oversight

Better Oversight and Planning are Needed to Improve FEMA's Transitional Sheltering Assistance Program

Published by the Department of Homeland Security, Office of Inspector General on 2021-02-11.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

Better Oversight and
Planning are Needed to
Improve FEMA's
Transitional Sheltering
Assistance Program




                    February 11, 2021
                           OIG-21-20
                  OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security
                        Washington, DC 20528 / www.oig.dhs.gov



                               February 11, 2021

MEMORANDUM FOR:         Robert Fenton
                        Senior Official Performing the Duties of the
                        Administrator
                        Federal Emergency Management Agency               4 F




FROM:                   Joseph V. Cuffari, Ph.D.         JOSEPH V       Digitally signed by JOSEPH V
                        Inspector General                               CUFFARI

                                                         CUFFARI
                                             6 F



                                                                        Date: 2021.02.10 15:35:02 -05'00'



SUBJECT:                Better Oversight and Planning Are Needed to Improve
                        FEMA’s Transitional Sheltering Assistance Program

For your action is our final report, Better Oversight and Planning are Needed to
Improve FEMA’s Transitional Sheltering Assistance Program. We incorporated
the formal comments provided by your office.       9 F




The report contains two recommendations aimed at improving the Transitional
Sheltering Assistance program. Your office concurred with both
recommendations. Based on information provided in your response to the
draft report, we consider recommendations 1 and 2 open and resolved. Once
your office has fully implemented the recommendations, please submit a formal
closeout letter to us within 30 days so that we may close the recommendations.
The memorandum should be accompanied by evidence of completion of agreed-
upon corrective actions and of the disposition of any monetary amounts.
Please send your response or closure request to
OIGAuditsFollowup@oig.dhs.gov.

Consistent with our responsibility under the Inspector General Act of 1978, as
amended, we will provide copies of our report to congressional committees with
oversight and appropriation responsibility over the Department of Homeland
Security. We will post the report on our website for public dissemination.

Please call me with any questions, or your staff may contact Thomas Kait,
                                                                 16 F




Acting Assistant Inspector General for Audits, at (202) 981-6000.               18
                                                                                F




Attachment




www.oig.dhs.gov
                                  DHS OIG HIGHLIGHTS
                          Better Oversight and Planning Are
                        Needed to Improve FEMA’s Transitional
                            Sheltering Assistance Program

February 11, 2021                                         What We Found                   26F




Why We Did                                                The Federal Emergency Management Agency
                                                          (FEMA) provided hotel rooms to about 90,000
This Audit                        19F



                                                          households (nearly 227,000 survivors) after the
                                                                             27F                                 28F




                                                          2017 California wildfires and Hurricanes Harvey,
 FEMA is responsible for                                  Irma, and Maria. However, FEMA did not oversee
 helping state and                                        and manage the Transitional Sheltering Assistance
 territorial governments                                  (TSA) program to ensure it operated efficiently and
 
 develop pre-disaster                                     effectively to meet disaster survivors’ needs.                            30F




 plans for mass care,                                     Specifically, FEMA:
 emergency assistance,
 transitional sheltering,                                     did not accurately validate taxes charged for
 interim housing, and                                          hotel rooms and did not ensure the contractor
                                                                                   31F




 human services. For the    20F


                                                               responsible for administering the TSA program
 2017 disasters, FEMA                                          maintained accurate records to show taxes
 spent about $642 million                                      charged were reasonable and allocable;                         32F




 for hotel rooms for                                          paid for unoccupied rooms;
 disaster survivors in the
                                                                                                      3F




                                                              did not transition survivors from TSA hotels to
 TSA program. We      21F



                                                               interim or permanent housing timely; and
 conducted this audit to
                                                                                                                       34F




                                                              did not adequately coordinate with states and
 determine to what extent                                      a territory to prepare initial housing strategies.
 FEMA met survivors’
                                                                                                                                                35F




 transitional sheltering                                  The deficiencies occurred because FEMA officials
 needs.   2F




                                                          did not establish standard operating procedures
                                                          and a dedicated program office with sufficient staff
What We                                                   to support the TSA program. As a result, FEMA
                                                          paid more than $55.8 million in unverified taxes,
Recommend                               23F




                                                          disbursed indeterminate amounts for unoccupied
                                                                                                                                          37F




                                                          rooms, and left over 146,000 disaster survivors to
We made two
                                                                 38F




                                                          remain in hotels for more than the recommended
recommendations that,
                                                                                                           39F




                                                          30 days.
when implemented, will
                                                                       40F




improve FEMA’s
oversight and pre-                                        FEMA Response                         41F




disaster planning of
transitional sheltering.                      24F

                                                          FEMA concurred with both recommendations.

