oversight

Homeland Security: DHS Needs Better Project Information and Coordination among Four Overlapping Grant Programs

Published by the Government Accountability Office on 2012-02-28.

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

                United States Government Accountability Office

GAO             Report to Congressional Requesters




February 2012
                HOMELAND
                SECURITY
                DHS Needs Better
                Project Information
                and Coordination
                among Four
                Overlapping Grant
                Programs




GAO-12-303
                                               February 2012

                                               HOMELAND SECURITY
                                               DHS Needs Better Project Information and
                                               Coordination among Four Overlapping Grant
                                               Programs
Highlights of GAO-12-303, a report to
congressional requesters




Why GAO Did This Study                         What GAO Found
From fiscal years 2002 through 2011,           Multiple factors contribute to the risk of duplication among four FEMA grant
the Department of Homeland                     programs that GAO studied—the State Homeland Security Program (SHSP),
Security’s (DHS) Federal Emergency             Urban Areas Security Initiative (UASI), Port Security Grant Program, and Transit
Management Agency (FEMA)                       Security Grant Program. Specifically, these programs share similar goals, fund
distributed approximately $20.3 billion        similar projects, and provide funds in the same geographic regions. Further,
to four grant programs: the State              DHS’s ability to track grant funding, specific funding recipients, and funding
Homeland Security Program, Urban               purposes varies among the programs, giving FEMA less visibility over some
Areas Security Initiative, Port Security       grant programs. Finally, DHS’s award process for some programs bases
Grant Program, and Transit Security
                                               decisions on high-level, rather than specific, project information. Although GAO’s
Grant Program. These programs are
                                               analysis identified no cases of duplication among a sample of grant projects, the
intended to enhance the capacity of
state and local first responders to
                                               above factors collectively put FEMA at risk of funding duplicative projects. FEMA
prevent, respond to, and recover from          officials stated that there is a trade-off between enhancing management visibility
a terrorism incident. GAO was asked to         and reducing administrative burden, but also recognized that FEMA should use
evaluate the extent to which: (1)              more specific project-level information for award decisions and have taken initial
overlap and other factors among these          steps towards this goal. For example, FEMA is considering how to better use
programs could impact the risk of              existing grant information and has also begun to phase in a grants management
duplication; (2) mechanisms exist that         system that includes an explicit goal of collecting project-level information.
enhance coordination and reduce the            However, FEMA has not determined all of its specific data requirements. As
risk of duplication and how they are           FEMA determines these requirements, it will be important to collect the level of
being implemented; and (3) DHS has             information needed to compare projects across grant programs. Given the
implemented performance measures to            limitations in currently collected information, FEMA would benefit from collecting
evaluate the effectiveness of these            information with greater detail as this could help FEMA better position itself to
programs. To address these                     assess applications and ensure that it is using its resources effectively.
objectives, GAO reviewed grant
guidance and funding allocation                FEMA, as well as state and local stakeholders, have taken steps to improve
methodologies. GAO also interviewed            coordination in administering the four programs, but FEMA could take further
DHS officials, and grant administrators        action. For example, FEMA does not internally coordinate application reviews
in five urban areas—selected because           across the four programs. Specifically, the programs are managed by two
they receive funding from all four grant       separate FEMA divisions which review grant applications for each program
programs in this review—about grant            separately and there is no process in place to ensure that application information
processes and program challenges,              is shared among the programs during this process. Thus, it is difficult for FEMA
among other things.                            to identify whether grant monies are being used for the same or similar purposes.
                                               FEMA could benefit from further examining its internal grant coordination
What GAO Recommends                            process, while considering the large volume of grant applications it must process.
GAO recommends that DHS: (1)
                                               FEMA introduced some performance measures for the UASI and SHSP
collect project information with the level
of detail needed to identify any               programs in 2011 that add value, but these measures do not assess program
unnecessary duplication; (2) explore           effectiveness. FEMA has efforts under way to develop outcome measures—that
opportunities for enhanced internal            will focus on program effectiveness—for each of the four grant programs in this
coordination in grant administration;          review, but has not completed these efforts. Further, the FEMA project plan that
and (3) revise its plan to ensure the          guides these efforts does not provide information on what measures will be
timely implementation of performance           implemented for each grant program and when this will occur. A revised project
measures to assess the effectiveness           plan that includes more specific schedule information and accurate
of these grants. DHS concurred with all        implementation timelines could help guide these efforts. DHS also has several
recommendations.                               efforts under way to measure the collective effectiveness of its grant programs in
                                               achieving shared program goals, but these efforts are recent and ongoing. Thus,
View GAO-12-303. For more information,
contact David C. Maurer at (202) 512-9627 or   it is too soon to evaluate the extent to which these initiatives will provide FEMA
MaurerD@gao.gov.                               with the information it needs to determine whether these grant programs are
                                               effectively improving the nation’s security.
                                                                                       United States Government Accountability Office
Contents


Letter                                                                                     1
               Background                                                                  6
               Overlap and Other Factors Increase the Risk of Duplication among
                 Grant Programs                                                          12
               Enhanced Federal Coordination Could Help Reduce the Risk of
                 Duplication                                                             26
               Some Performance Measures Exist for Individual Grant Programs,
                 but Work Remains to Assess Grant Effectiveness                          30
               Conclusions                                                               36
               Recommendations for Executive Action                                      37
               Agency Comments and Our Evaluation                                        37

Appendix I     FEMA Grants Portfolio                                                     41



Appendix II    Comments from the Department of Homeland Security                         42



Appendix III   GAO Contact and Staff Acknowledgments                                     46



Tables
               Table 1: SHSP, UASI, PSGP, and TSGP Funding for Fiscal Years
                        2002-2011                                                          7
               Table 2: Purpose, Project Type, and Eligible Applicants of SHSP,
                        UASI, PSGP, and TSGP                                             14
               Table 3: Description of Project Information to Which FEMA Has
                        Access for Four Projects in One Jurisdiction                     23
               Table 4: Description of Project Information to Which FEMA Has
                        Access—Example #2                                                24
               Table 5: Selected DHS Grant Program Initiatives to Develop
                        Outcome-Based Performance Measures                               32
               Table 6: FEMA Initiatives to Evaluate Overall Effectiveness across
                        Grant Programs                                                   35


Figures
               Figure 1: General Grant Life Cycle                                          9



               Page i                                  GAO-12-303 Preparedness Grant Programs
Figure 2: Involved Federal Agencies and Grant Funding Paths and
         Processes of SHSP, UASI, PSGP, and TSGP                                          16




