Analysis of GAO/OIG
Audits 2011-2014
Recovery Directorate
June 12, 2014
Executive Summary
Background
Between 2011 and early 2014, FEMA’s Recovery Directorate received 202 total audits, with 680 recommendations from
both the Government Accountability Office (GAO) and the Department of Homeland Security’s (DHS) Office of the
Inspector General (OIG). The audits objectives were to assess and improve the efficiencies and effectiveness of the
Recovery Directorate’s programs. Some audits included recommendations for corrective action, while others contained no
recommendations and praised FEMA’s actions. The subjects of the audits included FEMA Headquarters (HQ) as well as
individual Regions, Long-Term Recovery Offices (LTRO), and Transitional Recovery Offices (TRO). Further, some
audits applied to multiple federal agencies, and there was significant overlap between the various jurisdictions, especially
between the Regions and a LTRO or TRO. 1
In February 2014, the Recovery Directorate engaged in a comprehensive analysis of these 202 audits, looking at the full
text of the audit (i.e., background, findings, recommendations, etc.) as well as each recommendation individually. Each
recommendation was coded separately in order to provide a more nuanced analysis by program topic, cause, and
associated cost; the full text of the audit was analyzed because non-recommendation parts of the audit may have touched
upon Recovery-related topics that may not necessarily have been reiterated in a recommendation. The latter is especially
prevalent in audits praising FEMA’s efforts that do not contain any recommendations. 2
This analysis is not meant to be exhaustive, but rather a preview of the direction the Recovery Directorate would like to
take in its ongoing audit responsibilities. Several challenges arose during the coding process are discussed later in this
report in the Observations and Recommendations section. Key among those challenges was that information necessary for
a robust analysis was missing, incomplete, or incorrect due to various internal and external factors. One example is a lack
of a consistent and clear-cut baseline dollar amount against which to compare the amounts that GAO or OIG
recommended FEMA disallow or deobligate. 3 Another major challenge was the lack of proper coding software that would
have allowed for more direct connections; the software used for this analysis was Excel, which limited the ability of the
coding to show only correlation rather than causation. Other challenges included limited staff availability, which was
partially and temporarily addressed using a FEMA Corps team for the coding portion. The Recovery Directorate plans to
address these and other related matters in the coming months.
Results of Review
Programmatically, the audits pertained to Recovery’s Public Assistance (PA) Program, Individual Assistance (IA)
Program, and the National Processing Service Centers (NPSCs), regardless of whether the audit was assigned to HQ, a
Region, or a LTRO/TRO. Overall, an overwhelming majority of the audits and recommendations applied to the PA
Program. Of the 202 audits analyzed, 188 (93.1%) applied to PA, and 659 recommendations out of 680 (96.9%) also
applied to PA. The average questioned cost 4 per audit for PA was roughly $5.7 million, and the average cost per
1
This analysis included any audits and recommendations pertaining to the Recovery Directorate, which was determined by looking at
1) Audits officially assigned to Recovery by the Office of Policy and Program Analysis (OPPA) in their Executive Management
System (EMS); and 2) Audits officially assigned to any of the Regions or LTROs/TROs that mentioned one of Recovery’s programs
in the title or recommendations. The analysis includes audits for which Recovery (or even FEMA) was not the primary component
responsible. Any non-Recovery related recommendations in an audit were not analyzed.
2
Whether the audit had any recommendations was an important characteristic that was also analyzed and marked, as is discussed in
Appendix G (there were 27 such audits). As a subset of this, we also marked whether the audit was positive in nature (there were 16
positive audits). Finally, as will be discussed in Appendix F, there were 6 audits that are linked with related cases under a Second
Appeal before HQ.
3
As an example of the complexity of determining what the appropriate baseline would be, in OIG Report Number DA-11-13 from
April 2011, the OIG mentioned that the City of Deerfield Beach, Florida received a PA grant for $13.9 million, but the OIG only
reviewed $13.5 million; furthermore, the total amount that OIG questioned (as a sum of the seven individual recommendations) was
around $3.9 million.
4
“Questioned cost” is a term of art that encompasses all amounts at issue. OIG used “questioned cost” in a more limited sense to mean
ineligible or unsupported costs, but the term used in the coding process also includes 1) unused funds or funds FEMA should put to
better use; 2) potential savings; and 3) duplicate benefits or costs. Furthermore, the full amount of questioned costs was coded,
regardless if federal share was mentioned.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
2 of 33 | P a g e s
recommendation was approximately $1.6 million. Most of the questioned costs associated with the PA Program were
broken down by recommendation, so the recommendation analysis allowed for a more detailed picture. Therefore, this
report is focused predominantly on recommendations concerning the PA Program.
Broken down even further, the top topics by average cost per recommendation for PA were 1) General Topic – Eligibility:
Facility Eligibility at over $8 million per recommendation (16 recommendations), even though Cost Eligibility had the
largest total cost and number of recommendations ($776 million and 376 recommendations); 2) General Topic –
Category/Administrative: Buildings, Contents and Equipment (Cat E) at more than $3.6 million per recommendation (174
recommendations), even though Administrative had the largest total cost and frequency ($213 million and 344
recommendations); and 3) Specific Topic: Repair vs. Replacement (50% Rule) at nearly $7.8 million per recommendation
(13 recommendations), even though Accounting had the largest cost and frequency ($416 million and 397
recommendations).
The top specific PA topics by frequency were Accounting (397 recommendations or 58.4%), Contracting (179
recommendations or 26.3%), Procurement (104 recommendations or 15.3%), Duplication of Benefits (95
recommendations or 14.0%), Closeouts (79 recommendations or 11.6%), Insurance (62 recommendations or 9.1%), and
Force Account Labor & Equipment (56 recommendations or 8.2%). Of those specific topics, the most actionable on
FEMA’s part is Procurement. Recognizing the pervasiveness of this topic in OIG audits, especially pertaining to the
eligibility of resulting contract costs, the Recovery Directorate and the Office of Chief Counsel (OCC) developed a cadre
of deployable field attorneys, known as the Procurement Disaster Assistance Team (PDAT). The mission of the PDAT is
to assist disaster assistance applicants in complying with Federal procurement standards, 5 particularly in advance of
awarding contracts to reduce potential procurement violations. The PDAT will not only ensure that federal funds are
expended efficiently, effectively, and in compliance with Federal regulations, but will also lead to fewer audit
recommendations on the matter.
On the other side of the spectrum, only 23 audits (11.4%) and 28 recommendations (4.1%) applied to the IA Program. In
fact, only two groups of audits had any questioned costs at all for IA: OIG-13-102, Unless Modified, FEMA’s Temporary
Housing Plans Will Increase Costs by an Estimated $76 Million Annually, which was coded as having questioned costs of
$76,000,000 regarding potential savings; and six audits pertaining to the Disaster Assistance Recoupment Fairness Act of
2011 (OIG-12-62, OIG-12-91, OIG-12-127, OIG-13-17, OIG-13-51, and OIG-13-100), with a total questioned cost of
$643,000,000. Interestingly enough, however, due to the abnormally high questioned costs figures, the average cost per
IA audit was $31.6 million (far exceeding the PA average of $5.7 million), and $2.7 million per recommendation.
Finally, only 7 audits (3.5%) and 2 recommendations (0.3%) applied to the NPSCs. Because of the broad programmatic
overlap between the NPSCs and the IA Program, there were no specific topics coded for the NPSCs. Furthermore, the
only questioned costs associated with the NPSCs was due to the full text of OIG-13-102 being coded as applying to the
NPSCs as well, even though the $76 million in questioned costs for that audit applied solely to IA. There were no
questioned costs associated with any NPSC recommendations.
On a jurisdictional level, 179 audits (88.6%) and 624 recommendations (91.8%) were assigned to the Regions, with just
29 audits (14.4%) and 56 recommendations (8.2%) at the Headquarters level. A further breakdown shows that Region IV
received the most audits (71 audits or 35.1%) and the most recommendations (252 recommendations or 37.1%); then
Region VI with 40 audits (19.8%) and 167 recommendations (24.6%); then Region IX with 34 audits (16.8%) and 124
recommendations (18.2%). However, the Region with the highest average cost per audit was Region VI at $15.4 million,
then Region VII at $11.6 million, and Region V at $8.5 million. Similarly, the highest average cost per recommendation
belonged to Region VII at $5.4 million, switching places with Region VI at $3.7 million, and then Region V again at $2.7
million.
On the LTRO/TRO front, there were a total of 55 audits and 215 recommendations spread across four LTROs/TROs
(Florida, Louisiana, Mississippi, and Sandy). Louisiana and Mississippi had the highest average cost per audit and
5
44 C.F.R. § 13.36; 2 C.F.R. pt. 215.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
3 of 33 | P a g e s
recommendation, with nearly $20 million per audit and $4.4 million per recommendation for Louisiana, and $3 million
per audit and roughly $693,000 per recommendation for Mississippi.
Finally, the most frequent cause was Review/Oversight with 192 audits (95.0%) and 635 recommendations (93.4%). Next
was Communication, with 116 audits (57.4%) and 194 recommendations (28.5%), then Procedures with 90 audits (46.0%)
and 138 recommendations (20.3%). However, the most expensive causes by average cost per audit were Planning at $50.4
million, and average cost per recommendation Guidance at $2.6 million.
Creation of Audits Unit
For the reasons outlined above and throughout this report, the Recovery Directorate has embarked upon creating a new
audits unit to oversee, coordinate, and implement GAO/OIG audits involving Recovery. Due to the high proportion of
audits regarding the Public Assistance Program, this new unit will be housed in the PA Division. In order to promote
better collaboration and consistency between audits and PA Appeals, another significant source of inquiries regarding
implementation of the PA Program, the audits unit will be a section co-located in the same branch as PA Appeals. The
Recovery Directorate developed a business case to create this new unit, to include a proposal for 8-10 additional staff
members.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
4 of 33 | P a g e s
Table of Contents
Executive Summary ............................................................................................................................................ 2
Background ......................................................................................................................................................... 6
Scope ................................................................................................................................................................... 6
High-Level Snapshots ......................................................................................................................................... 8
Frequency ........................................................................................................................................................ 8
Average Cost per Full Audit ............................................................................................................................ 9
Average Cost per Recommendation .............................................................................................................. 10
Topic & Cause Breakdowns .............................................................................................................................. 11
Public Assistance ........................................................................................................................................... 11
Individual Assistance ..................................................................................................................................... 12
National Processing Service Centers ............................................................................................................. 12
Causes ............................................................................................................................................................ 12
Observations and Recommendations ................................................................................................................ 13
Challenges ..................................................................................................................................................... 13
Audit Coding and Analysis Going Forward: Process, People, and Technology ........................................... 14
Deeper Dive Analysis .................................................................................................................................... 14
Audit Coordinating and Tracking .................................................................................................................. 15
Intra-Agency Collaboration ........................................................................................................................... 15
Collaboration with GAO and OIG................................................................................................................. 16
Implications for Policies and Programs ......................................................................................................... 16
Recovery Audits Unit .................................................................................................................................... 16
Contributors to the Report ................................................................................................................................. 17
Appendices
Appendix A: Acronyms .................................................................................................................................... 19
Appendix B: Factors Tracked ........................................................................................................................... 20
Appendix C: Coding Terminology .................................................................................................................... 21
Appendix D: Definitions ................................................................................................................................... 23
Appendix E: Dashboard Materials .................................................................................................................... 28
Appendix F: Table of Audits Related to Public Assistance Second Appeals ................................................... 32
Appendix G: All Audits Analyzed .................................................................................................................... 33
Back to Top
Analysis of GAO/OIG Audits 2011-2014
5 of 33 | P a g e s
Background 6
Between 2011 and early 2014, the Recovery Directorate received 202 total audits, with 680 recommendations from both
the Government Accountability Office (GAO) and the Department of Homeland Security (DHS) Office of the Inspector
General (OIG). The audits objectives were to assess and improve the efficiencies and effectiveness of FEMA’s Recovery
Directorate programs. Some audits included recommendations for corrective action, while others contained no
recommendations and praised FEMA’s actions. The subjects of the audits included FEMA Headquarters (HQ) as well as
individual Regions, Long-Term Recovery Offices (LTRO), and Transitional Recovery Offices (TRO). Further, some
audits applied to multiple federal agencies.