For Further Information                             25F




Contact our Office of Public Affairs at
(202) 981-6000, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov



   www.oig.dhs.gov                                                                                                           OIG-21-20 



    
                           OFFICE OF INSPECTOR GENERAL
                                   Department of Homeland Security


                                                                  Background   42F




In 2017, the Gulf Coast, U.S. Virgin Islands, and Puerto Rico endured major
                                    43F                                   4F                                             45F




hurricanes that made landfall from August through September. During                                                                  46F




October 2017, nearly two dozen wildfires burned more than 200,000 acres of
land in northern California. These events resulted in Presidential declarations
                                          47F




for Hurricanes Harvey in Texas, Hurricane Irma in Florida and Puerto Rico,
                                                      48F                                              49F                                                 50F




Hurricane Maria in Puerto Rico, and the wildfires in California.
                                                            51F                                                                52F




The Robert T. Stafford Disaster Relief and Emergency Assistance Act is the
statutory authority for most Federal disaster response activities, especially for
the Federal Emergency Management Agency (FEMA) and its programs. The                                                                             53F




Response – Federal Interagency Operational Plan (Plan) supports these activities
and describes how the Federal Government should coordinate efforts in
response to disasters. According to the Plan, FEMA is responsible for helping
                             54F




states and other territorial governments develop pre-disaster plans for mass
care, emergency assistance, transitional sheltering, interim housing, and
human services. Before and during disaster response, the Mass Care and
                      5F                                                                         56F




Emergency Assistance Branch (Mass Care), within FEMA’s Office of Response
and Recovery, is directly responsible for preparing and managing the
Transitional Sheltering Assistance (TSA) program.                                    57F




The TSA program is a form of temporary shelter such as hotel rooms for
survivors who will be displaced from 5 to 14 days. The program may extend to
30 days and, in rare cases, can be extended up to 6 months. Survivors qualify                                      58F




for TSA if they:

      are registered with FEMA for assistance and pass identity and citizenship
       verification;
      have a pre-disaster primary residence in the area designated for TSA;
      are displaced from their pre-disaster residence due to the disaster;
      have remained in transitional, congregate, or other shelters; and
      are unable to obtain lodging through another source.                                                  59F




The TSA program is designed to transition survivors from congregate shelters
to hotels. Survivors are then transitioned from hotels and into interim
          60F




housing, if needed, or into a permanent residence. Interim housing is a long-              61F




term option up to 18 months until a permanent housing option becomes
available. Interim housing includes lodging in manufactured homes or FEMA’s
                62F                                                                                                                        63F




short-term leasing programs. For permanent housing, FEMA provides
                                                64F




survivors with financial assistance to make repairs to their pre-disaster



www.oig.dhs.gov                                                       1                                                                                OIG-21-20
                                        OFFICE OF INSPECTOR GENERAL
                                                      Department of Homeland Security


dwellings or enter into leasing agreements. (See Figure 1 and Appendix C for
                    65F                                                                        6F




more details on housing programs and types of sheltering.)

             Figure 1. Types of Temporary Sheltering and Housing Programs




             Source: Office of Inspector General (OIG) analysis of response – Federal Interagency
             Operational Plan (Aug. 2016)                       67F




Since 2005, Corporate Lodging Consultants (CLC) has administered the TSA
program and pays hotels for eligible stays. FEMA awarded CLC its latest                  68F




contract in May 2016. FEMA’s responsibilities for the TSA program include
                                                69F




determining disaster survivors’ eligibility for the TSA program, notifying                                           70F




applicants of their eligibility status, and sending eligibility information to CLC.
                                                                           71                                                         72F




Subsequently, CLC adds disaster survivors’ information to its Emergency
Lodging Assistance system, which allows eligible survivors to check into
                                                          73F




participating hotels anywhere in the Nation. For the 2017 disasters, FEMA                           74




provided hotel rooms to about 90,000 households (nearly 227,000 survivors)                                     75F              76F




and spent approximately $642 million in lodging costs for over 5 million nights 7F




in TSA-participating hotels, as of October 2018.                                                         78F




We conducted this audit to determine to what extent FEMA met survivors’
transitional sheltering needs. This is a follow-up to prior related audits of the
FEMA-TSA contract and program. 1                                      0F