Abbreviations

BSIR              Biannual Strategy Implementation Report
CBRNE             Chemical, biological, radiological, and nuclear detection
                  equipment
DHS               Department of Homeland Security
FA                Fiduciary Agent
FEMA              Federal Emergency Management Agency
GPD               Grant Programs Directorate
HSPD-8            Homeland Security Presidential Directive-8
IJ                Investment Justification
NAPA              National Academy of Public Administration
ND Grants         Non disaster grant management system
NPAD              National Preparedness Assessment Division
NPD               National Preparedness Directorate
OIG               DHS Office of Inspector General
PPD-8             Presidential Policy Directive-8
PSGP              Port Security Grant Program
SAA               State Administrative Agency
SHSP              State Homeland Security Program
THIRA             Threat and Hazard Identification Risk Assessment
TSA               Transportation Security Administration
TSGP              Transit Security Grant Program
UASI              Urban Areas Security Initiative
UAWG              Urban Area Working Group
USCG              U.S. Coast Guard




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Page ii                                          GAO-12-303 Preparedness Grant Programs
United States Government Accountability Office
Washington, DC 20548




                                   February 28, 2012

                                   Congressional Requesters

                                   More than 10 years after the September 11, 2001, terrorist attacks, the
                                   United States remains vulnerable to attack, as evidenced by the
                                   attempted Christmas Day bombing of Flight 253 in 2009, the attempted
                                   car bombing of Times Square in New York City in 2010, and the disrupted
                                   plot to attack the subway system in Washington, D.C., in 2010, among
                                   other examples. As noted by the Department of Homeland Security
                                   (DHS), terrorist threats continue to evolve and can vary widely in their
                                   origin and scope, ranging from a lone U.S. citizen detonating a pipe-bomb
                                   to a sophisticated biological attack by an international group. In addition
                                   to the vast expansion of federal homeland security measures over the last
                                   decade, state, local, tribal, and private sector entities, as well as citizens
                                   themselves, have assumed a greater role in protecting the nation from
                                   terrorism. To assist states and localities in strengthening the security and
                                   resilience of their communities against risks associated with potential
                                   terrorist attacks, the federal government has undertaken a variety of
                                   initiatives. For example, the government has expanded financial
                                   assistance to a wide array of public and private stakeholders for terrorism
                                   preparedness activities through various grant programs administered by
                                   DHS through its component agency, the Federal Emergency
                                   Management Agency (FEMA). For certain grant programs that require a
                                   particular subject-matter expertise, FEMA also coordinates with other
                                   DHS entities, such as the U.S. Coast Guard (USCG) or the
                                   Transportation Security Administration (TSA), to administer the grant
                                   program. Through these grant programs, DHS has sought to enhance the
                                   capacity of states, localities, and other entities, such as ports or transit
                                   agencies, to prevent, respond to, and recover from a terrorism incident.

                                   From fiscal years 2002 through 2011, the federal government
                                   appropriated over $37 billion to a variety of DHS homeland security
                                   preparedness grant programs. 1 DHS distributed approximately $20.3



                                   1
                                    This total is based on Congressional Research Service data and GAO analysis, and
                                   includes firefighter assistance grants and emergency management performance grants.
                                   See Congressional Research Service, Department of Homeland Security Assistance to
                                   States and Localities: A Summary of Issues for the 111th Congress, R40246 (Washington,
                                   D.C.: Apr. 30, 2010).




                                   Page 1                                        GAO-12-303 Preparedness Grant Programs
billion of this funding to grant recipients through four programs: the State
Homeland Security Program (SHSP), the Urban Areas Security Initiative
(UASI), the Port Security Grant Program (PSGP), and the Transit Security
Grant Program (TSGP). Although these four programs are administered
separately, they fund broadly similar activities, such as planning, training,
equipment, and exercises. We previously reported on FEMA’s full suite of
17 fiscal year 2010 preparedness programs, including these four
programs, and noted that FEMA needed to improve oversight and
coordination of its grant awards to identify and address any unnecessary
overlap and duplication, among other things. 2

For the purposes of this report and our analysis of the four grant
programs, we considered “duplication” to occur when two or more
agencies or programs were engaged in the same activities or provided
the same services to the same beneficiaries. We used the term “overlap”
when multiple agencies or programs had similar goals, engaged in similar
activities or strategies to achieve them, or targeted similar beneficiaries.
The presence of overlap can suggest the need to look closer at the
potential for unnecessary duplication. However, determining whether and
to what extent project funding is actually duplicative requires project-level
information, which we collected for a sample of grant projects as
discussed below.

You requested that we evaluate these four grant programs, including the
administrative coordination and effectiveness of these programs. This
report addresses the extent to which:

1. overlap, if any, among the four selected grant programs and other
   factors impact the risk that duplication may occur within and across
   the programs;
2. federal, state, and local mechanisms exist that enhance coordination
   and reduce the risk of unnecessary duplication, and how DHS and
   other stakeholders are implementing these mechanisms; and
3. DHS has implemented performance measures to evaluate the
   effectiveness of these grant programs.

To determine the extent to which overlap, if any, among the four selected
grant programs and other factors impact the risk that duplication may


2
 GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax
Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011).




Page 2                                       GAO-12-303 Preparedness Grant Programs
occur within and across the programs, we analyzed FEMA grant guidance
and information for each program throughout the grants cycle, including
grant recipients, project types, and funding amounts. To determine the
eligible recipients, grant program purposes, and allowable projects, we
analyzed federal grant guidance. To establish the various methods that
DHS used to distribute grant funds, we analyzed the grant guidance and
applicable federal statutes. Then, to understand how these various
distribution methods affected coordination within and across the grant
programs, we interviewed FEMA’s federal partners—USCG and TSA—
both of which play important roles in program management for PSGP and
TSGP, respectively. To determine the extent to which DHS components
were involved with the project selection process, we analyzed grant
guidance, applicable federal statutes and regulations, state and urban
area homeland security strategies, and other documents that describe
local project selection processes. We also spoke with federal, state, and
local officials and collected documentation on distribution methods during
site visits to five urban areas: Houston, Texas; Jersey City/Newark, New
Jersey; New York City, New York; San Francisco, California; and Seattle,
Washington. We used specific criteria to select these urban areas,
including their levels of grant funding for all four grant programs,
recommendations from stakeholders familiar with the programs such as
FEMA program officials and association groups, and their diversity of
terrorism and disaster threats. While the information we obtained from
these urban areas and corresponding states cannot be generalized, it
provided insights into projects initiated using grant funding across the
grant programs we reviewed.