The purpose of this analysis is to provide the Recovery Directorate with a more complete understanding of the substantive
trends, patterns, and costs associated with the GAO/OIG reports so that Recovery may improve policy, procedures, and
operational oversight. More specifically, the Directorate is looking to answer the question, “What specific policies and
practices are negatively affecting disaster survivors and the implementation of Recovery programs?” This document
describes the process by which these audits and recommendations were analyzed and coded. This report also provides
insight as to the most frequently occurring topics and causes as well as the average cost per audit and per
recommendation. A dashboard in Excel (Appendix E) was created to allow FEMA staff the ability to organize the data in
various ways to produce tailor-made reports of the various correlations between division, topic, and cause.7
Qualitative analysis methods were used to identify, analyze, and report patterns across Recovery Directorate audits and
recommendations, and mixed methods (qualitative and quantitative) were used to extrapolate the results of the analysis
presented in the Executive Summary above and tables below. The Recovery Audit Coordinator and Qualitative Analyst
within the Recovery Front Office’s (RFO), Executive Communications Unit (ECU) worked with the Office of the Senior
Policy Advisor for Recovery (OSPAR) to develop a codebook of topics (themes) and causes (issues). To ensure validity,
ECU and OSPAR conferred with other members of RFO and Public Assistance Appeals subject matter experts at HQ.
FEMA Corps Team Terrapin 2 assisted in the coding process. Nine team members were trained in qualitative analysis and
began coding under the direction of the Audit coordinator and Qualitative Analyst.
The analysis was performed using Microsoft Excel 2010 as a tool to organize the data. A new SharePoint page was
created for the audits analysis that houses relevant links for FEMA Corps, the final reports being analyzed,
terminology/coding references, contact information, and the dataset that each used. The site is available to the entire
Recovery Directorate HERE. Appendix G includes a list of all Recovery audit final reports analyzed with links to their
location.
Scope
•
•
•
•
Audit Authors: GAO and OIG
Types of Reports: Final audit reports issued from 2011-2014 (as of 03/24/2014). Final reports provide the most
comprehensive and reliable data, so this analysis does not cover draft reports and audits that did not result in a
final report.
Jurisdiction: Audits assigned to the Recovery Directorate at Headquarters (HQ); Regional audits; and audits
assigned to a long-term recovery office (LTRO), or transitional recovery office (TRO). Some audits are assigned
to HQ, a Region and/or LTRO/TRO. Audits assigned to a LTRO or TRO are coded as such, but they are primarily
analyzed with respect to what Region they fall in.
Groups of Coding:
o Full Audits: The full text of an audit, including background, findings, and recommendations (the sum of its
parts).
6
All links to Audit Reports and the Recovery SharePoint site are to internal FEMA sites. These sites are not accessible outside the
FEMA firewall. The remaining links are to cross-references in this report.
7
For the list of coding terminology and associated definitions, please see Appendix C and Appendix D, respectively.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
6 of 33 | P a g e s
Recommendations: Each individual Recovery-related recommendation if a final report includes one. Some
final reports have no recommendations, and some have recommendations that apply to another agency or
different FEMA program.
 For HQ audits assigned to Recovery, the analysis only looks at recommendations specifically
assigned to the Recovery Directorate by the Office of Policy and Program Analysis (OPPA) Audit
Liaison Office’s (ALO) audit tracking system (Executive Management System, or EMS).
 All recommendations within an audit assigned solely to a Region (as opposed to an audit also
assigned to HQ) are assumed to be assigned to the Region as well.
Divisions: The following three are the only divisions implicated by the audits analyzed.
o Public Assistance Division (PA)
o Individual Assistance Division (IA)
o National Processing Service Centers (NPSC)
o
•
Back to Top
Analysis of GAO/OIG Audits 2011-2014
7 of 33 | P a g e s
High-Level Snapshots
Frequency
Table 1: Audits Analyzed 8
Jurisdiction
All Recovery
Public Assistance
Individual Assistance
National Processing Service Centers
Headquarters
Regions
RIV
RVI
RIX
RII
RVII
RV
RX
RIII
RI
RVIII
LTROs/TROs
Louisiana TRO (R6)
Mississippi TRO (R4)
Florida (L)TRO (R4)
Sandy Recovery Office (R2)
Total Audits 9
202
188 93.1%
23 11.4%
7
3.5%
29
14.4%
179
88.6%
71 35.1%
40 19.8%
34 16.8%
9
4.5%
9
4.5%
6
3.0%
6
3.0%
3
1.5%
1
0.5%
0
0.0%
55
27.2%
28 13.9%
16
7.9%
7
3.5%
4
2.0%
Total
Recommendations 10
680
656
96.9%
28
4.1%
2
0.3%
56
8.2%
624
91.8%
252
37.1%
167
24.6%
124
18.2%
21
3.1%
17
2.5%
19
2.8%
19
2.8%
3
0.4%
2
0.3%
0
0.0%
215
31.6%
127
18.7%
66
9.7%
22
3.2%
0
0.0%
8
The figures in this table are sorted by frequency of audits.
Several audits may overlap as they may be assigned to more than one jurisdiction. 6 audits overlapped between Headquarters (HQ)
and the Regions, so the total sum is 208, but there are only 202 individual audits; 1 audit overlaps between two different Regions; 55
audits overlap between Regions and Long-Term Recovery Offices (LTROs)/Transitional Recovery Offices (TROs); and 3 audits
overlap between HQ, the Regions, and a LTRO/TRO.
10
For the sake of simplicity, the recommendations from all Regional and LTRO/TRO audits coded were treated as applying to
Recovery. Furthermore, due to lack of breakdown by division or otherwise in the tracking of regional audits, all recommendations
from regional or LTRO/TRO audits were assumed to have been assigned to that Region or LTRO/TRO as well (as opposed to HQ
audits, where not all recommendations applied to Recovery). Additionally,
The only instances of overlap for recommendations occur between the Regions and a LTRO/TRO when the full audit was assigned
to a LTRO/TRO (but there are no HQ recommendations assigned to any other component, Region, or LTRO/TRO). Due to geographic
overlaps and the somewhat temporary nature of LTRO/TROs, all audits and recommendations assigned to a LTRO/TRO were also
coded as being assigned to the corresponding Region. There are 55 audits and 215 recommendations coded as having such an overlap.
9
Back to Top
Analysis of GAO/OIG Audits 2011-2014
8 of 33 | P a g e s
Average Cost per Full Audit
Table 2: Questioned Costs Summary by Average Cost per Full Audit
Audit
Jurisdiction/Type
Percentage Questioned Costs 12
Frequency 11
All Audits 202
100%
$1,795,906,146
HQ vs. Regions vs. LTROs/TROs
14.4%
$733,086,951
Total HQ 29
27.2%
$616,674,874
Total LTRO/TRO 55
88.6%
$1,076,606,146
Total Regions 179
GAO vs. OIG
97.5%
$1,795,906,146
OIG 197
2.5%
$0
GAO 5
Division Breakdown
11.4%
$726,627,370
Individual Assistance 23
93.1%
$1,076,606,146
Public Assistance 188
3.5%
$0
National Processing Service Centers 7
Regional Breakdown
Total Regions 179
88.6%
$1,076,606,146
RVI 40
19.8%
$616,693,519
RVII 9
4.5%
$104,801,005
RV 6
3.0%
$51,131,233
RII 9
4.5%
$51,514,102
RIX 34
16.8%
$95,175,497
RIV 71
35.1%
$151,479,825
RX 6
3.0%
$5,147,522
RI 1
0.5%
$357,332
RIII 3
1.5%
$306,111
RVIII 0
0.0%
$0
LTRO/TRO Breakdown
Total LTRO/TRO 55
27.2%
$616,674,874
Louisiana TRO (R6) 28
13.9%
$559,500,819
Mississippi TRO (R4) 16
7.9%
$48,847,392
Florida (L)TRO (R4) 7
3.5%
$8,326,663
Sandy Recovery Office (R2) 4
2.0%
$0
Avg.
Cost
$8,890,624
$25,278,860.38
$11,212,270
$6,014,559
$9,116,275
$0
$31,592,494
$5,726,628
$0
$6,014,559
$15,417,338
$11,644,556
$8,521,872
$5,723,789
$2,799,279
$2,133,519
$857,920
$357,332
$102,037
$0
$11,212,270
$19,982,172
$3,052,962
$1,189,523
$0
11
Many audits overlap between HQ/Regions and among the divisions, so the sum of all the audits is more than the number of
individual audits analyzed.
12
The Questioned Costs total for the Full Audit includes the sum of all Questioned Costs for Recommendations along with any
miscellaneous values; due to audit overlaps, the sum of the different Questioned Costs is far greater than the actual total Questioned
Costs the 202 audits.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
9 of 33 | P a g e s
Average Cost per Recommendation
Table 3: Questioned Costs Summary by Average Cost per Recommendation
Recommendation
Jurisdiction/Type
Percentage Questioned Costs 14
Frequency 13
All Recommendations 680
100%
$1,149,472,402
HQ vs. Regions vs. LTROs/TROs
31.6%
$613,541,130
Total LTRO/TRO 215
91.8%
$1,059,685,451
Total Regions 624
8.2%
$89,786,951
Total HQ 56
GAO vs. OIG
99.6%
$1,149,472,402
OIG 677
0.4%
$0
GAO 3
Division Breakdown
4.1%
$76,000,000
Individual Assistance 28
96.9%
$1,073,350,483
Public Assistance 659
0.3%
$0
National Processing Service Centers 2
Regional Breakdown
Total Regions 624
91.8%
$1,059,685,451
RVII 17
2.5%
$91,014,054
RVI 167
24.6%
$616,693,519
RV 19
2.8%
$51,131,233
RII 21
3.1%
$51,514,102
RIX 124
18.2%
$95,175,497
RIV 252
37.1%
$148,346,081
RX 19
2.8%
$5,147,522
RI 2
0.3%
$357,332
RIII 3
0.4%
$306,111
RVIII 0
0.0%
$0
LTRO/TRO Breakdown
Total LTRO/TRO 215
31.6%
$613,541,130
Louisiana TRO (R6) 127
18.7%
$559,500,819
Mississippi TRO (R4) 66
9.7%
$45,713,648
Florida (L)TRO (R4) 22
3.2%
$8,326,663
Sandy Recovery Office (R2) 0
0.0%
$0
Avg.
Cost
$1,690,401
$2,853,680
$1,698,214
$1,603,338
$1,697,891
$0
$2,714,286
$1,628,756
$0
$1,698,214
$5,353,768
$3,692,776
$2,691,118
$2,453,052
$767,544
$588,675
$270,922
$178,666
$102,037
$0
$2,853,680
$4,405,518
$692,631
$378,485
$0
13
Many audits overlap between HQ/Regions and among the divisions, so the sum of all the audits is more than the number of
individual audits analyzed.