                                                       
1 Management Alert – FEMA Did Not Safeguard Disaster Survivors’ Sensitive Personally

Identifiable Information, OIG-19-32, Mar. 15, 2019; Additional Controls Needed to Better
Manage FEMA’s Transitional Sheltering Assistance Program, OIG-19-37, Mar. 29, 2019; and


www.oig.dhs.gov                                                                      2                                     OIG-21-20
                                              OFFICE OF INSPECTOR GENERAL
                                                  Department of Homeland Security


                                                          Results of Audit                   81F




 
FEMA Did Not Sufficiently Oversee and Manage the TSA
Program                   82 F




FEMA did not sufficiently oversee and manage the TSA program to ensure it
operated efficiently and effectively to meet disaster survivors’ needs.                                        83F




Specifically, FEMA officials did not validate taxes charged for hotel rooms and                                        84F




did not ensure CLC maintained accurate records. FEMA also paid for                     85F




unoccupied rooms and did not ensure timely transition of survivors from hotels
                                        86F




to interim or permanent housing. These deficiencies occurred because FEMA
                                                            87F




officials did not establish a dedicated TSA program office with the staff needed
to develop standard operating procedures and coordinate with states to prepare
                                                                            89F




disaster-housing strategies in advance of disasters.                                               90F




FEMA Did Not Verify Accuracy of Hotel Taxes and Records                                                  91F




According to Standards for Internal Control in the Federal Government, FEMA
must ensure efficient operations that minimize waste of resources. Consistent
with Federal Acquisition Regulations, contractors are responsible for
appropriately accounting for costs by maintaining accurate records to ensure
costs are reasonable and allocable.                               93F




Despite these requirements, FEMA officials did not accurately validate taxes
charged for hotel rooms under the TSA program and did not ensure CLC              94




maintained accurate records to confirm taxes charged were reasonable and
accurate. Specifically, CLC used its Emergency Lodging Assistance system to
                    95F




receive hotel payment requests, in the form of electronic invoices, but did not
require hotels to provide detailed itemization of room rates, taxes, and fees. As                                                  96F




permitted by the TSA contract,2 CLC sent FEMA invoice reports that lumped all
hotel charges together in one total that included room costs, taxes, and fees.                                                           97F




FEMA’s review process to identify erroneous charges on the invoice reports                                                   98F




consisted of only two steps:

      1)            FEMA verified whether the dates billed for the hotel nights were
                    within the survivor’s eligibility period; and

                                                       
FEMA Did Not Properly Award and Oversee the Transitional Sheltering Assistance Contract, OIG-
20-58, Aug. 5, 2020. 
2 FEMA Transitional Sheltering Assistance Contract with CLC (Order Number: HSFE80-16-0211;

May 13, 2016).


www.oig.dhs.gov                                                         3                                            OIG-21-20
                      OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security


   2)        FEMA verified whether the total nightly amounts billed did not exceed
             the FEMA approved lodging rate for the corresponding disasters.          9F




This two-step process could not fully determine if TSA program costs were
allowable and did not permit FEMA to ensure costs were accurate, reasonable,
and allocable as required by Federal Acquisition Regulations. The review
process limited FEMA’s reimbursements to ceilings based on the approved
lodging rates. FEMA’s review process also did not align with the TSA contract
stating FEMA would cover the lodging taxes and fees in addition to applicable
lodging rates. Therefore, FEMA should consider all those components
separately when reviewing hotel charges. As such, the process adversely
affected hotels’ ability to accurately charge room taxes for survivors sheltered
under the TSA program.     103F




Based on our review of lodging data reported to CLC by hotels, we requested an
itemization of the underlying hotel charges including taxes. In February 2019,
CLC provided OIG with data for 4,120 TSA-participating hotels that reported
                                         105F




taxes charged to CLC for rooms supplied to survivors of the 2017 disasters.
These hotels charged about $471 million for about 3.9 million hotel room
                                                    107F




nights, of which $55.8 million was for taxes .             109F




We reviewed the tax data provided by CLC and identified numerous instances
in which the amounts listed in the tax lines did not align with the
corresponding city’s tax rate. For example, the New York, NY tax rate is 14.75
                                  10F




percent. However, according to CLC’s data, the taxes charged by hotels in New
        1F




York city ranged from 1 percent to as high as 22 percent. Similarly, the CLC  12F




data showed tax amounts charged by hotels in Orlando, FL; Houston, TX; and
Santa Rosa, CA, that also did not align with the corresponding city’s tax rates.           13F




