Oregon

Under 40 U.S.C. § 1315, DHS had the legal authority to designate and deploy DHS law enforcement officers from CBP, ICE and United States Secret Service to help the Federal Protective Service protect Federal facilities in Portland, Oregon.  However, DHS was unprepared to effectively execute cross-component activities to protect Federal facilities when component law enforcement officers first deployed on June 4, 2020.  Specifically, not all officers completed required training; had the necessary equipment; or used consistent uniforms, devices, and operational tactics when responding to the events in Portland.  This occurred because DHS did not have a comprehensive strategy that addressed the potential for limited state and local law enforcement assistance, and cross-designation policies, processes, equipment, and training requirements.  We made two recommendations to improve DHS’ preparedness for protecting Federal property.  DHS concurred with both recommendations.

We could not fully assess whether Oregon’s State Administrative Agency (OEM) expenditures for State Homeland Security Program (SHSP) and Urban Areas Security Initiative (UASI) funding awarded from FY 2013 through FY 2015 enhanced its preparedness and security because we found some issues. These issues occurred because OEM did not obtain written consent when withholding more than 20 percent of funds, coordinate with subrecipients after award receipt, have approved indirect cost rate agreements, adhere to its subrecipient monitoring procedures, have a tracking system, or provide guidance to subrecipients. FEMA concurred with all 10 recommendations and plans to take corrective action.

We conducted this audit early in the Public Assistance process to identify areas where the Department may need additional technical assistance, or monitoring to ensure compliance, before improperly expending any of the Federal grant funds.  We determined if the Department conforms to its policies, procedures, and business practices, FEMA has reasonable assurance, but not absolute, that the Department will properly manage the Public Assistance grant funds it receives. During our audit, we determined the Department did not always use the lowest of FEMA and local rates for equipment costs.  Department officials agreed with this finding and took immediate corrective action by notifying Oregon that they would revise and resubmit payment reimbursement claims with correct equipment rate costs.  The Department has revised its procurement procedures for small contracts to include affirmative steps and assure the use of DBEs when possible, as 2 CFR 200.321 requires.  We are not requiring any further action from FEMA, therefore we consider this audit closed. 

We determined the City has established adequate policies, procedures, and business practices to account for and expend Public Assistance grant funds according to Federal regulations and FEMA guidelines. Therefore, if the City follows its policies, procedures, and business practices it has in place, FEMA has reasonable, but not absolute assurance, that the City will properly manage the Public Assistance grant funds it receives. We did not identify any reportable issues and consider this audit closed.

We determined that the Columbia County Roads Department (Department) does not have written procurement policies and procedures that fully conform to Federal procurement standards; is not accounting for direct administrative costs properly; and cannot yet initiate large permanent work projects more than 9 months after the disaster.  These findings occurred because Department officials were not familiar with applicable Federal regulations and FEMA guidelines adequately.  In addition, the Oregon Office of Emergency Management (Oregon) is responsible for ensuring that its subrecipient,the Department, is aware of and complies with these requirements, as well as for providing technical assistance and monitoring grant activities.  Because of our audit, the Department is revising its policies and procedures to comply with Federal requirements.  However, the Department needs additional, ongoing assistance from Oregon and FEMA to ensure that it properly manages the $2 million FEMA grant it expects to receive.  Therefore, we recommended that FEMA disallow contract costs that do not comply with applicable Federal procurement standards, unless FEMA grants an exception to the administrative requirements as 2 CFR 200.102 allows and determines the costs are reasonable.  The OIG made three other recommendations to FEMA related to directing Oregon, as its grant recipient, to provide increased monitoring and technical assistance to the Department, to ensure the Department follows Federal regulations and FEMA guidelines and avoids misspending its $2 million grant award.