14
The Questioned Costs total for the Full Audit includes the sum of all Questioned Costs for Recommendations along with any
miscellaneous values; due to audit overlaps, the sum of the different Questioned Costs is far greater than the actual total Questioned
Costs the 202 audits.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
10 of 33 | P a g e s
Topic & Cause Breakdowns 15
Public Assistance
Table 4: PA Topics by Average Cost
Full Audits
Frequency Questioned Cost Avg. Cost/Audit
General Topic - Eligibility
PA - Facility Eligibility
12
$223,326,181
$18,610,515
$290,318,457
$13,196,294
PA - Applicant Eligibility
22
PA - Work Eligibility
89
$616,630,902
$6,928,437
PA - Cost Eligibility
143
$913,409,581
$6,387,480
General Topic – Category/Administrative
Frequency Questioned Cost- Avg. Cost/Audit
PA - Buildings, Contents and Equipment (Cat E)
81
$766,888,199
$9,467,756
PA - Administrative
149
$810,897,981
$5,442,268
PA - Parks, Recreational, and Other (Cat G)
34
$176,720,308
$5,197,656
PA - Emergency Protective M easures (Cat B)
50
$196,656,461
$3,933,129
PA - Debris Removal (Cat A)
65
$186,478,831
$2,868,905
PA - Water Control Facilities (Cat D)
15
$42,089,827
$2,805,988
PA - Utilities (Cat F)
38
$106,507,580
$2,802,831
29
$66,110,083
$2,279,658
PA - Road Systems and Bridges (Cat C)
S pecific Topic
Frequency Questioned Cost Avg. Cost/Audit
PA - Legal Responsibility
16
$342,856,575
$21,428,536
$115,526,333
$19,254,389
PA - Appeals
6
PA - Repair vs. Replacement (50% Rule)
9
$167,130,602
$18,570,067
PA - Insurance
47
$593,634,937
$12,630,531
2
$19,615,728
$9,807,864
PA - Codes and Standards
$232,289,393
$9,291,576
PA - Administrative Costs
25
PA - Application Process
6
$45,549,564
$7,591,594
PA - Duplication of Benefits
64
$470,859,450
$7,357,179
14
$99,760,437
$7,125,746
PA - Project M anagement Costs
$7,108,282
PA - Procurement
69
$490,471,450
PA - Contracting
$536,926,286
$5,711,982
94
$5,170,920
PA - Closeouts
61
$315,426,147
PA - Alternate Projects
7
$36,094,252
$5,156,322
PA - Accounting
149
$757,091,075
$5,081,148
PA - Improved Projects
12
$50,331,931
$4,194,328
PA - Force Account Labor & Equipment
35
$88,988,722
$2,542,535
PA - Hazard M itigation
7
$11,523,825
$1,646,261
14
PA - M As/M OUs/Inter-Agency Agreements
$19,323,124
$1,380,223
$603,031
PA - Environmental Compliance
2
$301,516
PA - Preliminary Damage Assessments
4
$1,141,358
$285,340
Recommendations
General Topic - Eligibility
Frequency Questioned Cost Avg. Cost/Rec
PA - Facility Eligibility
16
$128,956,526
$8,059,783
PA - Applicant Eligibility
30
$146,376,216
$4,879,207
$776,150,073
$2,064,229
PA - Cost Eligibility
376
PA - Work Eligibility
147
$291,661,128
$1,984,089
General Topic – Category/Administrative
Frequency Questioned Cost Avg. Cost/Rec
$631,126,971
$3,627,167
PA - Buildings, Contents and Equipment (Cat E)
174
PA - Parks, Recreational, and Other (Cat G)
47
$120,876,710
$2,571,845
PA - Utilities (Cat F)
58
$77,425,201
$1,334,917
PA - Emergency Protective M easures (Cat B)
71
$83,856,522
$1,181,078
PA - Debris Removal (Cat A)
115
$105,282,825
$915,503
PA - Water Control Facilities (Cat D)
32
$27,217,058
$850,533
PA - Road Systems and Bridges (Cat C)
51
$38,407,405
$753,086
PA - Administrative
344
$212,908,082
$618,919
Frequency Questioned Cost Avg. Cost/Rec
S pecific Topic
$7,819,473
PA - Repair vs. Replacement (50% Rule)
13
$101,653,153
PA - Legal Responsibility
20
$146,511,281
$7,325,564
$6,682,925
PA - Codes and Standards
2
$13,365,849
$3,981,112
PA - Insurance
62
$246,828,970
PA - Administrative Costs
24
$77,501,470
$3,229,228
PA - Procurement
104
$266,588,195
$2,563,348
PA - Contracting
179
$309,617,530
$1,729,707
PA - Alternate Projects
7
$11,698,512
$1,671,216
PA - Improved Projects
15
$22,856,822
$1,523,788
PA - Duplication of Benefits
95
$143,899,270
$1,514,729
PA - Appeals
11
$15,475,414
$1,406,856
10
$12,949,595
$1,294,960
PA - Project M anagement Costs
$1,088,999
PA - M As/M OUs/Inter-Agency Agreements
6
$6,533,992
PA - Accounting
397
$415,605,440
$1,046,865
PA - Closeouts
79
$39,947,571
$505,665
PA - Force Account Labor & Equipment
56
$22,355,957
$399,214
$396,579
PA - Hazard M itigation
10
$3,965,788
$207,909
PA - Environmental Compliance
2
$415,817
PA - Preliminary Damage Assessments
3
$452,551
$150,850
PA - Application Process
7
$0
$0
15
The following tables are sorted by average cost per recommendation (left) and per audit (right), from largest to smallest. Because a
recommendation or full audit may be coded for several general or specific topics at once, the frequency and questioned cost figures for
each general/specific topic are not mutually exclusive.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
11 of 33 | P a g e s
Individual Assistance
Table 5: IA Topics by Average Cost
Recommendations
Full Audits
General Topic - IA
Frequency Questioned Cost Avg. Cost/Audit
General Topic - IA
Frequency Questioned Cost Avg. Cost/Rec
IA - Other Needs Assistance
7
$643,300,000
$91,900,000
IA - Housing
15
$76,000,000
$5,066,667
IA - Housing
15
$719,300,000
$47,953,333
IA - Process/Administration
22
$76,000,000
$3,454,545
IA - Process/Administration
19
$726,627,370
$38,243,546
IA - Other Needs Assistance
4
$0
$0
IA - M ass Care
4
$0
$0
IA - M ass Care
4
$0
$0
IA - Community Services
5
$0
$0
IA - Community Services
3
$0
$0
General Topic - IA S ubstantive
Frequency Questioned Cost Avg. Cost/Audit
General Topic - IA S ubstantive
Frequency Questioned Cost Avg. Cost/Rec
IA - Other Needs Assistance
7
$643,300,000
$91,900,000
IA - Direct Housing
11
$76,000,000
$6,909,091
IA - Financial Assistance
10
$643,300,000
$64,330,000
IA - Other Needs Assistance
4
$0
$0
IA - Direct Housing
5
$76,000,000
$15,200,000
IA - Financial Assistance
4
$0
$0
IA - Voluntary Organizations Active in Disasters
3
$0
$0
IA - Voluntary Organizations Active in Disasters
2
$0
$0
IA - Sheltering
3
$0
$0
IA - Sheltering
1
$0
$0
IA - Disaster Recovery Centers
2
$0
$0
IA - Emergency Food and Shelter Program
0
$0
$0
IA - Emergency Food and Shelter Program
1
$0
$0
IA - Disaster Recovery Centers
0
$0
$0
S pecific Topic – IA Process/Admin
Frequency Questioned Cost Avg. Cost/Audit
S pecific Topic – IA Process/Admin
Frequency Questioned Cost Avg. Cost/Rec
IA - Contracts
6
$76,000,000
$12,666,667
IA - Contracts
3
$76,000,000
$25,333,333
IA - M As/M OUs/Inter-Agency Agreements
6
$76,000,000
$12,666,667
IA - M As/M OUs/Inter-Agency Agreements
4
$76,000,000
$19,000,000
National Processing Service Centers
Table 6: NPSC Topics by Average Cost
Full Audits
General Topic – NPS C
Recommendations
Frequency Questioned Cost Avg. Cost/Audit
NPSC - Registration Intake
6
$643,300,000
$107,216,667
General Topic – NPS C
Frequency Questioned Cost Avg. Cost/Rec
NPSC - Registration Intake
2
$0
$0
Causes
Table 7: Causes by Average Cost
Full Audits
Cause
Recommendations
Frequency Questioned Cost Avg. Cost/Audit
Cause
Frequency Questioned Cost Avg. Cost/Rec
Planning
13
$654,647,383
$50,357,491
Guidance
29
$76,117,951
$2,624,757
Guidance
24
$926,980,015
$38,624,167
Procedures
138
$278,125,035
$2,015,399
Analysis, Data, and Technology
32
$803,118,334
$25,097,448
Review/Oversight
635
$1,072,918,076
$1,689,635
Procedures
90
$1,494,446,453
$16,604,961
Analysis, Data, and Technology
46
$76,033,223
$1,652,896
Review/Oversight
192
$1,719,788,195
$8,957,230
People
45
$45,511,222
$1,011,360
People
37
$276,366,700
$7,469,370
Communication
194
$128,880,441
$664,332
Communication
116
$829,049,417
$7,146,978
Training/Exercises
12
$0
$0
Training/Exercises
13
$70,997,297
$5,461,331
Planning
10
$0
$0
Back to Top
Analysis of GAO/OIG Audits 2011-2014
12 of 33 | P a g e s
Observations and Recommendations
Challenges
•
•
•
•
Ensuring all of the data was collected before analysis could begin provided an early challenge that was overcome
with persistent communication with the Regional Audit Coordinators. Headquarters needs to continue to improve
oversight of the audits sent to Regional offices, which are assigned to Regional Audit Coordinators by the Audit
Liaison Office (ALO) within the Office of Policy and Program Analysis. The new Recovery Audits Section will
work with ALO, the Regional Audit Coordinators, the Recovery Divisions, and particularly, the PA Appeals
Section to address this matter.
Time was an anticipated challenge due to the tight deadline provided and the extensive nature of the coding
process. The normal analytical process requires heavy reading and deliberation, which was magnified by the sheer
quantity of information to be analyzed. In order to address this in the immediate term, a FEMA Corps team was
brought on board for a limited time to assist with the coding process. However, for future analyses, a full-time
audits unit, composed of multiple staff with extensive Recovery Directorate knowledge, would be best conducive
for more accurate and efficient coding and analysis.
The recursive nature of qualitative analysis can lead to regular updating of the themes and definitions used to
guide the coding process. This was anticipated to be a challenge early on due of the lack of oversight in regards to
regional audits. The initial codebook was set with only headquarters related data and had to be adjusted to include
regional audit themes as they emerged. While this codebook provided a good foundation, there was sometimes
confusion between terms, 16 the terms were overinclusive, 17 or a term was missing. 18 Going forward, the new
audits unit, the PA Appeals Section, the Recovery Policy and Doctrine Unit, and other Recovery stakeholders
should work together to expand this codebook and flesh out a uniform set of terminology.
The content of the GAO and OIG reports themselves also posed a challenge in that there were some
inconsistencies in the terms used from audit to audit; 19 there was a lack of a clear baseline dollar amount against
which to compare the costs questioned; recommendations to disallow funds that involved a federal share did not
elaborate upon which federal share policy applied, and many audits did not mention the federal share amount; 20
and not all audits of PA awards listed what category of the projects/amounts questioned, so the general topic
figures for PA may not be fully representative. 21 Increased collaboration with the GAO and OIG can remedy these
issues going forward.
16
For example, PA Cost Eligibility and Work Eligibility were treated interchangeably, and the difference between PA Contracting and
PA Procurement was not always clear (this particular matter was later remedied by cleaning up the data).