We reviewed a judgmental sample of 2,964 hotel bills of which only 744 (about
                                                                  14F




25 percent) matched the corresponding city’s tax rate. (See Table 1 and 15F




Appendix D for details.)




www.oig.dhs.gov                                 4                                   OIG-21-20
                                        OFFICE OF INSPECTOR GENERAL
                                                  Department of Homeland Security


                             Table 1. Percent of Bills with Questionable Tax Charges




                   Source: OIG analysis of CLC data         6F




Without reviewing the itemized costs, FEMA has no assurance the hotel costs
charged were accurate or allowable. We therefore question the accuracy of the
$55.8 million FEMA paid in taxes to hotels during the 2017 disasters.                          18F




 
FEMA Paid for Unoccupied Hotel Rooms                                       19F




To verify applicant eligibility for the TSA program,3 FEMA requires hotel
personnel to ensure disaster survivors complete TSA Terms and Conditions
forms with survivor information, FEMA registration number, check-in date,
            120F




signature, and date acknowledging acceptance of TSA program requirements.                                  12F




As indicated in our March 2019 report , FEMA paid hotels participating in the
                                                                 21F




TSA program for an indeterminate number of unoccupied rooms. For example,               124F




FEMA identified five instances of disaster survivors departing the TSA program
without notifying FEMA or hotel personnel. The hotels continued to bill FEMA     125F




                                                       
3   As required per FEMA’s Transitional Sheltering Assistance Playbook, Aug. 2017.


www.oig.dhs.gov                                                        5                             OIG-21-20
                                        OFFICE OF INSPECTOR GENERAL
                                                  Department of Homeland Security


for the rooms even though the disaster survivors had vacated the hotels. In                                                                                    126F




these five instances, FEMA collectively paid TSA hotels about $4,700 for 41
nights of unoccupied rooms.                                             127F




Although FEMA required disaster survivors to sign and date TSA Terms and
Conditions forms at check-in , FEMA did not require survivors to document or   128F




notify FEMA or hotel personnel upon checkout. Additionally, we determined
that FEMA did not provide information on its TSA Terms and Conditions form
for reporting allegations of fraud, waste, and abuse .4 As a result, FEMA is                                   130F




uncertain about the true magnitude of unnecessary payments for unoccupied
hotel rooms from August 27, 2017, to September 14, 2018 . Further, in
                         31F                                                                                                       132F




response to our March 2019 interim report, FEMA has updated its Terms and
Conditions forms, starting with Hurricane Florence in 2018, to include a
hotline number for reporting fraud.5 

FEMA Did Not Ensure Survivors’ Timely Transition from TSA Hotels to
Interim or Permanent Housing                                                                 134F




The DHS Response Federal Interagency Operational Plan6 and FEMA’s National                                                  135F




Disaster Housing Strategy7 direct FEMA to work with states to create initial
                                                                 136F




housing strategies in preparation for disasters. To do so, FEMA will work with
state entities to conduct joint planning to address housing needs, engage
appropriate stakeholders, identify a range of options, describe how those
options would be implemented, and identify the necessary resources . Once                                                                       138F




disasters occur, FEMA is required to adapt the initial housing strategies to
address actual incidents. An initial housing strategy helps ensure FEMA is
                                                          139F




better prepared and able to transition survivors quickly from congregate and
transitional shelters to interim or permanent housing .                               140F                            14F




However, FEMA did not transition survivors from TSA hotels timely following
the 2017 disasters. FEMA officials acknowledged that the DHS Response
                                          142F                                                          143F




Federal Interagency Operational Plan instructs the component to work with the
states prior to a disaster to develop a temporary housing strategy . However, for                                                         41F




the 2017 disasters, FEMA did not dedicate staff to support this effort, and                                                                            145F




many states did not have temporary housing strategies in place. Further,
FEMA also stated that although some states used housing strategies in 2018,
FEMA did not have a standardized national approach for the 2017 disasters.
Consequently, FEMA allowed TSA program extensions beyond the
                                                       
4   FEMA TSA Terms and Conditions Form – DR-4339-PR (Updated Nov. 1, 2017).
5   FEMA TSA Terms and Conditions Form – DR-4393-NC (Updated Sept. 20, 2018).
6   DHS Response Federal Interagency Operational Plan (Second Edition; Aug. 2016).
7   FEMA’s National Disaster Housing Strategy (Jan. 16, 2009). 


