolve issues as they arose, or ensure prompt project completion.  In addition, FEMA had a backlog of 2,150 completed grant projects it had not closed out due to inadequate oversight of its Region 6 staff to ensure they promptly carried out this responsibility.  As of the fourth quarter of 2018, the combined backlog of 2,750 grant projects represented nearly $6.6 billion in obligated funds.  By May 2020, FEMA had reduced the backlog, but the significant number of remaining projects could lead to delays reimbursing applicants as well as deobligating funds that could be put to better use.  We made three recommendations to FEMA to strengthen its oversight of project completion and closeout processes to ensure they are timely and compliant.  FEMA concurred with one recommendation and did not concur with two.  However, FEMA’s responses resulted in all three recommendations being considered open and unresolved.

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. 

Williams-Adley determined that the Federal Emergency Management Agency (FEMA) did not always ensure that Department of Transportation and Public Works (DTOP) established and implemented policies, procedures, and practices to account for and expend PA grant funds according to Federal regulations and FEMA guidance.  Specifically, DTOP did not have (1) an effective grants management process; (2) sufficient internal controls in the procurement process; and (3) sufficient controls over its processes for claiming Force Account Labor costs.  This occurred because FEMA and Central Office of Recovery, Reconstruction and Resiliency (COR3) did not adequately oversee DTOP’s grant management activities.  We made three recommendations to improve COR3’s and DTOP’s management of FEMA Public Assistance funds, ensuring they are expended according to Federal regulations and FEMA guidance.  FEMA concurred with the recommendations.

Williams-Adley determined that the Federal Emergency Management Agency (FEMA) did not ensure the Puerto Rico Central Office of Recovery, Reconstruction, and Resiliency (COR3) and the Puerto Rico Aqueduct and Sewer Authority (PRASA) establish and implement policies, procedures, and practices to account for and expend Public Assistance (PA) grant funds according to Federal regulations and FEMA guidance.  Specifically, PRASA did not follow established policies and procedures for: (1) recording the capacity size and rate of its force account equipment; and (2) ensuring each vendor had a certificate of eligibility before receiving a contract award.  We made two recommendations to improve PRASA’s management of FEMA PA funds, ensuring they are expended according to Federal regulations and FEMA guidance.

Colorado’s Department of Public Safety, Division of Homeland Security and Emergency Management (Colorado) did not effectively oversee its subrecipient, Frasier Meadows, to ensure it was aware of and followed Federal procurement regulations and Federal Emergency Management Agency (FEMA) guidelines.  In addition, FEMA should have ensured Colorado delivered assistance to Frasier Meadows consistent with the FEMA-State Agreement and the State Administrative Plan.  We recommended the Regional Administrator, FEMA Region VIII, disallow $5.57 million for contracts and direct Colorado to work with Frasier Meadows officials to ensure they implement their updated Federal procurement policies and procedures in the event of a future disaster.  FEMA officials agreed with both recommendations.  Prior to final issuance of this report, FEMA took action to resolve and close both recommendations.  No further action is required.

We verified that Refugio County, Texas awarded contracts that complied with Federal procurement regulations and FEMA guidelines.  We determined that the County initially did not have written procurement policies to comply with all Federal procurement regulations.  Instead, for purchases and contracting, County officials said they followed Texas Local Government Code, Chapter 262.  In response to our audit, the County adopted written procurement procedures to comply with Federal requirements.  The report contains no recommendations.  FEMA did not submit a formal response to our draft report, but informally replied that it did not identify any issues requiring further action by FEMA.