17
For instance, the Cause of Review/Oversight was coded for 93.4% of all recommendations, reducing the significance of this data
point. Any future coding should distinguish among 1) actual instances of non-compliance and instructions to deobligate funds or
disallow costs; 2) more administrative recommendations that tell FEMA to instruct the State to remind the applicant to comply with
the law; and 3) recommendations that require improved internal controls, review, or oversight by FEMA or the State. Compare, e.g.,
OIG Report Number DA-13-08, FEMA Should Recover $470,244 of Public Assistance Grant Funds Awarded to the City of Lake
Worth, Florida – Hurricanes Frances and Jeanne (December 2012) (“Recommendation #4: Disallow $8,570 (Federal share $7,713)
of ineligible costs for small project work not completed (finding E).”) with id. (“Recommendation #1: Instruct the State to remind the
City that it is required to comply with Federal procurement standards when acquiring goods and services under FEMA awards
(finding A).”) and OIG Report Number DD-11-12, Xavier University of Louisiana (April 2011) (“Recommendation #6: Require
GOHSEP to implement controls to ensure subgrantees comply with federal regulations regarding time restriction and extensions on
project completion (Finding F).”).
18
There were instances where a project cost less than the amount obligated, so OIG would recommend FEMA deobligate the funds
and put them to better use. There were no coding terms that easily applied, so such recommendations were usually coded as Cost
Eligibility (PA General Topic – Eligibility), Administrative (PA General Topic – Category/Administrative), Accounting (PA Specific
Topic), and Review/Oversight (Cause). See, e.g., OIG Report Number DA-13-01, FEMA Should Deobligate $226,096 of Unneeded
Public Assistance Grant Funds Awarded to the Town of Dauphin Island, Alabama – Tropical Storm Ida (November 2012).
19
For instance, what may be labeled as a Standard Operating Procedure matter in one audit may have been referred to as a protocol,
policy, or guidance in another audit.
20
For purposes of consistency, all questioned costs were coded for the full amount, regardless of what the federal share was.
21
Some audits included a table of Project Worksheets (PW) audited, associated PA category, and questioned costs; for the audits that
did not identify which category of work a PW related to, the coder would have to separately look up the individual PW number. Due
to this cumbersome process and limited timeframe, some audits or recommendations did not include coding for category of work.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
13 of 33 | P a g e s
•
Due to technology limitations, it was not possible to determine the breakdown between general/specific topics,
causes, and questioned costs. For example, one audit may concern an entire disaster recovery effort including IA
and PA and be coded for the cause communication; however, it is not clear whether the communication cause
applies to IA, PA, or both. Microsoft Excel 2010 was used for the coding process, but more sophisticated software
is necessary in order to make direct links between the topics and causes.
Audit Coding and Analysis Going Forward: Process, People, and Technology
A standardized process for analyzing audits in the future should include detailed instructions on the process of qualitative
analysis and coding and a clear format identified for the documentation of findings. Coding and analysis should occur
simultaneously to allow the analysis to inform revisions to the coding terminology; this process should begin as soon as an
audit final report is received.
The coding and analysis should be done by one to three (1-3) analysts who have extensive background knowledge of the
Recovery Directorate as well as of the GAO/OIG audit process. Having dedicated analysts will allow for deeper dives into
the data to retrieve further analysis within a tight deadline. This will also diminish the need for subject matter experts to
take substantive time away from their work to explain programs and policies which could be easily understood by analysts
from within Recovery.
While Excel 2010 allows for the use of pivot tables in the analysis, a program created specifically for qualitative analysis
would be beneficial for use in future analysis projects. 22 MAXQDA is a type of coding software that provides qualitative
and mixed methods data analysis for Windows and Mac, allowing one to create custom coding systems, mark information
within data sources themselves, retrieve codes with ease, and organize analysts’ thoughts and theories in memos attached
directly to the text. This software will also allow for a hierarchy of themes or topics to show how sub-topics fit within
umbrella topics that can each be measured separately. 23
Deeper Dive Analysis
During the course of the coding process and analysis, several areas for a deeper look in the future came to light. Since
most of the audits and recommendations pertained to Public Assistance, the general and specific topics identified for
further analysis are PA-related. Deeper dive recommendations regarding questioned costs and causes are also identified
below:
• PA General Topic
o Cost Eligibility (e.g., Unsupported documentation for claimed cost; Over-charges; Interest charged; Incorrect
charges; Cost-plus charges; Non-compliance with procurement regulations; No cost or price analysis
conducted; Costs were not reasonable or necessary).
o Work Eligibility (e.g., Outside the scope of work; Damage not the result of declared disaster).
o Applicant Eligibility (e.g., Legal responsibility).
o Facility Eligibility (e.g., Legal responsibility).
o Administrative (e.g., FEMA needs to provide instructions to grantees/subgrantees regarding regulations and
project documentation; Appeals-related matters).
• PA Specific Topic
o Contracting (post-award) vs. Procurement (awarding process). Audits coded for procurement were often also
coded for Contracting; clearer definitions of each would minimize unnecessary overlaps.
o Closeouts (e.g., Incomplete projects; Closeout processes).
o Mission Assignments/Memoranda of Understanding/Inter-Agency Agreements: Interagency Coordination
(e.g., Horizontal coordination: federal agency-to-federal agency, state-to-state, tribe-to-tribe, and local-tolocal; Vertical coordination: federal-to-state/tribe, federal-to-local, state-to-tribe, state/tribe-to-local; FEMA
22
Other Recovery projects this coding process could be used for would be Correspondence and PA Appeals.
One example is procurement (sub-topic) versus contracting (umbrella topic): procurement is a subset of contracting as defined in
this analysis, but they are measured concurrently without showing the hierarchical breakdown.
23
Back to Top
Analysis of GAO/OIG Audits 2011-2014
14 of 33 | P a g e s
•
•
•
coordination: HQ office/directorate-to-office/directorate, HQ-to-Region; HQ-to-LTRO/TRO/JFO; Region-toLTRO/TRO/JFO; Office-to-field).
o Force Account Labor & Equipment (e.g., labor vs. equipment matters).
o Accounting (e.g., Separate accounting for project costs; Record-keeping; Budgeting; Accountability).
Questioned Costs
o Break down these values using GAO/OIG’s terms (e.g., Disallow vs. Deobligate; Questioned Costs vs. Funds
Put to Better Use vs. Underpaid Insurance Claims that Applicant will need to reimburse FEMA).
o Determine the appropriate dominator or baseline against which to compare questioned costs.
o Track by type of applicant (e.g., city vs. school).
o Perhaps track and compare questioned costs with full amount of award or the amount audited in the report, if
applicable (mostly PA). This can provide better context for the monetary value that the auditors questioned.
o Determine whether it is feasible to track and compare the federal vs. grantee/subgrantee share of the amount
questioned.
Cause
o Analysis, Data, and Technology (e.g., Technology systems and integration).
o Review/Oversight (e.g., Insufficient documentation; Non-compliance; Fraud/Waste/Abuse).
o Communication (e.g., Necessity of updating FEMA with changes to project scope; Recommendations that
FEMA instruct the State to remind the applicant to comply with statutes and regulations).
o People (e.g., Interagency cooperation; Agency roles/responsibilities).
o Procedures (e.g., Timeframes/deadlines; Instructions for FEMA to establish procedures vs. the State to
establish procedures).
Other
o Analyze recommendations based on actions FEMA can take vs. shared responsibilities of FEMA, the State,
and/or the Applicant vs. only the State’s or Applicant’s responsibilities.
Audit Coordinating and Tracking
The Recovery Audit Coordinator (AC) has been working with OPPA’s Audit Liaison Office (ALO) to enhance audit
tracking capabilities for all of FEMA. ALO’s goal is to train Audit Coordinators at HQ and in the Regions to input audit
information as it comes in, as well as start coding audits based on pre-determined Agency-wide topics/themes and
causes/issues. Recovery should incorporate a similar strategy in Recovery’s audit tracking system for Recovery-specific
topics and causes.
As a start to better audit coordination and tracking, the Recovery AC developed a Recovery Audits SharePoint site that
includes an audit engagement tracker (which tracks the status of the entire audit process from entrance conference to
closure), a recommendation tracker (which tracks the status of individual recommendations within final audit reports), a
calendar, and a tasking system. Going forward, the Recovery Audit Coordinator plans to link Recovery’s SharePoint
trackers to ALO’s tracker to streamline the process and prevent duplication of efforts. Furthermore, the Recovery AC will
work with ALO and the Regions to develop a regional audit tracker; and work with the PA Appeals Section to better track
audits implicated in PA appeals.
Intra-Agency Collaboration
GAO and OIG audits often traverse multiple FEMA components and programs in a single report. In order to promote
consistent, accurate, and timely responses, Recovery needs to increase and standardize collaboration within the
Directorate, with the ALO, with other components at HQ, and with the Regions, LTROs/TROs, and JFOs. Within
Recovery, the new audits unit, the PA Appeals Section, OSPAR, and the congressional correspondence staff should create
a unified set of terminology for coding. The audits unit and PA Appeals should be in constant communication to identify
instances of overlap. Better coordination between the two units would better prepare Recovery to fully engage the auditors
as well as implement the PA Program in a fair and consistent manner.
Recovery should also build upon the existing relationships with OPPA’s Audit Liaison Office, the Office of Chief
Counsel (OCC), Office of Chief Financial Officer (OCFO), and External Affairs (EA) in responding to audits. Recovery
has the opportunity to inform the new audit tracking system ALO is putting into place, and Recovery and ALO should
consult regarding coding terminology. While OCC is consulted in drafting responses and providing data, they should be
Back to Top
Analysis of GAO/OIG Audits 2011-2014
15 of 33 | P a g e s
consulted earlier in the drafting process. Recovery should also work with OCFO to determine the best way to organize
and access final award amounts and administrative costs associated with implementing Recovery programs. Finally,
Recovery should work more with EA to craft and share messaging pertaining to Recovery audit matters.
Collaboration within Headquarters is essential, but the relationships with the Regions, LTROs/TROs, and JFOs are just as
essential to maintain. As previously discussed, there is limited visibility on regional or LTRO/TRO audits, and the audit
initiation and tracking methods are not uniform across Regions. The new audits unit should work with the regional Audit
Coordinators and ALO to develop a robust and unified audit tracking system that can classify audits by FEMA program.
Furthermore, a significant number of audits recommended that FEMA instruct a State to inform an applicant to comply
with federal statutes and regulations, which has implications for both HQ and regional actions. 24
Collaboration with GAO and OIG
In order to provide better analysis and implementation of audits, Recovery should work with GAO and OIG to better
understand and delineate terminology. Recovery should also request that the GAO and OIG always include a table of PW
numbers, category of work, and questioned costs regarding PA audits. Together, Recovery and the auditors should
determine the most appropriate baseline or denominator with which to compare the various questioned costs in order to
provide a perspective on what proportion of Recovery awards are at issue. Finally, while the OIG Capping Reports for
each year are helpful in summarizing the audit amounts for two of FEMA’s most audited programs – PA and Hazard
Mitigation – it would be more helpful if the Capping Reports could separate the amounts for each program, as Hazard
Mitigation is a separate component from Recovery.
Another purpose of this collaboration is to gain a better understanding of what is driving the audits. We want to be able to
fix issues before they become the subject of an audit, and if an audit is issued, then resolve the problems before final
reports so that either no recommendations are issued or they are considered resolved and closed upon issuance of the final
report. What would help FEMA achieve these goals is to have insight into the factors GAO and OIG consider in deciding
what, who, and where to audit, particularly when an audit is triggered by a congressional inquiry.
Lastly, future discussions with GAO and OIG should promote writing recommendations that FEMA has the power to
implement. There are instances where the Applicant or the State has made errors in the grant process that renders them
ineligible for reimbursement. In some of those instances, FEMA can only advise the Applicants and States to comply with
the rules, such as the requirement to account for costs on a project-by-project basis; in other instances, FEMA does not
have jurisdiction to intercede, such as the manner in which contracts are carried out by Applicants or States.
Implications for Policies and Programs
Based on the audits analysis, Recovery should make tactical corrections in program delivery and strategic decisions about
prioritizing limited resources to focus on these issues. This will improve Recovery’s policy, procedures, and operational
oversight. As discussed above, with future analyses in mind regarding Correspondence and PA Appeals, similar
terminology should be used across Recovery to promote cohesion.