www.oig.dhs.gov                                                                                     6                                                         OIG-21-20
                                                           OFFICE OF INSPECTOR GENERAL
                                                                   Department of Homeland Security


recommended 30-day stay for the 2017 disaster survivors without transitioning                                                                                                                      147F




them to interim or permanent housing as required . To illustrate, FEMA                                                                                        148F




extended hotel stays up to 4 months for all survivors participating in the TSA
Program from the four disasters and did not transition survivors as required.                149F




Further, based on our analysis of the various FEMA Transitional Sheltering
Assistance Extension Request memos, for disaster survivors of Hurricanes Irma,
Maria, and Harvey, FEMA waived the recommended 6-month maximum
timeframe for participation and extended some survivors’ hotel stays to almost
a year.15F




Because FEMA did not have a strategy to transition survivors to interim or
permanent housing, more than 26,700 disaster survivors remained in hotels
                                                            152F




past the TSA Program’s recommended 6-month timeframe. (See Table 2
column A for TSA disaster declaration dates and column B for disaster
survivors participating during the 2017 disasters.)

       Table 2. TSA Activation Timelines and Populations after the 2017
       Hurricanes and Wildfires                                                                     154F




                                                                                                                 Survivors                              Survivors                                                                   Survivors in
                                                            Disaster                                                                                                                             End Date
                                                                                                                 in Hotels                              in Hotels                                                                    Hotels at
    Disaster and                                           Declaration                                                                                                                            for TSA
                                                                                                                  after 3O                               after 6                                                                    End of TSA
     Location                                                 Date                                                                                                                               Programs
                                                                                                                    Days                                 Months                                                                      Programs
                                              15F                      156F                                                                                                                                     159FQQQQ1




                                                               (A)                                                                                                                                  (D)
                                                                                                                              157F                                                 158F                                                                 160F




                                                                                                                     (B)                                   (C)                                                                          (E)

 Hurricane Harvey
                                                           8/25/2017                                             92,278                                 20,919                                   6/30/2018                            1,184
 in Texas
                                                                              162 F                                                         163                             164F                                            165 F




                    61F




 Hurricane Irma in
 Puerto Rico
                                                           9/10/2017          168 F




                                                                                                                 17,000 *                               5,814*                                   9/13/2018                            2,082
                                167F




 Hurricane Maria
                                                                                                                                     169F                            170F                                                   17 F                 172F




                                                           9/20/2017
 in Puerto Rico
                                                                              174 F




                                                    173F




 Hurricane Irma in
 Florida     175F
                                                           9/10/2017                                             36,179                                                            -      178F   3/10/2018                  179 F     2,439      180F




 Wildfires in
 California               18F
                                                           10/10/2017                 182F                         915 183F                                                        -      184F   3/15/2018                  185 F       2 186F




      TOTAL                            187F                                                                      146,372                          18F   26,733          189F                                                          5,707

Source: DHS OIG analysis of FEMA data                                                                      19F




* Combined registrant count for Hurricanes Irma and Maria

Further, thousands of survivors were still sheltering in TSA-participating hotels
when FEMA ended the TSA programs and stopped providing these transitional
sheltering benefits. (See Table 2, columns D and E for details). FEMA was                                                                                                                                 192




www.oig.dhs.gov                                                                                                               7                                                                                                        OIG-21-20
                                              OFFICE OF INSPECTOR GENERAL
                                                            Department of Homeland Security


unable to confirm whether the more than 5,700 survivors in hotels
                                       193F




successfully transitioned to interim or permanent housing.                                                              195F




FEMA Did Not Have Standard Operating Procedures and a Dedicated
Program Office for the TSA Program                                          196F




According to the Standards for Internal Control in the Federal Government,8                                                                                 1F




management should establish an organizational structure, assign
responsibility, and delegate authority to achieve the entity’s objectives. This                                                       197F




entails management providing an understanding of the overall responsibilities,
assigning the responsibilities to discrete business units to enable the
organization to operate in an efficient and effective manner, and implementing
control activities through policies and procedures.                                                 198F




Deficiencies in the TSA program were due to FEMA officials not implementing
                                                                      19F




effective internal controls . Specifically, FEMA did not develop and implement
                                                              20F




standard operating procedures to carry out processes and activities of the TSA
program . Additionally, FEMA did not establish a dedicated program office with
                  201F




staff to oversee and manage the TSA program. FEMA assigned a single
headquarters official as the TSA program manager during the 2017 disasters,
                                                     203F




but the role was secondary to the official’s primary duties. FEMA also assigned
field personnel in the regions to oversee disaster activities of their TSA
program, but the program tasks were either secondary or tertiary duties.                                                                      205F