To assess the extent to which SHSP, UASI, PSGP, and TSGP funds
could have been allocated to unnecessarily duplicative projects, we
reviewed FEMA Investment Justifications (IJ), 3 Biannual Strategy
Implementation Reports (BSIR), 4 and other FEMA files, such as



3
  Investment Justifications (IJ) are one component of SHSP, UASI, PSGP, and TSGP
applications for grant funding. They provide narrative information on proposed activities
(investments) that will be accomplished with the grant funds and are described in more
detail later in this report. The IJ must demonstrate how proposed investments address
gaps and deficiencies in current capabilities, and also demonstrate adherence to program
guidance.
4
  The Biannual Strategy Implementation Report (BSIR) is a reporting requirement
submitted by states to FEMA on the progress of certain grants. These reports are
described in more detail later in this report.




Page 3                                          GAO-12-303 Preparedness Grant Programs
spreadsheets related to PSGP and TSGP awards. We also reviewed a
DHS Office of Inspector General (OIG) report on DHS preparedness
grant funding that reported on each of the programs we reviewed. We
reviewed the methodology and findings of this work and determined the
findings to be sufficiently reliable to be included in this report. We also
analyzed every project submitted by the selected five urban areas for all
four programs for fiscal years 2008 through 2010, which totaled 1,957
projects. For our project analysis, we defined overlap as any projects that
appeared to have the same purpose, the same project type, or the same
entities receiving funds. Projects were defined as unnecessarily
duplicative if they overlapped and FEMA had no evidence of coordination
between the recipients or in certain cases, between different FEMA
divisions. We did not regard projects that used different funding streams
for different aspects of a single project to be duplicative. Using this
definition, we analyzed FEMA information on grant projects and
categorized overlapping projects that had the same or similar project type
and description and were within the same jurisdiction. We used BSIR
data categories as the foundation for our analysis. Port and transit
projects are not included in the BSIR, thus information for these two grant
programs was obtained from FEMA spreadsheets and recategorized
according to the BSIR for comparison. The accuracy of the categorization
of the projects was confirmed independently by two GAO analysts. For
the purposes of our report, we concluded that FEMA’s project information
was sufficiently reliable for each of the programs we reviewed. For
projects identified as potentially duplicative, we obtained and analyzed
additional information from state officials, including coordination plans,
project ledgers, equipment inventory lists, planning and training rosters,
and expanded project descriptions, to evaluate the extent to which any
funded activities were actually duplicative. To determine if the information
maintained by FEMA allowed the agency to meet its goals, we compared
the results of our data analysis to Standards for Internal Control in the
Federal Government.

To determine the extent to which mechanisms exist to enhance
coordination and prevent unnecessary duplication within and across the
four selected grant programs, we reviewed national planning documents,
such as the National Preparedness Guidelines, 5 along with grant


5
  Among other things, the National Preparedness Guidelines are intended to organize and
synchronize national—including federal, state, local, tribal, and territorial—efforts to
strengthen national preparedness.




Page 4                                         GAO-12-303 Preparedness Grant Programs
guidance and federal statutes that establish linkages across grant
programs. In addition, we interviewed FEMA officials from the grants
divisions responsible for administering each of the programs, along with
USCG and TSA officials involved with administering PSGP and TSGP. To
assess state and local coordination of grant programs in each of the five
selected urban areas, we interviewed State Administrative Agency (SAA)
officials, 6 various members of Urban Area Working Groups (UAWG), 7
PSGP fiduciary agents (FA), local USCG officials, and transit system
officials familiar with the TSGP. We also reviewed state, urban area, port,
and regional transit homeland security strategies for the selected areas,
along with other state or local guidelines related to the administration of
the grants programs, such as membership charters for the UAWGs. We
also reviewed FEMA guidance to states and urban areas on aligning their
homeland security strategies with national preparedness objectives. We
assessed coordination efforts against best practices described in our prior
reports. 8

To determine the extent to which DHS has implemented performance
measures to evaluate the effectiveness of these four grant programs, we
analyzed DHS and FEMA documents from 2011 related to current
performance measures as well as performance measures under
development. This analysis included FEMA’s Performance Measure
Implementation Plan, a document that provides FEMA’s general
approach to performance measurement including effectiveness
measures, as well as a list of key milestones to implement new
performance measures and refine existing measures. We interviewed
grant officials from FEMA’s Grant Programs Directorate (GPD) and
FEMA’s National Preparedness Directorate (NPD) to determine what


6
 A designated State Administrative Agency (SAA) is responsible for managing the SHSP
and UASI programs at the state level. This management includes processing project
applications prior to submitting them to FEMA, “passing though” federal funds to regional
or local entities, and ensuring that local grant recipients comply with various statutory and
grant requirements.
7
  The Urban Area Working Groups (UAWG), in the UASI regions, develop the
methodology for allocating funding and make decisions, based on consensus, on all UASI
funding allocations.
8
  See GAO, Transit Security Grant Program: DHS Allocates Grants Based on Risk, but Its
Risk Methodology, Management Controls, and Grant Oversight Can Be Strengthened,
GAO-09-491 (Washington, D.C.: June 8, 2009) and Results-Oriented Government:
Practices That Can Help Enhance and Sustain Collaboration among Federal Agencies,
GAO-06-15 (Washington, D.C.: Oct. 21, 2005).




Page 5                                            GAO-12-303 Preparedness Grant Programs
                     grant performance measurement data FEMA had collected or planned to
                     collect in the future. In addition, we compared DHS and FEMA efforts to
                     evaluate the performance of selected grant programs and FEMA’s
                     Performance Measure Implementation Plan with guidance on
                     performance measurement contained in our previous reports and
                     standards contained in Project Management Institute best practices. 9

                     We conducted this performance audit from October 2010 through
                     February 2012 in accordance with generally accepted government
                     auditing standards. 10 Those standards require that we plan and perform
                     the audit to obtain sufficient, appropriate evidence to provide a
                     reasonable basis for our findings and conclusions based on our audit
                     objectives. We believe the evidence obtained provides a reasonable
                     basis for our findings and conclusions based on our audit objectives.