Recovery Audits Unit
As demonstrated above, Recovery Directorate programs are regularly audited, in large part due to the large amount of
monetary assistance provided to States, Tribes, and localities. Currently, there is only one Recovery staff member
dedicated almost full-time to audits, with occasional support from two other Recovery employees. For this reason and the
reasons previously discussed, the Recovery Directorate has embarked upon creating a new audits unit to oversee,
coordinate, and implement GAO/OIG audits involving Recovery.
24
E.g., OIG Report Number DA-13-08, FEMA Should Recovery $470,244 of Public Assistance Grant Funds Awarded to the City of
Lake Worth, Florida – Hurricanes Frances and Jeanne (December 2012) (“Recommendation #1: Instruct the State to remind the City
that it is required to comply with Federal procurement standards when acquiring goods and services under FEMA awards (finding
A).”).
Back to Top
Analysis of GAO/OIG Audits 2011-2014
16 of 33 | P a g e s
Due to the high proportion of audits regarding the Public Assistance Program, this new unit will be housed in the PA
Division. In order to promote better collaboration and consistency between audits and PA Appeals, another significant
source of inquiries regarding implementation of the PA Program, the audits unit will be a section co-located in the same
branch as PA Appeals. The Recovery Directorate developed a business case to create this new unit, to include a proposal
for 8-10 additional staff members.
Contributors to the Report
Recovery Front Office
Executive Communications Unit
John Pearl – Section Chief & Project Manager
Eamonn Bethel – Technical Analyst
Meghan Griffin – Qualitative Analyst, Report Compiler & FEMA Corps Trainer
Victoria Roth – Recovery Audit Coordinator, Lead Report Compiler & FEMA Corps Trainer
Recovery Policy & Doctrine Unit
Deana Platt – Senior Policy Advisor & Section Chief
Heather Coons – Program Analyst
FEMA Corps
Team Terrapin 2
Katrina Beitz – Team Lead
Tyler Cipriano
Joel Devoid
Megan Fix
Andreya Frankhuizen
Deborah Isen
Brittany Kaplan
Adam Livermore
Alisa Ray
Back to Top
Analysis of GAO/OIG Audits 2011-2014
17 of 33 | P a g e s
Appendices
Appendix A: Acronyms
AC – Audit Coordinator
ALO – Audit Liaison Office (FEMA)
DHS – Department of Homeland Security
EA – External Affairs
ECU – Executive Communications Unit
EMS – Executive Management System
GAO – Government Accountability Office
HQ – Headquarters (FEMA)
IA – Individual Assistance
JFO – Joint Field Office
LTRO – Long-Term Recovery Office
NPSC – National Processing Service Centers
OCC – Office of Chief Counsel
OCFO – Office of Chief Financial Officer
OFDC – Office of Federal Disaster Coordination
OIG – Office of the Inspector General, Department of Homeland Security
OPPA – Office of Policy and Program Analysis
OSPAR – Office of the Senior Policy Advisor for Recovery
PA – Public Assistance
PDA – Preliminary Damage Assessment
PDAT – Procurement Disaster Assistance Team
PW – Project Worksheet
RFO – Recovery Front Office
TRO – Transitional Recovery Office
Back to Top
Analysis of GAO/OIG Audits 2011-2014
19 of 33 | P a g e s
Appendix B: Factors Tracked
Report Number
Job Code
Audit Type
Subject
Report Title
Final Report Date
Recommendation
Number
Recommendation
Language
Type
Questioned Costs
Assigned to Recovery HQ
PA Second Appeal
Region
LTRO/TRO
Disaster Number
Division
General Topic
Specific Topic
Cause
Tone
Back to Top
Official number given by GAO or OIG.
Official job code assigned by GAO or OIG for tracking purposes before a final report is issued.
This code is how audits are organized in EMS.
Whether the audit is by GAO or OIG.
Summary of the subject of the audit; sometimes the same as the Report Title.
Official title provided by GAO or OIG.
Date final report was issued.
If the report includes recommendations, this lists the recommendation number that is being
analyzed. If the analysis is of a full audit, this box would be marked as “N/A.”
If the report includes recommendations, this lists the exact language of the recommendation. If the
analysis is of a full audit, this box would be marked as “N/A.”
Whether the item is a full audit or recommendation.
This will always be a monetary value; this is a collective term referring to all types of monetary
issues identified by GAO or OIG:
• Questioned Costs or Unsupported Costs – where GAO/OIG recommends FEMA disallow
funds due to ineligible work or charges.
• Unused Funds or Funds Put to Better Use – where GAO/OIG recommends FEMA deobligates unused funds.
• Potential Savings – where GAO/OIG has identified an alternative solution or procedure
that, if followed, could save FEMA money.
• Duplicate Costs or Duplicate Benefits – where GAO/OIG recommends FEMA disallow or
deobligate funds due to duplication.
Questioned Cost values reported in this analysis also represent the full amount questioned,
regardless of cost share breakdown. Additionally, the full amount of questioned costs were coded,
even if the audit mentioned the federal share because not all audits included this information, and it
was unclear how all the costs broke down and which federal share policy applied.
Whether the audit is assigned to HQ (instead of or in addition to being assigned to a
Region/LTRO/TRO).
Whether this audit relates to a matter being determined by HQ for a Second Appeal. The Audit
Coordinator was provided a list of active Second Appeal-related audits by PA; additional related
audits were identified from the text of the full audit.
If an audit was assigned to a Region, LTRO, or TRO, what Region had overarching jurisdiction.
Whether an audit was specifically assigned to a LTRO or TRO in OPPA’s audit tracking system.
Any disaster numbers affiliated with the audit. Some audits were affiliated with multiple disasters.
Whether the audit related to the Public Assistance Division (PA), the Individual Assistance
Division (IA), the National Processing Service Centers (NPSC), or any combination thereof.
• For PA, general topics included Category of assistance, type of Eligibility, or
Administrative/Other.
• For IA, general topics included the main program areas within IA (i.e. Housing, Other Needs
Assistance (ONA), Mass Care, and Community Services).
• NPSC: the general topics included Customer Service, Helpline, and Registration Intake. For
the full set of terms and definitions, please see Appendix B.
For PA, specific topics included substantive as well as process/administrative items (e.g.,
Accounting, Appeals, Contracting, Hazard Mitigation, Procurement, Repair vs. Replace (50%
rule)). For IA, specific topics also included substantive as well as process/administrative items
(e.g., Direct Housing, Disaster Recovery Centers, Financial Assistance, and Voluntary
Organizations Active in Disasters). For NPSC, there were no unique NPSC specific topics, but
some NPSC-coded audits were affiliated with IA specific topics due to programmatic overlaps. For
the full set of terms and definitions, please see Appendix B.
The list of causes was the same for all three divisions and included Analysis, Data, and
Technology; Communication; Guidance; People; Planning; Procedures; Review/Oversight, and
Training/Exercises. For the full set of terms and definitions, please see Appendix B.
Whether the audit was positive in nature (i.e. no recommendations and praised FEMA) or negative
in nature (i.e. included recommendations or was critical even with no recommendations).
Analysis of GAO/OIG Audits 2011-2014
20 of 33 | P a g e s
Appendix C: Coding Terminology
Topic Reference Lists
Division
Public Assistance
General Topic
Specific Topic
Applicant Eligibility
Preliminary Damage Assessments
Facility Eligibility
Contracting
Cost Eligibility
Procurement
Work Eligibility
Appeals
Debris Removal (Cat A)
Closeouts
Emergency Protective Measures (Cat B)
Mission Assignments/Memoranda of
Understanding/Inter-Agency Agreements
Road Systems and Bridges (Cat C)
Hazard Mitigation
Water Control Facilities (Cat D)
Insurance
Buildings, Contents and Equipment (Cat E)
Improved Projects
Utilities (Cat F)
Alternate Projects
Parks, Recreational, and Other (Cat G)
Environmental Compliance
Administrative
Repair vs. Replacement (50% Rule)
Codes and Standards
Administrative Costs
Force Account Labor & Equipment
Project Management Costs
Duplication of Benefits
Application Process
Accounting
Legal Responsibility
Division
General Topic
Specific Topic
Direct Housing
Housing
Financial Assistance
Other Needs Assistance
Other Needs Assistance
Sheltering
Mass Care
Health Care/ Mental Health
Emergency Food and Shelter Program
Disaster Unemployment Assistance
Disaster Legal Services
Individual Assistance
Community Services
Crisis Counseling Program
Voluntary Organizations Active in Disasters
Disaster Recovery Centers
Disaster Case Management
Contracts
Process/Administration
Preliminary Damage Assessment
Mission Assignments/Memoranda of
Understanding/Inter-Agency Agreements
Back to Top
Analysis of GAO/OIG Audits 2011-2014
21 of 33 | P a g e s
Division
National Processing
Service Centers
General Topic
Specific Topic
Customer Service
N/A
Helpline
N/A
Registration Intake
N/A
Definition
Examples
Causes Reference List
Cause
Guidance
The documents that provide direction, statements,
rules, and procedures to external stakeholders at all
levels, and/or FEMA staff.
Analysis, Data, and
Technology
The ability to:
•
Collect, report, and integrate data;
•
Perform data and program analysis;
•
Assess, procure, and use technology to
best administer Recovery programs.
Review/Oversight
The ability to ensure that disaster Recovery
programs are implemented properly and used for
their stated purpose.
People
Planning
Communication
Training/Exercises
Back to Top
There are an appropriate number of people
completing a task or mission, and that the roles and
responsibilities of those people are correctly
apportioned.
FEMA and its partners have appropriately developed
consistent actions to better recover from disasters.
This includes the implementation of previous lessons
learned.
The ability to convey information to, collect
information from, and cooperate with all whole
community partners to achieve our mission.
FEMA’s staff and partners have been properly
trained to administer Recovery’s programs, as well
as having tested that knowledge through disaster
simulations.
Analysis of GAO/OIG Audits 2011-2014
Directives
Guidance
Policies
Standard Operating Procedures
Rulemaking/Regulations
Data Analysis
Data Systems Integration
Data Tracking and Reporting
Technology
Cost Benefit Analysis
Risk Analysis
Non-Compliance
Oversight
Review
Fraud/Waste/Abuse
Internal Controls
Personnel
Agency Roles and Responsibility
Staff Roles and Responsibility
Applicant Planning
Lessons Learned
Operations Planning
Interagency Cooperation
Regional/JFO/LTRO/HQ Interaction
Information Sharing
Exercises/tests
Training
22 of 33 | P a g e s
Appendix D: Definitions
Public Assistance
General Topics
Applicant Eligibility: Whether the entity applying for assistance under the PA Program falls into the four categories
of eligible applicants - State governments, local governments, Indian Tribes or authorized Tribal organizations and
Alaskan Native Villages, and PNP organizations; whether the entity has legal responsibility to repair or replace a
facility (includes issues regarding whether entity owns or occupies a facility).
Facility Eligibility: Whether the building, works, system, equipment, or improved natural feature on which work
will be done by the applicant is eligible under the PA program (e.g., buildings, roads, utilities, parks, etc.).
Cost Eligibility: Whether FEMA can reimburse a cost claimed by a grantee or sub grantee; determined only after
the applicant and facility have been deemed eligible.
Work Eligibility: Whether the work completed by a grantee or sub grantee is consistent with the Public Assistance
Program; whether the funding is being used within the scope of work (i.e., for the specific project for which
funding was allocated); whether the funding is being used on a facility that was damaged or destroyed as a result of
the disaster.
Debris Removal (Cat A): A type of work done in the PA program that includes the removal of trees and woody
debris; building components or contents; sand, mud, silt, and gravel; wreckage produced during conduct of
emergency protective measures (e.g., drywall); and other disaster-related wreckage to eliminate immediate threats
to lives, public health, safety, and improved property; ensure economic recovery, or; mitigate the risk to lives and
property.