According to FEMA management, the component plans to create a dedicated
TSA program office. However, as of May 2020, FEMA’s Office of Response and
                                              206F




Recovery had not yet formally approved the proposed TSA business unit
concept or assigned full-time employees to manage the TSA program. Without                                                     207F




a dedicated TSA program office to improve overall program oversight and
management, develop standard operating procedures, and work with states to                                       209F




develop housing strategies prior to disasters , FEMA risks not meeting disaster        210F




survivors’ needs in future catastrophic events.                                               12F




 
                                                                    Recommendations                        21F




Recommendation 1: We recommend FEMA’s Office of Response and Recovery
direct the Mass Care and Emergency Assistance Branch to establish a business
unit, assign responsibility, and delegate authority to ensure the effective and
efficient implementation, oversight, and management of the TSA program.                                                                              214F




                                                       
8   Standards for Internal Control in the Federal Government, GAO-14-704G, Sept. 2014.


www.oig.dhs.gov                                                                    8                                                         OIG-21-20
                   OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security


Recommendation 2: We recommend FEMA’s Office of Response and Recovery
direct the Mass Care and Emergency Assistance Branch to develop, document,
and implement standard operating procedures for the TSA Program specifically
designed and implemented to ensure:

      CLC collects and maintains detailed cost data and FEMA verifies that
       costs and taxes are reasonable, allocable, and accurate;
      FEMA does not pay for unoccupied hotel rooms and consistently requires
       disaster survivors to personally sign and date the TSA Terms and
       Conditions form during the hotel checkout process;
      FEMA and CLC transition survivors from hotels to interim or permanent
       housing within the TSA program’s 6-month timeframe; and 216F




      FEMA works with states and territories to develop initial temporary
       sheltering and interim housing strategies before disasters occur, as
       required by the Response Federal Interagency Operational Plan, so FEMA
       best meets the needs of disaster survivors going forward .     217F




              FEMA Management Comments and OIG Analysis                      218F




FEMA concurred with both recommendations. We included a copy of the
Management Comments in their entirety in Appendix B. We also received
technical comments to the draft report and revised the report as appropriate.
A summary of FEMA’s responses and our analysis follows.

FEMA Response to Recommendation 1: Concur. According to FEMA, the
Individual Assistance Division established a dedicated TSA unit under the
Mass Care, Voluntary Agency Coordination and Community Services Branch to
oversee the implementation and management of the TSA program and non-
congregate sheltering efforts in response to future events. Currently, there is
one full-time dedicated staff member with three additional detailees to provide
support. Mass Care is preparing to on-board additional staff to support this
unit.

OIG’s Analysis: We are pleased FEMA is standing up the TSA unit. This
recommendation will remain resolved and open until FEMA provides
documentation showing that the additional staff are on-board, assigned
responsibility, and delegated authority to ensure the effective and efficient
implementation, oversight, and management of the TSA program.

FEMA’s Response to Recommendation 2: Concur. According to FEMA, the
TSA unit is actively developing resources, tools, and procedures to support a
more effective TSA program.


www.oig.dhs.gov                         9                                           OIG-21-20
                  OFFICE OF INSPECTOR GENERAL
                      Department of Homeland Security


OIG’s Analysis: Recommendation 2 is resolved and open until FEMA provides
supporting documentation, including final approved copies of the Transitional
Sheltering Assistance Policy (FEMA Policy #104-009-20), the TSA Tool Kit, a
sample of the new Terms and Conditions documents, and the Quality
Assurance Surveillance Plan signed by both FEMA and the contractor.  




www.oig.dhs.gov                      10                              OIG-21-20
                         OFFICE OF INSPECTOR GENERAL
                           Department of Homeland Security


Appendix A
Objective, Scope, and Methodology                             20F




The Department of Homeland Security Office of Inspector General was
established by the Homeland Security Act of 2002 (Public Law 107−296) by                                         21F




amendment of the Inspector General Act of 1978. This audit addresses the  2F




extent to which FEMA met disaster survivors' transitional sheltering needs
after the California wildfires and Hurricanes Harvey, Irma, and Maria in 2017.                                                    23F




