debris removal

We determined that FEMA did not ensure procurements and costs for debris removal operations in Monroe County, Florida, met Federal requirements and FEMA guidelines.  Specifically, FEMA did not adequately review local entities’ procurements for debris removal projects and reimbursed local entities for questionable costs.  These deficiencies were due to weaknesses in FEMA training and its quality assurance process.  As a result, FEMA approved reimbursement to local entities for nearly $25.6 million (more than $23 million in Federal share) for debris removal projects, including contracts that may not have met Federal procurement requirements, and more than $2 million in questionable costs.  Without improvements to FEMA’s training and project review processes, FEMA risks continuing to expose millions of dollars in disaster relief funds to fraud, waste, and abuse.  We made three recommendations with which FEMA officials concurred.  Based on the information FEMA provided, we consider the three recommendations resolved and open.

We identified debris removal contract performance issues and concerns.  In the report, we discuss our observations regarding the use of pre-disaster debris removal contracts in Florida following Hurricane Irma.  We also emphasize how FEMA can benefit from implementing effective controls to track systemic issues after a disaster and ensure FEMA follows procedures for uploading required documentation to support debris removal costs for proper grant management.  The report contains no recommendations.

The Federal Emergency Management Agency (FEMA), through its Public Assistance (PA) Program, is currently responding to Hurricane Irma — one of the most catastrophic disasters in recent United States history.  FEMA’s damage estimates for Florida and Georgia exceed $4.2 billion, with debris removal operations constituting approximately 36 percent of the total PA cost.  Debris removal costs in Florida and Georgia are estimated to reach approximately $1.5 billion as of May 2018.  FEMA’s guidance for debris monitoring lacks sufficient information to ensure adequate oversight.  In the 2011 OIG report, FEMA’s Oversight and Management of Debris Removal Operations, we identified deficiencies in FEMA’s debris removal guidance.  To resolve these deficiencies, we made 10 recommendations to, in part, strengthen FEMA’s debris removal guidance and procedure.  In response, FEMA released additional criteria pertaining to debris estimating and monitoring to enhance the overall effectiveness of the process.  FEMA removed the detailed responsibilities when it released its Public Assistance Program and Policy Guide (PAPPG).  Going forward from the PAPPG version 1.0, FEMA relies solely on the subrecipient to monitor the debris removal operations, and removes monitoring responsibilities from both FEMA and the State.  Subrecipients now have a greater responsibility to identify issues or concerns during debris removal operations.  We made three recommendations that when implemented will strengthen FEMA’s debris monitoring operations.  FEMA concurred with all recommendations.

The purpose of this advisory report is to notify FEMA of an issue we observed during our ongoing audit of CalRecycle.  We determined that CalRecycle expects it will cost about $230 million to complete debris removal work, and has received invoices totaling $200 million from two contractors performing the work.  Yet, these invoices included documentation with numerous discrepancies that did not fully support the invoiced costs as Federal cost principles and procurement standards require.  Moreover, as of September 8, 2016, our audit cutoff date, CalRecycle had paid its contractors about $186.4 million of the $200 million in invoiced costs, but had not completed its review of invoices nor collected all missing support records.   FEMA and California, therefore, should continue to assist CalRecycle in assuring that all costs are valid and eligible.  We recommended that FEMA Region IX Administrator (1) direct California, as grantee, to provide CalRecycle with technical assistance it may need to ensure compliance with all applicable Federal regulations, specifically for document support and contract management, and to avoid improperly funding any of the $230 million ($173 million Federal share) in contract costs CalRecycle estimates it will claim for damages caused by this disaster; and (2) direct California, as grantee, to ensure that all CalRecycle’s cost reimbursement claims for debris removal work are supported with adequate documentation and that costs are eligible in accordance with FEMA’s debris removal guidelines.