Background
Overview of DHS      Within DHS, FEMA manages a diverse portfolio of grant programs
Preparedness Grant   including a variety of preparedness grants. (See app. I for a diagram of
Programs             FEMA’s grants portfolio.) According to FEMA, the overarching goal of the
                     preparedness grants is to enhance the capacity of state and local
                     emergency responders to prevent, respond to, and recover from a
                     terrorism incident involving chemical, biological, radiological, nuclear, or
                     other explosive devices, or cyber attacks. Responsibility for administering
                     federal preparedness grants has shifted numerous times within DHS. 11 In
                     fiscal year 2003, DHS’s Office of Domestic Preparedness administered
                     grant programs; since then, at different times other DHS offices have
                     administered the programs, such as the Office for State and Local
                     Government Coordination and Preparedness and the Office of Grants


                     9
                      See GAO, Port Security Grant Program: Risk Model, Grant Management, and
                     Effectiveness Measures Could Be Strengthened, GAO-12-47 (Washington, D.C.: Nov. 17,
                     2011) and GAO-09-491; and Project Management Institute, The Standard for Program
                     Management, © (2006).
                     10
                       This work was done in conjunction with a separate review of the Port Security Grant
                     Program. See GAO-12-47.
                     11
                       Prior to DHS’s formation in 2003, agencies such as the Department of Justice and the
                     Department of Health and Human Services administered various preparedness-related
                     grants.




                     Page 6                                         GAO-12-303 Preparedness Grant Programs
                                       and Training. However, since its creation in April 2007, FEMA’s GPD has
                                       been responsible for the program management of DHS’s preparedness
                                       grants. 12 GPD consolidated the grant business operations, systems,
                                       training, policy, and oversight of all FEMA grants and the program
                                       management of preparedness grants into a single entity. GPD works
                                       closely with other DHS entities to manage several grants, including the
                                       USCG for the PSGP and TSA for the TSGP.

Grant Funding for                      From fiscal years 2002 through 2011, DHS distributed approximately
Preparedness Programs                  $20.3 billion through four grant programs: SHSP, UASI, PSGP, and
                                       TSGP. 13 See table 1 for a breakdown of the funding for these programs.

Table 1: SHSP, UASI, PSGP, and TSGP Funding for Fiscal Years 2002-2011

(Dollars in millions)
Fiscal year                                 SHSP                                UASI                   PSGP                           TSGP
2002                                        $316                                  N/A                     $93                            N/A
2003                                       $2,066                               $596                     $244                            N/A
2004                                       $1,675                               $671                     $179                            N/A
2005                                       $1,062                               $855                     $141                           $108
2006                                        $528                                $711                     $168                           $131
                                                                                                             a
2007                                        $509                                $747                    $311                            $251
2008                                        $863                                $782                     $389                           $356
                                                                                                             b                               c
2009                                        $861                                $799                    $539                           $498
2010                                        $842                                $833                     $288                           $253
2011                                        $527                                $663                     $235                           $200
Total                                      $9,249                             $6,657                  $2,587                          $1,797
                                       Source: GAO analysis of FEMA grant guidance.
                                       a
                                        This figure includes $201 million in funding pursuant to the fiscal year 2007 appropriation and an
                                       additional $110 million in funding pursuant to the 2007 supplemental appropriation.
                                       b
                                        This figure includes $389 million in funding pursuant to the fiscal year 2009 appropriation and an
                                       additional $150 million in funding pursuant to appropriations in the American Recovery and
                                       Reinvestment Act. Pub. L. No. 111-5, 123 Stat. 145, 164 (2009).




                                       12
                                          The Post-Katrina Emergency Management Reform Act transferred most of the
                                       Preparedness Directorate to FEMA, effective on March 31, 2007. Pub. L. No. 109-295,
                                       120 Stat. 1355, 1394 (2006).
                                       13
                                         In fiscal year 2011, FEMA distributed funds to a total of 16 preparedness grant
                                       programs including SHSP, UASI, PSGP, and TSGP.




                                       Page 7                                                 GAO-12-303 Preparedness Grant Programs
                          c
                          Includes $150 million in funding pursuant to appropriations in American Recovery and Reinvestment
                          Act. Id.


Overview of Grant Cycle   Federal grants, including SHSP, UASI, PSGP, and TSGP generally follow
                          the grant life cycle shown in figure 1 of announcement, application,
                          award, postaward, and closeout. A grant program may be established
                          through legislation––which may specify particular objectives, eligibility,
                          and other requirements—and a program may also be further defined by
                          the grantor agency. For competitive grant programs, the public is notified
                          of the grant opportunity through an announcement, and potential grantees
                          must submit applications for agency review. In the application and award
                          stages, the agency identifies successful applicants or legislatively defined
                          grant recipients and awards funding to them. The postaward stage
                          includes payment processing, agency monitoring, and grantee reporting,
                          which may include financial and performance information. The closeout
                          phase includes preparation of final reports and any required accounting
                          for property. Audits may occur multiple times during the life cycle of the
                          grant and after closeout.




                          Page 8                                              GAO-12-303 Preparedness Grant Programs
Figure 1: General Grant Life Cycle




Grant Programs Are Tied              SHSP, UASI, PSGP, and TSGP are specific grant programs nested under
to Broader National                  a larger framework of national preparedness. The broader initiatives
Preparedness Initiatives             described below, some of which are in development, are intended to help
                                     determine preparedness goals and the capabilities necessary to achieve
                                     these goals. Grants programs such as the four we reviewed can then help
                                     facilitate specific investments to close identified capability gaps. The
                                     purpose and status of the larger preparedness framework affects SHSP,



                                     Page 9                                GAO-12-303 Preparedness Grant Programs
UASI, PSGP, and TSGP in a number of ways, including the development
of grant performance metrics to assess the effectiveness of the programs.

•     In December 2003, the President issued Homeland Security
      Presidential Directive-8 (HSPD-8), which called on the Secretary of
      Homeland Security to coordinate federal preparedness activities and
      coordinate support for the preparedness of state and local first
      responders, and directed DHS to establish measurable readiness
      priorities and targets.

•     In October 2006, the Post-Katrina Emergency Management Reform
      Act was enacted, which requires FEMA to develop specific, flexible,
      and measurable guidelines to define risk-based target preparedness
      capabilities and to establish preparedness priorities that reflect an
      appropriate balance between the relative risks and resources
      associated with all hazards. 14

•     In September 2007, DHS published the National Preparedness
      Guidelines. The purposes of the guidelines are to: organize and
      synchronize national—including federal, state, local, tribal, and
      territorial—efforts to strengthen national preparedness; guide national
      investments in national preparedness; incorporate lessons learned
      from past disasters into national preparedness priorities; facilitate a
      capability-based and risk-based investment planning process; and
      establish readiness metrics to measure progress and a system for
      assessing the nation’s overall preparedness capability to respond to
      major events, especially those involving acts of terrorism. Each of the
      grant programs in our review has specific strategies that are aligned
      with the overall federal national preparedness guidelines, as the
      following examples illustrate.