To accomplish our objective, we reviewed Federal guidance, relevant
documents, and applicable Federal laws. In addition, we conducted visits to
Texas, Florida, and Puerto Rico to gather documentation and visually inspect                        25F




hotels in the TSA program. We judgmentally selected locations based on the
duration of participation and expenditures in the FEMA TSA program after the
2017 disasters. We interviewed Federal and state officials, officials from
Florida, Texas, and Puerto Rico’s departments of emergency management, and                                             27F




more than 50 hotel managers from TSA-participating hotels in the locations.                                                  28




We telephonically interviewed Federal and state officials in California assigned
                                             29F




to the same roles.230F




At the national level, we interviewed officials from FEMA and the Department of              231F




Housing and Urban Development to understand the process for planning,
coordinating, and providing sheltering and interim housing services after major
disasters. Similarly, we interviewed officials from CLC, the contractor FEMA
          32F




selected to administer the TSA program, to understand their roles and
responsibilities in implementing the program. We also interviewed a 23F




representative of the National Low Income Housing Coalition to gather
information about experiences with disasters and observations regarding
transitional sheltering and interim housing in response to the 2017 hurricanes
and California wildfires.

We performed extensive analyses using TSA records FEMA provided from
August 2017 to October 2018. The data contained records for eligible
                                      235F




applicants participating in the TSA programs in California, Florida, Puerto
Rico, and Texas and billing and invoices from TSA-participating hotels that
served eligible disaster survivors from these locations. To assess the reliability    236F




of the data, we interviewed knowledgeable FEMA officials about their process                              237F




for ensuring accurate applicant information is entered into CLC’s Emergency
Lodging Assistance system, and reviewed a sample of the submissions to
                               238F




identify missing or invalid data elements. We found the data to be sufficiently
                                                        239




reliable for the purposes of our reporting objective.                          240F




www.oig.dhs.gov                                    11                                                            OIG-21-20
                         OFFICE OF INSPECTOR GENERAL
                           Department of Homeland Security


We evaluated FEMA’s actions against Federal internal control standards for
oversight and documentation. We also evaluated FEMA’s efforts to develop pre-
disaster strategies for sheltering and interim housing with Florida, Puerto Rico,
and Texas against FEMA’s responsibilities outlined in the Response Federal
Interagency Operational Plan.   42F




We conducted this performance audit between June 2018 and September 2019
pursuant to the Inspector General Act of 1978, as amended, and according to
                                                             243F




generally accepted government auditing standards. Those standards require
                                                    42F




that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based upon our
audit objectives. We believe that the evidence obtained provides a reasonable
                  245F




basis for our findings and conclusions based upon our audit objectives.




www.oig.dhs.gov                          12                            OIG-21-20
                  OFFICE OF INSPECTOR GENERAL
                    Department of Homeland Security


Appendix B
FEMA Comments to the Draft Report        247F




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Appendix C
Type of Sheltering and Interim Housing Options Provided to
Survivors during the 2017 Responses9                                                             249F




Sheltering Options                          250F




Congregate Sheltering                                     251F




Local and state territorial governments establish initial shelter operations. The                                               52F




operations are often in public buildings, including coliseums, stadiums, and
sports arenas, to provide a safe and secure environment for survivors. This
                               253F                                                                                   254F




option is a short-term solution ordinarily open for 60 days. Wrap-around                                       256F




services include childcare; feeding; medical and mental health; access and
functional needs support services; and support to children, household pets,
and service animals.                               257F




Transitional Sheltering Assistance (TSA)                                            258F




FEMA may provide TSA services to applicants who are unable to return to their
pre-disaster primary residence because the home is either uninhabitable or
inaccessible. The goal of this program is to reduce the number of disaster
survivors in congregate shelters by transitioning survivors into short-term
accommodations, typically hotels. The program is usually intended to end
after 30 days, but may be extended up to 6 months.                                                      261F




Sheltering and Temporary Essential Power                                                   62F




FEMA used Sheltering and Temporary Essential Power to assist state,
territorial, and tribal governments in performing work and services essential to
saving lives, protecting public health and safety, and protecting property to
enable survivors to shelter at home. FEMA determined that this program could263F




not be implemented as intended and discontinued use of the program in 2019.                                                           264F




Recreational Vehicles
FEMA leases recreational vehicles from vendors and provides them to disaster
survivors. Survivors may use the vehicles for up to 6 months during the
sheltering phase.                     26F




                                                       
9Catastrophic Housing Annex to the 2012 Federal Interagency Operations Plan – Hurricane (Aug.
2012).