Emergency Protective Measures (Cat B): A type of work done in the PA program undertaken by a community
before, during, and following a disaster that are necessary to eliminate or reduce an immediate threat to life, public
health, or safety; or eliminate or reduce an immediate threat of significant damage to improved public.
Road Systems and Bridges (Cat C): A type of work done in the PA program on roads, bridges, and associated
facilities (e.g., auxiliary structures, lighting, and signage); also includes storm drain systems.
Water Control Facilities (Cat D): A type of work done in the PA program on Water Control Facilities, to include
– dams and reservoirs; levees; lined and unlined engineered draining channels; canals; aqueducts; sediment basins;
shore protective devices; irrigation facilities, and; pumping facilities.
Buildings, Contents, and Equipment (Cat E): A type of work done in the PA program on buildings, structural
components, interior systems such as electrical or mechanical work, equipment, and contents including furnishings.
Utilities (Cat F): A type of work done in the PA program on water treatment plants and delivery systems; power
generation and distribution facilities, including natural gas systems, wind turbines, generators, substations, and
power lines; sewage collection systems and treatment plants; and communications.
Parks, Recreational and Other (Cat G): A type of work done in the PA program on mass transit facilities such as
railways; playground equipment; swimming pools; bath houses; tennis courts; boat docks; piers; picnic tables; golf
courses; fish hatcheries; and facilities that do not fit Categories C-F.
Administrative: The process and procedures by which the Public Assistance program is administered and
implemented.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
23 of 33 | P a g e s
Specific Topics
Accounting: The act of and the tools used to properly capture information associated the PA program, such as
costs, projects, and other necessary data to ensure the correct application of the PA program.
Administrative Costs: The costs to the applicant associated with delivering the grant.
Alternate Projects: When an applicant determines that the public welfare would not be best served by restoring a
damaged facility or its function, the applicant may use the PA grant for that facility for other eligible purposes.
Appeals: The opportunity for applicants to request reconsideration of FEMA determinations regarding application
for or the provision of assistance. There are two levels of appeal. The first level appeal is to the RA. The second
level appeal is to FEMA Headquarters.
Application Process: The process by which grantees and sub-grantees receive eligible assistance from the PA
program.
Closeouts: When FEMA assures that all of the grants awarded under the PA Program for a given disaster meet the
statutory and regulatory requirements governing the program. To achieve programmatic closure, FEMA ensures
that all funds have been obligated.
Codes and Standards: When a facility must be repaired or replaced, FEMA may pay for upgrades that are
necessary to meet specific requirements of reasonable current codes and standards.
Contracting: The process of carrying out a contract, including any matters related to the eligibility of contract
costs, monitoring of contracting, or involvement of contractors. Contracting encompasses, but involves more than,
procurement. Contracts do not include grants or mutual aid agreements.
Duplication of Benefits: When another source provides money, goods, or services that are a direct duplication of
FEMA awarded grant funding. The Stafford Act prohibits the duplication of benefits.
Environmental and Historical Compliance: When providing funds through the PA program, FEMA must
consider all laws on the environmental and historic preservation. Analyses must be completed to determine whether
the project will run afoul of these laws.
Hazard Mitigation: Cost-effective action taken to prevent or reduce the threat of future damage to a facility.
Improved Projects: When an applicant decides to use the opportunity to make improvements to the facility while
still restoring its pre-disaster function and at least its pre-disaster capacity.
Insurance: A practice or arrangement by which a company or government agency provides a guarantee of
compensation for specified loss, damage, illness, or death in return for payment of a premium. OIG
recommendations regarding insurance may deal with a variety of issues including deductibles, self-insurance,
insurance reviews, and insurance proceeds.
Legal Responsibility: Whether the applicant is legally responsible for the repair of the subject of the project (e.g.,
facilities, roads, parks, utilities) or the performance of eligible emergency services at the time of the disaster.
Mission Assignments/Memoranda of Understanding/Inter-Agency Agreements: Tools by which FEMA
coordinates with other federal agencies to provide services and goods to disaster survivors in their Recovery.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
24 of 33 | P a g e s
Preliminary Damage Assessments: An assessment performed to document the impact and magnitude of the
disaster on individuals, families, businesses, and public property and to gather information for disaster management
purposes.
Procurement: The pre-award process related to bidding, solicitation, acquisition, competition, and cost-price
analysis for a contract for goods or services (including construction).
Repair vs. Replacement (50% Rule): FEMA will restore an eligible facility to its pre-disaster design. To
determine the eligible cost of doing so, FEMA applies the 50% Rule to determine whether the cost to repair the
building to its pre-disaster design is eligible or if the cost to replace the building to its pre-disaster design is eligible.
Force Account Labor & Equipment: Labor performed by the applicant’s employees, rather than by a contractor;
certain ownership and operating costs for force account (i.e., applicant-owned) equipment.
Project Management Costs: The costs to the applicant associated with oversight of an eligible project from the
design phase to the completion of work.
Individual Assistance
General Topics
Community Services: Services and programs delivered at the community level that encourages quicker and more
efficient recovery. This includes services such as Disaster Recovery Centers, and programs such as Crisis
Counseling and Disaster Case Management.
Housing: IA programs that deliver assistance through both financial grants and direct means to assist disaster
survivors in finding intermediate and long term housing options.
Mass Care: The provision of immediate needs for disaster survivors to include food, the distribution of goods, and
sheltering.
Other Needs Assistance: Financial grants available for necessary expenses and serious needs caused by the
disaster, such as disaster-related medical and dental expenses; disaster-related funeral and burial expenses clothing;
household items; tools required for your job; necessary educational materials; fuels for primary heat source; cleanup items; disaster-related damage to a vehicle, and; moving and storage expenses related to the disaster.
Process/Administration: The process and procedures by which the Individual Assistance program is administered
and implemented.
Specific Topics
Contracts: A mutually binding legal relationship obligating the seller to furnish the supplies or services (including
construction) and the buyer to pay for them. It includes all types of written commitments of funds, including (but
not limited to) awards and notices of awards; job orders or task letters issued under basic ordering agreements;
letter contracts; orders, such as purchase orders, under which the contract becomes effective by written acceptance
or performance; and bilateral contract modifications. Contracts do not include grants and cooperative agreements.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
25 of 33 | P a g e s
Crisis Counseling Program: A program that assists individuals and communities in recovering from the effects of
natural and human-caused disasters through the provision of community-based outreach and psycho-educational
services.
Direct Housing: Programs by which the Individual Assistance provides physical housing options to disaster
survivors. This includes the Permanent Housing Construction, Temporary Housing Units, and Modular Housing
Units programs.
Disaster Case Management: A time-limited process that involves a partnership between a disaster case manager
and a survivor to develop and carry out a Disaster Recovery Plan. This partnership provides the survivor with a
single point of contact to facilitate access to a broad range of resources.
Disaster Legal Services: A program that provides free legal assistance to persons affected by presidentially
declared major disasters. DLS is a federal disaster assistance program operated by the American Bar Association
Young Lawyers Division. DLS delivers free legal services on legal matters that arise directly from major disasters.
Disaster Recovery Centers: A physical area in or near the affected disaster area where FEMA, State, and other
entities provide one-on-one help to survivors to apply for and find assistance.
Disaster Unemployment Assistance: A program that provides temporary benefits to individuals whose
employment or self-employment has been lost or interrupted as a direct result of a major disaster and who are not
eligible for regular unemployment insurance
Emergency Food and Shelter Program: A program intended to supplement and expand ongoing efforts to
provide shelter, food and supportive services for hungry and homeless people across the nation.
Financial Assistance: Programs by which Individual Assistance provides financial assistance grants to disaster
survivors to secure safe and secure intermediate and long-term housing. This includes the Lodging Expenses
Reimbursement and Rental Assistance programs.
Health Care/ Mental Health: Related to the prevention, treatment, and management of illness and the preservation
of mental (including emotional, psychological, and social) and physical well-being through the services offered by
the medical and allied health professions.
Mission Assignments/Memoranda of Understanding/Inter-Agency Agreements: Tools by which FEMA
coordinates with other federal agencies to provide services and goods to disaster survivors in their Recovery.
Other Needs Assistance: Financial grants available for necessary expenses and serious needs caused by the
disaster, such as disaster-related medical and dental expenses; disaster-related funeral and burial expenses clothing;
household items; tools required for your job; necessary educational materials; fuels for primary heat source; cleanup items; disaster-related damage to a vehicle, and; moving and storage expenses related to the disaster.
Preliminary Damage Assessment: An assessment performed to document the impact and magnitude of the
disaster on individuals, families, businesses, and public property and to gather information for disaster management
purposes.
Sheltering: A program and service that provides immediate housing options to disaster survivors. Other Recovery
programs help to transition survivors out of shelters as more intermediate and long-term housing options are
identified.
Voluntary Organizations Active in Disasters: The coordination of voluntary agency activity in times of disaster
to achieve the most comprehensive recovery for disaster survivors.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
26 of 33 | P a g e s
National Processing Service Centers
General Topics
Customer Service: How well disaster survivors’ needs are met when they contact the NPSC to apply for and
follow up on disaster assistance.
Helpline: The means by which disaster survivors’ contacts the NPSC.
Registration Intake: The process and procedures by which the NPSC registers disaster survivors for assistance,
this also includes the process and procures by which applicants check on their status, as well as process appeals.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
27 of 33 | P a g e s
Appendix E: Dashboard Materials
Audit Dashboard Screenshot
The audit/recommendation analysis and quantitative reporting can be viewed through an automated filtering tool in Excel.
Filters to provide a count of each Topic and Cause and update the quantitative
reports. Filter by:
• Audit or Recommendation
• GAO or OIG
• Division
• HQ or Region
• Specific Region
• Specific LTRO/TRO
Focus on particular Topics or Causes by filtering only those
audits/recommendations that were coded for the selected
parameters. Multiple selections can be made. Click on “1” to
filter for reports that did include the parameter; click on “0”
to filter for reports that excluded that parameter.
Back to Top
Each time a filter is added, the total frequency and
dollar amount questioned in the audit or
recommendation is updated to include only those
coded for the selected parameters.
The filters on this Dashboard will also update two separate report tabs (pictured on
the next page):
1. Report Summary – Charts of the
2. Report Details – Lists the actual
top topics and causes and
audits or recommendations that have
associated questioned costs for the
been filtered through the dashboard
selected parameters
Analysis of GAO/OIG Audits 2011-2014
28 of 33 | P a g e s
Report Summary Screenshot
Report Summary tab based on
the filtered results for PA –
Debris Removal (Cat A).
Report Details Screenshot
Report Details tab based on
the filtered results for PA –
Debris Removal (Cat A).