      •    State and Urban Area Homeland Security Strategies (all four
           grants): These strategies are designed to (1) provide a blueprint
           for comprehensive, enterprise wide planning for homeland
           security efforts; and (2) provide a strategic plan for the use of
           related federal, state, local, and private resources within the state
           and/or urban area before, during, and after threatened or actual
           domestic terrorist attacks, major disasters, and other
           emergencies. State and urban area homeland security strategies



14
     6 U.S.C. § 746.




Page 10                                      GAO-12-303 Preparedness Grant Programs
          are required by FEMA for receiving SHSP and UASI funding.

     •    Port-Wide Risk Mitigation Plan (PSGP): The primary goal of
          these plans is to provide a port area with a mechanism for
          considering its entire port system strategically as a whole, and to
          identify and execute a series of actions designed to effectively
          mitigate risks to the system’s maritime critical infrastructure. FEMA
          requires a Port-Wide Risk Mitigation Plan for receiving PSGP
          funding for the high-risk ports, known as Groups I and II, as
          discussed in table 2. 15

     •    Regional Transit Security Strategy (TSGP): These strategies
          serve as the basis on which funding is allocated to address
          regional transit security priorities, and are the vehicles through
          which transit agencies may justify and access other funding and
          available resources. TSA requires a Regional Transit Security
          Strategy for receiving TSGP funding.

•    On March 30, 2011, the President issued Presidential Policy
     Directive-8 (PPD-8), which directs the development of a national
     preparedness goal and the identification of the core capabilities
     necessary for preparedness. PPD-8 replaces HSPD-8. 16 FEMA
     officials noted that the National Preparedness System affirms the all-
     hazards risk-based approach to national preparedness. 17 FEMA
     officials further noted that PPD-8 looks to build on the efforts already
     in place, including those that supported the Post-Katrina Emergency
     Management Reform Act and the 2009 National Infrastructure



15
  Based on risk, each port area is placed into one of three funding groups—Group I,
Group II, or Group III. Groups I and II port areas are the highest risk port areas that
receive the bulk of the PSGP grant funding.
16
   PPD-8 states, “This directive replaces Homeland Security Presidential Directive
(HSPD)-8 (National Preparedness), issued December 17, 2003, and HSPD-8 Annex I
(National Planning), issued December 4, 2007, which are hereby rescinded, except for
paragraph 44 of HSPD-8 Annex I. Individual plans developed under HSPD-8 and Annex I
remain in effect until rescinded or otherwise replaced.”
17
  The national preparedness system is designed to help guide the domestic efforts of all
levels of government, the private and nonprofit sectors, and the public to build and sustain
national capabilities. The national preparedness system is to include guidance for
planning, organization, equipment, training, and exercises to build and maintain domestic
capabilities. It is intended to provide an all-of-nation approach for building and sustaining a
cycle of preparedness activities over time.




Page 11                                            GAO-12-303 Preparedness Grant Programs
                                   Protection Plan. 18 PPD-8 has specific deadlines for deliverables: 180
                                   days for the National Preparedness Goal, 240 days for a description
                                   of the National Preparedness System, and 1 year for a National
                                   Preparedness Report. 19


Overlap and Other
Factors Increase the
Risk of Duplication
among Grant
Programs
Grant Programs Have           The four grant programs in our review—SHSP, UASI, PSGP, and
Similar Goals, Fund           TSGP—have overlapping goals, project types, and funding jurisdictions,
Similar Projects, and Exist   which increases the risk of duplication among the programs. Although the
                              specifics of the four programs vary, they share the overarching goal of
in the Same Urban Areas,      enhancing the capacity of state and local emergency responders to
Which Increases the Risk      prevent, respond to, and recover from a terrorism incident involving
of Duplication                chemical, biological, radiological, nuclear, or other explosive devices, or


                              18
                                 In accordance with the Homeland Security Act and in response to HSPD-7, DHS
                              issued, in June 2006, the first National Infrastructure Protection Plan, which provides the
                              overarching approach for integrating the nation’s critical infrastructure and key resource
                              protection initiatives into a single effort. DHS issued a revised Plan in January 2009. The
                              Plan sets forth a risk management framework and details the roles and responsibilities of
                              DHS, sector-specific agencies, and other federal, state, regional, local, tribal, territorial,
                              and private sector partners, including how they should use risk management principles to
                              prioritize protection activities within and across sectors.
                              19
                                 In September 2011, DHS issued the National Preparedness Goal as directed by PPD-8.
                              According to DHS, the goal is “A secure and resilient Nation with the capabilities required
                              across the whole community to prevent, protect against, mitigate, respond to, and recover
                              from the threats and hazards that pose the greatest risk.” Thirty-two “core capabilities,”
                              such as “planning” and “threats and hazard identification,” are listed and defined under
                              each of the five broader mission areas named in the goal (“prevent,” “protect against,”
                              etc.). These capabilities will be the foundation for measuring overall national preparedness
                              and allocating resources to fill preparedness gaps. Additionally, in November 2011, DHS
                              released its description of the National Preparedness System that summarizes the
                              components of the National Preparedness System, which include: identifying and
                              assessing risk, estimating the level of capabilities needed to address those risks, building
                              or sustaining the required levels of capability, developing and implementing plans to
                              deliver those capabilities, validating and monitoring progress, and reviewing and updating
                              efforts to promote continuous improvement.




                              Page 12                                            GAO-12-303 Preparedness Grant Programs
cyber attacks. More specifically, each program funds similar projects such
as training, planning, equipment, and exercises. For example, the four
programs have overlapping lists of allowable costs, so certain types of
equipment, such as communication radios, may be purchased through
each grant program. Further, although the programs target different
constituencies, such as states and counties, urban areas, and port or
transit stakeholders, there is overlap across recipients. For example, each
state and eligible territory receives a legislatively mandated minimum
amount of SHSP funding to help ensure that all areas develop a basic
level of preparedness, while UASI explicitly targets urban areas most at
risk of terrorist attack. 20 However, many jurisdictions within designated
UASI areas also apply for and receive SHSP funding. Similarly, a port
stakeholder in an urban area could receive funding for patrol boats
through both PSGP and UASI funding streams, and a transit agency
could purchase surveillance equipment with TSGP or UASI dollars. More
broadly, any designated high-risk urban area located near major
waterways can receive funding through SHSP, UASI, PSGP, and TSGP
sources.