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                                                    Department of Homeland Security



Interim Housing Options                                            267F




Direct Lease                   268F




FEMA leases property from landlords and then provides housing units to                        269F




survivors when rental resources are unavailable in specific areas.                                        270F




Manufactured Housing Units                                                      271F




Manufactured homes or other readily fabricated dwellings owned by FEMA are                                          72F




provided to eligible applicants for use as interim housing for a limited time.                                            273F




Multi-family Lease and Repair                                                          274F




FEMA repairs existing multi-family housing units, such as apartments, to use
as interim housing for eligible applicants who are unable to use rental
                                             275F




assistance.             276F




Rental Assistance                      27F




FEMA provides financial assistance to disaster survivors to rent interim
housing units. The amount of rental assistance is based on the Department of
Housing and Urban Development’s Fair Market Rents in the area where the
rental resource is located. 10                            279F2F          280




                                                       
10The Department of Housing and Urban Development calculates Fair Market Rents including
the cost of housing plus the cost of utilities to determine payment standard amounts for
several of its housing programs.


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                          Department of Homeland Security


Appendix D
Detailed Sample of Hotels Participating in the TSA Program by
City and Analysis of Hotel Tax Rates

                             New York                                              Orlando,                                           Houston,                                     Santa Rosa,
       City, State
                             City, NY *                                               FL                                                TX                                             CA


    Total # of Hotels            25281F                                                 52                                              347                                            8


    Total # of Nights          35,834                          285F                 114,006                                    286F   878,832                               287F     6,431                    28F




     Total # of Bills           152              289F                                   504         290F                               2,229            291F                           79       92F




     # of Bills Over
                                 34                                                     268                                             586                                            3
   Location Tax Rate
                                   293F                                                                                                                                                  296F




    % of Bills Over
                                22%                                                     53%                                             26%                                            4%
   Location Tax Rate
                                                        297F                                               298F                                  29F




      # of Bills At
                                 80                                                     40                                              576                                            48
   Location Tax Rate
                                   301F                                                                                                    03F                                                  304F




     % of Bills At
                                53%                                                     8%                                              26%                                           61%
   Location Tax Rate
                                                        305F                                 306F                                                307F                                                  308F




    # of Bills Under
                                 38                                                     196                                            1,067                                           28
   Location Tax Rate
                                   309F                                                             310F                                                                                         312




    % of Bills Under
                                25%                                                     39%                                             48%                                           35%
   Location Tax Rate
                                                        13F                                                314F                                  315F                                                  316F




   Location Tax Rates        14.75%**                                 317           12.50%                                            17.00%                                        14.00%**                               320F




      Highest Over
                              20.78%                                                30.01%                                            30.10%                                         30.00%
       Taxed Rate
                                                                                                                         32F                                          23F                                           324F




      Lowest Under
                                0%                                                  0.51%                                              0.03%                                         11.40%
       Taxed Rate
                                          325F                                                                    326F                                         327F                                                 328F




Source: OIG analysis of CLC-provided data                                   329F




* New York, NY data includes all five boroughs (New York, Staten Island, Queens, Brooklyn,
and the Bronx) and accounting for New York City and New York State Excise Taxes.
** Base lodging tax rate, but varying excise taxes also applicable and considered in our
calculations.



www.oig.dhs.gov                                                                    19                                                                                                  OIG-21-20
                  OFFICE OF INSPECTOR GENERAL
                                     Department of Homeland Security


Appendix E
Office of Audits Major Contributors to This Report                                    31F




Yesi Starinsky, Director             32F




Andrew Smith, Audit Manager                      3F




James Lloyd, Auditor-in-Charge                        34F




Lauren Bullis, Auditor         35F




Stephanie Holloway, Auditor                36F




Corinn King, Auditor
                   37F




Yvette Mabry, Auditor    38F




Jessica Makowski, Program Analyst
James Townsend, Program Analyst                             340F




Deborah Mouton-Miller, Communications Analyst; and                      341F




Barry Bruner, Auditor, Independent Report Referencer                           342F




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                       Department of Homeland Security


Appendix F
Report Distribution     34F




Department of Homeland Security

Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Under Secretary, Office of Strategy, Policy and Plans
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
DHS Component Liaison

Office of Management and Budget      345F




Chief, Homeland Security Branch
DHS OIG Budget Examiner 
 
 
Congress

Congressional Oversight and Appropriations Committees
 




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