Back to Top
Analysis of GAO/OIG Audits 2011-2014
29 of 33 | P a g e s
Summary of General Topics Chart (Recommendations)
General Topic
Interconnected Topics and Causes
PA Eligibility
Topic
PA - Cost Eligibility
PA - Work Eligibility
PA - Applicant Eligibility
Frequency
Cost
Count
%
Count
%
Count
%
# of Occurrences
Questioned Cost
PA - Administrative
Top Five General Topics
138
36.7%
PA - Accounting
Top Five Specific Topics
221
58.8%
Review/Oversight
Top Five Causes
370
98.4%
PA - Buildings, Contents and Equipment (Cat E)
113
30.1%
PA - Contracting
111
29.5%
Communication
60
16.0%
PA - Debris Removal (Cat A)
76
20.2%
PA - Duplication of Benefits
76
20.2%
Procedures
49
13.0%
PA - Work Eligibility
65
17.3%
PA - Procurement
62
16.5%
People
11
376
$776,150,073
Percentage of Total Recs
Percentage of Total Cost
55.3%
67.5%
PA - Emergency Protective Measures (Cat B)
51
13.6%
PA - Force Account Labor & Equipment
50
13.3%
Analysis, Data, and Technology
8
2.1%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
65
44.2%
PA - Accounting
97
66.0%
Review/Oversight
144
98.0%
147
$291,661,128
PA - Administrative
50
34.0%
PA - Closeouts
24
16.3%
Communication
27
18.4%
Percentage of Total Recs
Percentage of Total Cost
PA - Buildings, Contents and Equipment (Cat E)
31
21.1%
PA - Contracting
22
15.0%
Procedures
16
10.9%
21.6%
25.4%
PA - Debris Removal (Cat A)
26
17.7%
PA - Duplication of Benefits
17
11.6%
People
8
5.4%
PA - Road Systems and Bridges (Cat C)
20
13.6%
PA - Force Account Labor & Equipment
16
10.9%
Guidance
2
1.4%
# of Occurrences
Questioned Cost
PA - Buildings, Contents and Equipment (Cat E)
10
33.3%
PA - Legal Responsibility
15
50.0%
Review/Oversight
28
93.3%
2.9%
30
$146,376,216
PA - Work Eligibility
9
30.0%
PA - Accounting
13
43.3%
People
11
36.7%
Percentage of Total Recs
Percentage of Total Cost
PA - Cost Eligibility
8
26.7%
PA - Contracting
6
20.0%
Procedures
11
36.7%
4.4%
12.7%
PA - Administrative
8
26.7%
PA - Procurement
5
16.7%
Communication
10
33.3%
PA - Facility Eligibility
6
20.0%
PA - Application Process
5
16.7%
Analysis, Data, and Technology
5
16.7%
Interconnected Topics and Causes
PA Category or Administrative
Topic
PA - Administrative
PA - Buildings, Contents and Equipment (Cat E)
PA - Debris Removal (Cat A)
PA - Emergency Protective Measures (Cat B)
PA - Utilities (Cat F)
PA - Road Systems and Bridges (Cat C)
Frequency
Cost
Count
%
Count
%
Count
%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
138
40.1%
PA - Accounting
264
76.7%
Review/Oversight
320
93.0%
344
$212,908,082
PA - Buildings, Contents and Equipment (Cat E)
Top Five General Topics
64
18.6%
PA - Contracting
Top Five Specific Topics
91
26.5%
Communication
Top Five Causes
143
41.6%
Percentage of Total Recs
Percentage of Total Cost
PA - Work Eligibility
50
14.5%
PA - Procurement
52
15.1%
Procedures
76
22.1%
50.6%
18.5%
PA - Debris Removal (Cat A)
50
14.5%
PA - Closeouts
46
13.4%
Analysis, Data, and Technology
30
8.7%
PA - Emergency Protective Measures (Cat B)
18
5.2%
PA - Force Account Labor & Equipment
30
8.7%
People
27
7.8%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
113
64.9%
PA - Accounting
87
50.0%
Review/Oversight
168
96.6%
174
$631,126,971
PA - Administrative
64
36.8%
PA - Contracting
49
28.2%
Procedures
28
16.1%
Percentage of Total Recs
Percentage of Total Cost
PA - Work Eligibility
31
17.8%
PA - Duplication of Benefits
44
25.3%
Communication
23
13.2%
25.6%
54.9%
PA - Emergency Protective Measures (Cat B)
22
12.6%
PA - Insurance
40
23.0%
People
11
PA - Parks, Recreational, and Other (Cat G)
20
11.5%
PA - Procurement
28
16.1%
Guidance
5
2.9%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
76
66.1%
PA - Accounting
72
62.6%
Review/Oversight
107
93.0%
6.3%
115
$105,282,825
PA - Administrative
50
43.5%
PA - Contracting
38
33.0%
Communication
26
22.6%
Percentage of Total Recs
Percentage of Total Cost
PA - Work Eligibility
26
22.6%
PA - Duplication of Benefits
20
17.4%
Procedures
21
18.3%
16.9%
9.2%
PA - Emergency Protective Measures (Cat B)
19
16.5%
PA - Procurement
17
14.8%
Analysis, Data, and Technology
8
7.0%
PA - Buildings, Contents and Equipment (Cat E)
16
13.9%
PA - Force Account Labor & Equipment
8
7.0%
People
6
5.2%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
51
71.8%
PA - Accounting
43
60.6%
Review/Oversight
71
100.0%
PA - Buildings, Contents and Equipment (Cat E)
22
31.0%
PA - Contracting
18
25.4%
Communication
13
18.3%
PA - Work Eligibility
19
26.8%
PA - Duplication of Benefits
13
18.3%
Procedures
4
5.6%
PA - Debris Removal (Cat A)
19
26.8%
PA - Closeouts
11
15.5%
Analysis, Data, and Technology
2
PA - Administrative
18
25.4%
PA - Force Account Labor & Equipment
10
14.1%
People
2
2.8%
71
$83,856,522
Percentage of Total Recs
Percentage of Total Cost
10.4%
7.3%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
40
69.0%
PA - Accounting
31
53.4%
Review/Oversight
56
96.6%
PA - Administrative
15
25.9%
PA - Contracting
26
44.8%
Procedures
18
31.0%
PA - Debris Removal (Cat A)
9
15.5%
PA - Procurement
20
34.5%
Communication
11
19.0%
PA - Work Eligibility
8
13.8%
PA - Duplication of Benefits
5
8.6%
People
2
3.4%
PA - Emergency Protective Measures (Cat B)
7
12.1%
PA - Closeouts
5
8.6%
Analysis, Data, and Technology
1
1.7%
98.0%
2.8%
58
$77,425,201
Percentage of Total Recs
Percentage of Total Cost
8.5%
6.7%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
37
72.5%
PA - Accounting
33
64.7%
Review/Oversight
50
51
$38,407,405
PA - Work Eligibility
20
39.2%
PA - Contracting
15
29.4%
Communication
9
17.6%
Percentage of Total Recs
Percentage of Total Cost
PA - Administrative
16
31.4%
PA - Procurement
12
23.5%
Procedures
8
15.7%
PA - Water Control Facilities (Cat D)
8
15.7%
PA - Duplication of Benefits
9
17.6%
Analysis, Data, and Technology
3
5.9%
PA - Buildings, Contents and Equipment (Cat E)
8
15.7%
PA - Force Account Labor & Equipment
7
13.7%
People
1
2.0%
7.5%
3.3%
Interconnected Topics and Causes
IA
Topic
IA - Process/Administration
IA - Housing
Count
%
Count
%
Count
%
IA - Housing
14
63.6%
IA - Direct Housing
10
45.5%
Procedures
14
63.6%
PA - Administrative
Top Five General Topics
5
22.7%
IA - Other Needs Assistance
4
18.2%
Review/Oversight
11
50.0%
IA - Other Needs Assistance
4
18.2%
IA - Financial Assistance
4
18.2%
Analysis, Data, and Technology
10
45.5%
IA - Community Services
2
9.1%
IA - Mas/MOUs/Inter-Agency Agreements
3
13.6%
Communication
10
45.5%
NPSC - Registration Intake
2
9.1%
IA - Contracts
3
13.6%
Guidance
9
40.9%
Questioned Cost
IA - Process/Administration
14
93.3%
IA - Direct Housing
11
73.3%
Procedures
11
73.3%
15
$76,000,000
IA - Other Needs Assistance
4
26.7%
Percentage of Total Recs
Percentage of Total Cost
NPSC - Registration Intake
2
13.3%
Frequency
Cost
# of Occurrences
Questioned Cost
22
$76,000,000
Percentage of Total Recs
Percentage of Total Cost
3.2%
6.6%
# of Occurrences
2.2%
6.6%
Top Five Specific Topics
IA - Other Needs Assistance
4
26.7%
Analysis, Data, and Technology
8
53.3%
IA - Financial Assistance
4
26.7%
Review/Oversight
6
40.0%
N/A
IA - Mas/MOUs/Inter-Agency Agreements
3
20.0%
Communication
5
33.3%
N/A
IA - Contracts
2
13.3%
Guidance
5
33.3%
Interconnected Topics and Causes
NPSC
Topic
NPSC - Registration Intake
Frequency
Cost
Count
%
Count
%
# of Occurrences
Questioned Cost
IA - Process/Administration
Top Five General Topics
2
100.0%
IA - Other Needs Assistance
2
100.0%
IA - Other Needs Assistance
2
100.0%
IA - Financial Assistance
2
100.0%
IA - Housing
2
100.0%
N/A
2
$0
Percentage of Total Recs
Percentage of Total Cost
0.3%
0.0%
Top Five Causes
Top Five Specific Topics
Top Five Causes
Review/Oversight
Count
%
2
100.0%
Analysis, Data, and Technology
1
50.0%
Guidance
1
50.0%
1
50.0%
N/A
N/A
Procedures
N/A
N/A
N/A
Since audits and even individual recommendations can touch upon several issues, the general topics are not mutually
exclusive, so recommendations were coded for multiple topics and causes, creating several overlaps. The chart above
shows the most frequently audited general topics for each division regarding recommendations (it does not, however,
show all of the general topics). For each general topic listed, the chart includes the top five (if applicable) interrelated
issues—other general topics, specific topics, and causes. This means that of the recommendations coded for one of
these general topics, the figures to the right show the most frequent coding overlaps among the other topics or causes.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
30 of 33 | P a g e s
Summary of Specific Topics & Causes Chart (Recommendations)
Specific Topic
Interconnected Topics and Causes
Topic
PA - Accounting
PA - Contracting
PA - Procurement
PA - Duplication of Benefits
PA - Closeouts
PA - Insurance
PA - Force Account Labor & Equipment
Frequency
Cost
# of Occurrences
Questioned Cost
397
$415,605,440
Percentage of Total Recs
Percentage of Total Cost
58.4%
36.2%
# of Occurrences
Questioned Cost
179
$309,617,530
Percentage of Total Recs
Percentage of Total Cost
Top Five General Topics
Count
%
Count
%
Count
%
PA - Administrative
264
66.5%
PA - Contracting
82
20.7%
Review/Oversight
390
98.2%
PA - Cost Eligibility
221
55.7%
PA - Closeouts
Top Five Specific Topics
52
13.1%
Communication
Top Five Causes
119
30.0%
13.9%
PA - Work Eligibility
97
24.4%
PA - Force Account Labor & Equipment
40
10.1%
Procedures
55
PA - Buildings, Contents and Equipment (Cat E)
87
21.9%
PA - Duplication of Benefits
39
9.8%
People
20
5.0%
PA - Debris Removal (Cat A)
PA - Cost Eligibility
72
111
18.1%
62.0%
PA - Duplication of Benefits
PA - Procurement
38
104
9.6%
58.1%
Analysis, Data, and Technology
Review/Oversight
18
175
4.5%
97.8%
PA - Administrative
91
50.8%
PA - Accounting
82
45.8%
Communication
65
36.3%
PA - Buildings, Contents and Equipment (Cat E)
49
27.4%
PA - Duplication of Benefits
8
4.5%
Procedures
53
29.6%
People
11
6.1%
Analysis, Data, and Technology
Review/Oversight
6
102
3.4%
98.1%
26.3%
26.9%
PA - Debris Removal (Cat A)
38
21.2%
PA - Force Account Labor & Equipment
4
2.2%
# of Occurrences
Questioned Cost
PA - Utilities (Cat F)
PA - Cost Eligibility
26
62
14.5%
59.6%
PA - Closeouts