In March 2011, we reported that overlap among government programs or
activities can be harbingers of unnecessary duplication. Further, we
commented on FEMA’s full suite of 17 fiscal year 2010 preparedness
programs, including the four programs in this review, and noted that
FEMA needed to improve oversight and coordination of its grant
awards. 21 Identifying and mitigating the risk of duplication could help
ensure that these four grant programs, which distributed over $20 billion
dollars in funding to grant recipients from fiscal years 2002 through 2011,
are allocating resources effectively. Table 2 below describes the basic
purposes, the types of projects funded, and the eligible applicants of the
SHSP, UASI, PSGP, and TSGP programs.




20
     6 U.S.C. § 605(e); 6 U.S.C. § 604.
21
     GAO-11-318SP.




Page 13                                   GAO-12-303 Preparedness Grant Programs
Table 2: Purpose, Project Type, and Eligible Applicants of SHSP, UASI, PSGP, and TSGP

                 State Homeland Security       Urban Areas Security           Port Security Grant                Transit Security Grant
                 Grant Program (SHSP)          Initiative (UASI)              Program (PSGP)                     Program (TSGP)
Purpose of the  SHSP provides funding to       UASI provides federal          PSGP provides federal              TSGP provides funds to
grant program   support states’                assistance to address the      assistance to strengthen           owners and operators of
                implementation of              unique needs of high-          the security of the nation’s       transit systems (which include
                homeland security              threat, high-density urban     ports against risks                intracity bus, commuter bus,
                strategies to address the      areas, and assists them        associated with potential          ferries, and all forms of
                identified planning,           in building an enhanced        terrorist attacks by               passenger rail) to protect
                organization, equipment,       and sustainable capacity       supporting increased port          critical surface transportation
                training, and exercise         to prevent, protect,           wide risk management,              infrastructure and the traveling
                needs at the state and local   respond to, and recover        enhanced domain                    public from acts of terrorism
                levels to prevent, protect     from acts of terrorism.        awareness, training and            and to increase the resilience
                against, respond to, and                                      exercises, and expanded            of transit infrastructure.
                recover from acts of                                          port recovery capabilities.
                terrorism and other
                catastrophic events.
Types of        •    Planning                  •    Planning                  •    Port resiliency and           •     Capital infrastructure
projects funded •    Organization              •    Organization                   recovery efforts                    projects
                •    Equipment                 •    Equipment                 •    Maritime domain               •     Operational activities
                                                                                   awareness efforts             •     Planning
                •    Training                  •    Training
                                                                              •    Planning                      •     Equipment
                •    Exercises                 •    Exercises
                                                                              •    Equipment                     •     Training
                                                                              •    Training                      •     Exercises
                                                                              •    Exercises
Eligible         SAA/ 50 states, DC, and       SAA/ 31 Designated             Port Areas: Groups I and II Selected transit agencies and
applicants       territories.                  Urban Areas (2 Tiers           (highest risk); Group III and ferry systems within high risk
                                                              a
                 •     SAA may allocate        based on risk).                “All Other Port Areas”        urban areas.
                                                                                           b
                       SHSP funds to           •   Urban Areas may            (lower risk).
                       Designated Urban            allocate UASI funds
                       Areas                       to port and transit
                                                   stakeholders
                                           Source: FEMA grant guidance.
                                           a
                                            In fiscal year 2011, Tier I UASI areas included the 11 highest risk urban areas and were allocated
                                           about 82 percent of the total UASI funding available; Tier II included the other 20 candidate areas and
                                           were allocated the remaining 18 percent funding. Tier I and II Urban Area are determined using a
                                           DHS risk model that incorporates threat, vulnerability, and consequence.
                                           b
                                            A DHS risk model determines the port areas at high risk of a terrorist attack and DHS places them in
                                           either Group I (highest risk group), Group II (next highest risk group) or Group III. In fiscal year 2011,
                                           there were 7 port areas in Group I and 48 port areas in Group II. Port areas in Group I are considered
                                           to be the highest risk port areas in the nation. Ports not identified in Group I, II, or III are eligible to
                                           apply for funding as part of the All Other Port Areas Group. For additional information on the PSGP
                                           and port area groups, see GAO-12-47.




                                           Page 14                                                   GAO-12-303 Preparedness Grant Programs
Differences in Administrative     FEMA’s ability to track which projects receive funding among the four
Processes among the Four          grant programs is varied because the project-level information FEMA has
Grant Programs Result in          available to make award decisions—including grant funding amounts,
Varied Levels of Information on   grant recipients, and grant funding purposes—also varies by program.
Which Award Decisions Are         This is due to differences in the grant programs’ administrative processes.
Based                             For example, in some cases, FEMA relies on stakeholders to review and
                                  recommend projects for grant funding—adding layers to the review
                                  process. Delegating administrative duties to stakeholders reduces
                                  FEMA’s administrative burden, but also contributes to FEMA having less
                                  visibility over some grant applications, specifically those funded via SHSP
                                  and UASI. A combination of federal statutes and DHS policy determine
                                  specific grant allocation mechanisms and the federal partners involved in
                                  grants administration. Figure 2 below describes the federal agencies
                                  involved, the path of the grant funds to the final recipient, and the
                                  application and award process for each grant, as of fiscal year 2011.




                                  Page 15                                 GAO-12-303 Preparedness Grant Programs
Figure 2: Involved Federal Agencies and Grant Funding Paths and Processes of SHSP, UASI, PSGP, and TSGP




                                       a
                                        The Urban Area Working Groups develop the methodology for allocating funding and make
                                       decisions, based on consensus, on all UASI funding allocations.

                                       b
                                        For Group I and Group II port areas—the highest risk port areas—money is passed from FEMA to
                                       the final grant recipient through the designated fiduciary agent as described in the table. However, for
                                       Group III and the All Other Port Areas Group, funding is passed directly from FEMA to the final grant
                                       recipient.




                                       Page 16                                                 GAO-12-303 Preparedness Grant Programs
As depicted in figure 2, grant funding follows a different path to final
recipients depending on the program’s administrative process. For
example, grant awards made under SHSP and UASI go through three
steps before the money reaches the final grant recipient. First, DHS
awards SHSP and UASI funds through FEMA to a designated SAA—
typically a state homeland security or emergency management office. The
SAA then passes funds to subrecipients, such as county or city
governments or designated urban areas. These subrecipients/local
governments may then further distribute SHSP and UASI funds to other
entities, including individual law enforcement agencies. It is these other
entities that will ultimately spend the grant funds to implement security
projects. Because state governments are required by the Implementing
Recommendations of the 9/11 Commission Act of 2007 (9/11
Commission Act) to have a role in the application process and distribution
of SHSP and UASI funding, 22 and because of the thousands of individual
projects that comprise these programs, FEMA relies on the SAAs to
administer the awards to smaller entities.

In delegating significant grants administration duties to the SAA for the
larger SHSP and UASI programs, FEMA officials recognized the trade-off
between decreased visibility over grant funding, subrecipients, and
specific project-level data in exchange for their reduced administrative
burden. For these two programs, the SAA, as the official grant recipient,
assumes responsibility for holding subrecipient entities accountable for
their use of funding, including ensuring that recipients use grant funds to
pay costs that are allowable (e.g., reasonable and necessary for proper
performance of the award). 23 However, according to FEMA officials,
states’ capacities to effectively administer and coordinate their grants vary
considerably.




22
     6 U.S.C. §§ 604, 605.
23
   Among other requirements, grant funds may only be used for allowable costs.
Allowable costs are those that, among other things, are reasonable and necessary for
proper and efficient performance and administration of federal awards, and a cost is
reasonable if, in its nature and amount, it does not exceed that which would be incurred by
a prudent person under the circumstances prevailing at the time the decision was made to
incur the cost. See 2 C.F.R. pt. 225. In this report, potential “overlap” and “duplication”
generally refer to two or more SHSP, UASI, PSGP, or TSGP projects that address the
same preparedness need and could be redundant or unnecessary if not coordinated.




Page 17                                         GAO-12-303 Preparedness Grant Programs
                                  In contrast, FEMA receives far fewer applications for TSGP and PSGP
                                  funds and awards grant funding more directly to the final grant recipients,
                                  with one and two steps, respectively, rather than three steps. As a result,
                                  FEMA has a greater ability to track grant funding, specific funding
                                  recipients, and funding purposes for these two smaller grant programs.
                                  Beginning in fiscal year 2009, appropriations acts required FEMA to
                                  award TSGP funds directly to transit authorities instead of through
                                  SAAs. 24 Per FEMA policy, the agency distributes PSGP funds to local
                                  FAs who then distribute grants to local entities within the port area, but
                                  FEMA is directly involved in this process. Due to the legal and
                                  departmental policies that establish a more direct award process for
                                  PSGP and TSGP, along with the smaller scope of those programs, FEMA
                                  has more information and is better able to track these grants through to
                                  the end user of the grant monies.

Differences in Administrative     Differences in administrative processes among each of the four grant
Processes Also Affect the Level   programs also impact the extent to which federal, state and local entities
of Federal Involvement in         share responsibility for prioritizing and selecting the individual
Award Decisions                   preparedness projects that will ultimately receive funding. Due to its
                                  greater involvement with the PSGP and TSGP project selection at the
                                  local level, DHS generally has more information on specific PSGP and
                                  TSGP projects than SHSP and UASI projects. For example, DHS
                                  components—USCG and TSA—are involved with the PSGP and TSGP
                                  selection process, which provides DHS with additional information over
                                  the use of grant funds. For instance, TSGP projects from fiscal years
                                  2007 through 2010 were selected by regional working groups. 25 The
                                  regional groups based their project selection on Regional Transit Security
                                  Strategies that each transit region had developed. For this grant program
                                  TSA had better information about the funding as well as influence over
                                  the project selection because TSA set the parameters for and approved
                                  the transit security strategies, and final project selection was based on
                                  TSA approval.




                                  24
                                       Pub. L. No. 110-329, 122 Stat. 3574, 3671 (2008).
                                  25
                                    The regional working groups choose projects for the highest risk Tier 1 regions. The
                                  remaining transit regions’—Tier 2 regions—projects are fully competitive.




                                  Page 18                                                  GAO-12-303 Preparedness Grant Programs
Similarly, the USCG, and in particular the Captain of the Port, 26 exerts
influence over the PSGP project selection process, given the agency’s
maritime security expertise and role in the PSGP award process. PSGP
project applications also undergo a second national review facilitated by
FEMA that includes the USCG, the Department of Transportation’s
Maritime Administration, 27 and other stakeholders. Along with federal
stakeholders, numerous local stakeholders are involved with the PSGP
selection process and in many locations are required to base their grant
award decisions largely on FEMA-required port security mitigation
strategies. These strategies also require FEMA approval before PSGP
grants can be awarded to port areas. 28 Thus, for these projects, FEMA is
more involved and has greater information on which to base award
decisions.

In contrast, local officials select SHSP and UASI projects with less federal
involvement, although the projects must comport with various program
rules, such as those related to allowable activities or costs, and address
any funding priorities stipulated in the grant guidance. For SHSP, FEMA
awards funds to states for certain broad purposes, such as interoperable
communications, but federal law and DHS policies allow states to
distribute these funds to individual projects or jurisdictions using different
mechanisms, given different local conditions and needs. One state may
choose to use a consensus-based approach to disburse the funds to
counties, for example, while another may distribute funding equally to all
of its jurisdictions. For example, in Washington State, SHSP grant
applications are reviewed by four distinct entities––the state’s homeland
security committee, the all-hazards statewide emergency council, the
state’s domestic security executive group, and the governor’s office––


26
   The Captain of the Port (COTP) is a Coast Guard officer responsible for enforcing port
safety, security and marine environmental regulations within a given port area. The COTP
also leads the local field-level review of PSGP projects, although the COTP’s actual level
of involvement in the selection process may vary from port to port depending on local
conditions.
27
  Programs of the Maritime Administration promote the development and maintenance of
an adequate, well-balanced United States merchant marine capable of service as a naval
and military auxiliary in time of war or national emergency. The Maritime Administration
also seeks to ensure that the United States maintains adequate shipbuilding and repair
services, efficient ports, effective intermodal water and land transportation systems, and
reserve shipping capacity for use in time of national emergency.
28
  For more detailed information on PSGP program requirements and processes see
GAO-12-47.




Page 19                                         GAO-12-303 Preparedness Grant Programs
                           prior to the state making risk-informed allocation decisions. In contrast,
                           one regional government council in Texas allocated SHSP funds equally
                           to all eligible jurisdictions within its region regardless of their risk level.