PA - Contracting
4
104
2.2%
100.0%
104
$266,588,195
PA - Administrative
52
50.0%
PA - Accounting
38
36.5%
Communication
51
49.0%
Percentage of Total Recs
Percentage of Total Cost
PA - Buildings, Contents and Equipment (Cat E)
28
26.9%
PA - Legal Responsibility
3
2.9%
Procedures
45
43.3%
PA - Utilities (Cat F)
20
19.2%
PA - Closeouts
2
1.9%
People
6
5.8%
17
76
16.3%
80.0%
PA - Project Management Costs
PA - Accounting
1
39
1.0%
41.1%
Analysis, Data, and Technology
Review/Oversight
5
93
4.8%
97.9%
44
46.3%
PA - Insurance
34
35.8%
Communication
6
6.3%
15.3%
23.2%
# of Occurrences
Questioned Cost
PA - Debris Removal (Cat A)
PA - Cost Eligibility
95
$143,899,270
PA - Buildings, Contents and Equipment (Cat E)
Percentage of Total Recs
Percentage of Total Cost
PA - Administrative
25
26.3%
PA - Contracting
8
8.4%
Analysis, Data, and Technology
3
3.2%
PA - Debris Removal (Cat A)
20
21.1%
PA - Administrative Costs
6
6.3%
People
2
2.1%
17
46
17.9%
58.2%
PA - Force Account Labor & Equipment
PA - Accounting
5
52
5.3%
65.8%
Procedures
Review/Oversight
2
76
2.1%
96.2%
14.0%
12.5%
# of Occurrences
Questioned Cost
PA - Work Eligibility
PA - Administrative
79
$39,947,571
PA - Cost Eligibility
38
48.1%
PA - Duplication of Benefits
5
6.3%
Communication
21
26.6%
Percentage of Total Recs
Percentage of Total Cost
PA - Work Eligibility
24
30.4%
PA - Contracting
4
5.1%
Procedures
17
21.5%
PA - Buildings, Contents and Equipment (Cat E)
16
20.3%
PA - Procurement
2
2.5%
Analysis, Data, and Technology
2
2.5%
11.6%
3.5%
# of Occurrences
Questioned Cost
PA - Emergency Protective Measures (Cat B)
PA - Cost Eligibility
11
49
13.9%
79.0%
PA - Alternate Projects
PA - Duplication of Benefits
2
34
2.5%
54.8%
Guidance
Review/Oversight
2
58
2.5%
93.5%
62
$246,828,970
PA - Buildings, Contents and Equipment (Cat E)
40
64.5%
PA - Accounting
13
21.0%
Communication
9
14.5%
Percentage of Total Recs
Percentage of Total Cost
PA - Administrative
18
29.0%
PA - Contracting
1
1.6%
Procedures
6
9.7%
9.1%
21.5%
PA - Parks, Recreational, and Other (Cat G)
16
25.8%
PA - Closeouts
1
1.6%
Analysis, Data, and Technology
3
4.8%
# of Occurrences
Questioned Cost
PA - Debris Removal (Cat A)
PA - Cost Eligibility
7
50
11.3%
89.3%
N/A
PA - Accounting
40
71.4%
Guidance
Review/Oversight
2
56
3.2%
100.0%
25.0%
56
$22,355,957
PA - Administrative
30
53.6%
PA - Duplication of Benefits
5
8.9%
Communication
14
Percentage of Total Recs
Percentage of Total Cost
PA - Work Eligibility
16
28.6%
PA - Administrative Costs
4
7.1%
Analysis, Data, and Technology
2
3.6%
8.2%
1.9%
PA - Emergency Protective Measures (Cat B)
10
17.9%
PA - Contracting
4
7.1%
Procedures
2
3.6%
PA - Debris Removal (Cat A)
8
14.3%
PA - Improved Projects
2
3.6%
Training/Exercises
1
1.8%
Frequency
Cost
Count
%
Cause
Interconnected Topics and Causes
Topic
Review/Oversight
Communication
Procedures
Analysis, Data, and Technology
People
Guidance
Top Five General Topics
Count
%
# of Occurrences
Questioned Cost
PA - Cost Eligibility
370
58.3%
PA - Accounting
390
61.4%
Communication
173
27.2%
635
$1,072,918,076
PA - Administrative
320
50.4%
PA - Contracting
Top Five Specific Topics
Count
175
27.6%
%
Procedures
Top Five Causes
109
17.2%
Percentage of Total Recs
Percentage of Total Cost
PA - Buildings, Contents and Equipment (Cat E)
168
26.5%
PA - Procurement
102
16.1%
People
38
6.0%
93.4%
93.3%
PA - Work Eligibility
144
22.7%
PA - Duplication of Benefits
93
14.6%
Analysis, Data, and Technology
23
3.6%
# of Occurrences
Questioned Cost
PA - Debris Removal (Cat A)
PA - Administrative
107
143
16.9%
73.7%
PA - Closeouts
PA - Accounting
76
119
12.0%
61.3%
Guidance
Review/Oversight
12
173
1.9%
89.2%
194
$128,880,441
PA - Cost Eligibility
60
30.9%
PA - Contracting
65
33.5%
Procedures
60
30.9%
Percentage of Total Recs
Percentage of Total Cost
PA - Work Eligibility
27
13.9%
PA - Procurement
51
26.3%
People
32
16.5%
28.5%
11.2%
PA - Debris Removal (Cat A)
26
13.4%
PA - Closeouts
21
10.8%
Guidance
19
9.8%
# of Occurrences
Questioned Cost
PA - Buildings, Contents and Equipment (Cat E)
PA - Administrative
23
76
11.9%
55.1%
PA - Force Account Labor & Equipment
PA - Accounting
14
55
7.2%
39.9%
Analysis, Data, and Technology
Review/Oversight
14
109
7.2%
79.0%
PA - Cost Eligibility
49
35.5%
PA - Contracting
53
38.4%
Communication
60
43.5%
PA - Buildings, Contents and Equipment (Cat E)
28
20.3%
PA - Procurement
45
32.6%
Analysis, Data, and Technology
25
18.1%
PA - Debris Removal (Cat A)
21
15.2%
PA - Closeouts
17
12.3%
People
24
17.4%
PA - Utilities (Cat F)
PA - Administrative
18
30
13.0%
65.2%
IA - Direct Housing
PA - Accounting
8
18
5.8%
39.1%
Guidance
Procedures
22
25
15.9%
54.3%
IA - Process/Administration
10
21.7%
IA - Direct Housing
6
13.0%
138
$278,125,035
Percentage of Total Recs
Percentage of Total Cost
20.3%
24.2%
# of Occurrences
Questioned Cost
46
$76,033,223
Percentage of Total Recs
Percentage of Total Cost
6.8%
6.6%
# of Occurrences
Questioned Cost
45
$45,511,222
Percentage of Total Recs
Percentage of Total Cost
6.6%
4.0%
# of Occurrences
Questioned Cost
29
$76,117,951
Percentage of Total Recs
Percentage of Total Cost
4.3%
6.6%
Review/Oversight
23
50.0%
PA - Cost Eligibility
8
17.4%
PA - Contracting
6
13.0%
Communication
14
30.4%
PA - Debris Removal (Cat A)
8
17.4%
PA - Procurement
5
10.9%
People
6
13.0%
IA - Housing
PA - Administrative
8
27
17.4%
60.0%
PA - Application Process
PA - Accounting
4
20
8.7%
44.4%
Guidance
Review/Oversight
4
38
8.7%
84.4%
PA - Applicant Eligibility
11
24.4%
PA - Legal Responsibility
13
28.9%
Communication
32
71.1%
PA - Cost Eligibility
11
24.4%
PA - Contracting
11
24.4%
Procedures
24
53.3%
PA - Buildings, Contents and Equipment (Cat E)
11
24.4%
PA - Procurement
6
13.3%
Guidance
8
17.8%
PA - Work Eligibility
PA - Administrative
8
19
17.8%
65.5%
PA - Duplication of Benefits
PA - Accounting
2
8
4.4%
27.6%
Analysis, Data, and Technology
Procedures
6
22
13.3%
75.9%
IA - Process/Administration
9
31.0%
PA - Contracting
6
20.7%
Communication
19
65.5%
PA - Buildings, Contents and Equipment (Cat E)
5
17.2%
PA - Procurement
4
13.8%
Review/Oversight
12
41.4%
IA - Housing
5
17.2%
IA - Direct Housing
4
13.8%
People
8
27.6%
PA - Debris Removal (Cat A)
4
13.8%
PA - Repair vs. Replacement (50% Rule)
3
10.3%
Analysis, Data, and Technology
4
13.8%
As with the previous chart, since audits and individual recommendations can touch upon several issues, the specific
topics and causes are not mutually exclusive. The charts above show the most frequently audited specific topics (top
chart) and causes (bottom chart) (they do not, however, show all the specific topics or causes). For each specific topic
and cause, the charts include the top five (if applicable) interrelated issues—other general topics, specific topics, and
causes. This means that of the recommendations coded for one of these specific topics or causes, the figures to the right
show the most frequent coding overlaps among the other topics or causes.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
31 of 33 | P a g e s
Appendix F: Table of Audits Related to Public Assistance Second Appeals
Report #
Auditor
Audited
Final
Report Date
Disaster
Audit Title
# of Recovery Related
Recommendations
Questioned Costs
DA-11-14
OIG
Region 4
4/15/2011
1546-DR-NC
North Carolina Department of Transportation - Disaster Activities Related
to Tropical Storm Frances
2
$63,095
DA-12-23
OIG
Region 4
8/27/2012
1539-DR-FL
South Florida Water Management District [Hurricane Charley]
3
$3,162,692
DA-12-24
OIG
Region 4
8/27/2012
1561-DR-FL
FEMA Public Assistance Grant Funds Awarded to South Florida Water
Management District Under Hurricane Jeanne
2
$1,814,495
DA-12-26
OIG
Region 4
8/27/2012
1545-DR-FL
South Florida Water Management District
6
$10,180,530
DD-13-09
OIG
HQ; R7
5/1/2013
1763-DR-IA
FEMA Should Recover $13.8 Million in FEMA Public Assistance Funds
Awarded to Cedar Rapids, Iowa, for Ineligible Hydroelectric Plant
1
$13,786,951
OIG-1401-D
OIG
Region 6;
Louisiana
TRO
10/24/2013
1786-DR-LA
FEMA's Application of Rules and Federal Regulations in Determining
Debris Removal Eligibility for Livingston Parish, Louisiana
N/A
N/A
This list was created by cross-checking the list of regional audits with the list of cases going through PA Second Appeals (6 total of the audits analyzed). There
were a number of audits that were originally assigned to a Region in which OIG recommended FEMA disallow costs or deobligate funds. Subsequently, the
Region likely concurred with the recommendation and disallowed the costs or deobligated the funds, and the applicant appealed. The Region then denied the
First Appeal, and the applicant made a Second Appeal, which is handled by HQ. At some point, the OIG may have closed the audit as completely implemented,
but because of a PA Second Appeal in which Recovery may overturn a decision that concurred with an OIG recommendation, the audit may be reopened.
Therefore, any audits related to appeals are considered active for Recovery purposes. However, this list is limited to audits related to Second Appeals. For future
audit operations, Recovery needs to confer with the Regions and the PA Appeals Section to determine which audits are related to a First Appeal.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
32 of 33 | P a g e s
Appendix G: All Audits Analyzed
The full list of audits analyzed is available on the Recovery Audits SharePoint site. Below is a screenshot of the list, and here is the direct link to that list. Several
sub-set views of this list have also been created for each jurisdiction (HQ; Region; LTRO/TRO); whether the audit was positive in nature (16 total); audits with no
recommendations (27 total); 25 and whether the audit was implicated in a PA Second Appeal, as discussed above (6 total).
25
This is distinct from “positive” audits because even if the audit does not have a recommendation, it could still be critical of FEMA’s actions. Those scenarios arise when FEMA
worked with OIG to resolve a negative finding before the final report was issued, so no recommendations were necessary.
Back to Top
Analysis of GAO/OIG Audits 2011-2014
33 of 33 | P a g e s