                           For UASI grants, FEMA requires each region to create its own UAWG,
                           but does not participate in these groups. 29 The UAWGs convene to select
                           individual projects for UASI funding based on the FEMA-identified grant
                           priorities for that grant year that are also consistent with the area’s grant
                           application and state and urban area strategic plans. For example, in
                           2009 the New York City UAWG identified protecting critical infrastructure
                           and key resources as one of eight goals in its homeland security strategic
                           plan, received UASI funding for this purpose, and selected and allocated
                           funds to specific projects in the urban area related to this goal. FEMA
                           approves all applications and strategic plans, which give the agency a
                           broad idea of what grant applicants intend to accomplish at the state and
                           local level. However, selection of specific projects occurs through local-
                           level working groups. As a result of the differing levels of DHS
                           involvement in project selection for each of the grants programs, DHS
                           generally has more project information for specific PSGP and TSGP
                           projects than SHSP and UASI projects.


FEMA Makes Award           When making preparedness grant awards, FEMA decisions are based on
Decisions Using Varying    less specific project-level information for SHSP and UASI programs than
Levels of Information      for PSGP and TSGP, which puts the agency at greater risk of funding
                           unnecessarily duplicative projects across all programs. In our prior work
Which Contributes to the   on overlap and duplication, we identified challenges agencies face in
Risk of Funding            collecting and analyzing the information needed to determine whether
Duplicative Projects       unnecessary duplication is occurring. For example, we identified 44
                           federal employment and training programs that overlap with at least 1
                           other program in that they provide at least one similar service to a similar
                           population. However, our review of 3 of the largest 44 programs showed


                           29
                              FEMA directs each UASI region to create its own regional working group, which
                           FEMA’s grant guidance refers to as an urban area working group. Grant guidance
                           requires the working group to determine representation from the jurisdictions and
                           response disciplines that comprise the UASI region. Beginning in fiscal year 2008, UASI
                           grant guidance recommended to urban areas that they consider for UASI working group
                           membership those counties within which the cities included in the UASI region reside,
                           contiguous jurisdictions, and jurisdictions within the region’s Metropolitan Statistical Area
                           (MSA). An MSA is a geographic entity defined by the Office of Management and Budget
                           that contains an urban core population of 50,000 or more.




                           Page 20                                            GAO-12-303 Preparedness Grant Programs
that the extent to which individuals actually receive the same services
from these programs is unknown due to program data limitations. 30 We
found similar data limitations in this review as FEMA bases its awards for
SHSP, UASI, PSGP, and TSGP in part upon IJs which contain limited
information. For the SHSP and UASI programs, states and eligible urban
areas submit IJs for each program with up to 15 distinct investment
descriptions that contain general proposals to address capability gaps in
wide-ranging areas such as interoperability communications or critical
infrastructure protection. Each IJ may encompass multiple specific
projects to different jurisdictions or entities, but project-level information,
such as a detailed list of subrecipients or equipment costs, is not required
by FEMA. According to FEMA, data system limitations, the high volume of
individual SHSP and UASI projects, and the desire to give states and
urban areas increased flexibility to add or modify specific projects after
the award period contributed to less detailed IJs. 31

In contrast, FEMA makes PSGP and TSGP award decisions based on
federal reviews of IJs that contain information about specific projects,
providing FEMA officials with more detailed knowledge of what is being
requested and what is being funded by these programs. Furthermore,
before awards are made, FEMA directs PSGP and TSGP applicants to
submit detailed budget summaries, but does not call for such information
from SHSP and UASI applicants. The 9/11 Commission Act establishes
minimum application requirements for SHSP and UASI, such as a
description of how funds will be allocated, but the act does not call for
specific project data. 32 For example, with SHSP, the statute requires
states to include in their grant applications the purpose for the grant
funds, a description of how they plan to allocate funds to local
governments and Indian tribes, and a budget showing how they intend to
expend the funds. FEMA officials stated that the SHSP and UASI IJ



30
     GAO-11-318SP.
31
  Regarding FEMA’s data limitations, FEMA is currently using a grants management
system “on-loan” from the Department of Justice. This involves a number of disparate
systems and spreadsheets. FEMA is in the process of transitioning to a new system called
ND (non disaster) Grants. ND Grants is slated to be a one-stop shop for programmatic
and financial information on DHS grants, as well as monitoring and payment. ND Grants
was introduced in 2011 but is still several years away from having full functionality,
according to FEMA.
32
     6 U.S.C. §§ 604, 605.




Page 21                                        GAO-12-303 Preparedness Grant Programs
                           format meet these statutory requirements, albeit at “a high summary
                           level.”


FEMA Is Considering        To improve the level of information that FEMA has available for making
Additional Action and      grant award decisions, FEMA is considering collecting more detailed
Taking Steps to Enhance    information on proposed grant projects. In May 2011, a FEMA report
                           based on the work of a Reporting Requirements Working Group
Grant Information, but     recommended collecting additional project information at the application
Further Efforts Are        stage. 33 Specifically, the FEMA report recommended that the agency
Needed to Avoid the Risk   modify the IJ format for SHSP and UASI applications to include a detailed
of Duplication             project list. This project list would contain information that is currently
                           collected through the BSIR later in the grant cycle after FEMA makes
                           grant awards. 34 If this recommendation is implemented, the policy of
                           collecting additional information at the application stage could be initiated
                           in the fiscal year 2013 grant cycle, according to FEMA. Although
                           collecting this additional information may be useful to FEMA, we
                           determined that the level of information contained in the BSIR alone
                           would not provide sufficient project information to identify and prevent
                           potentially unnecessary duplication within or across grant programs.

                           To make this determination, we reviewed the type of information that
                           FEMA would have available at the application stage if it implemented the
                           report recommendation. Specifically, we reviewed IJ and BSIR
                           information for the 1,957 grant projects awarded through the four grant
                           programs to five urban areas––Houston, Jersey City/Newark, New York
                           City, San Francisco, and Seattle––for fiscal years 2008 through 2010.
                           Our analysis determined that 140 of the projects, or 9.2 percent of the
                           overall funding associated with these projects––about $183 million––
                           lacked sufficient detail to determine whether these projects were
                           unnecessarily duplicative or had involved coordination during the state’s


                           33
                              FEMA, Redundancy Elimination and Enhanced Performance for Preparedness Grants
                           Act: Initial Report to Congress (Washington, D.C.: May 23, 2011). In August 2009, FEMA
                           established the Reporting Requirements Working Group to compile a list of select grant
                           reporting activities, collect grant stakeholder feedback, and make recommendations on
                           future data collection policies. The May 2011 Initial Report to Congress is based on the
                           Working Group’s research and outlines recommendations and implementation actions
                           related to grant application criteria and data integration, among other things.
                           34
                              BSIRs are submitted electronically by SAAs to FEMA for the life of the award to account
                           for the use of grant funding. All funds provided to the SAA must be accounted for and
                           linked to one or more projects in the BSIR.




                           Page 22                                         GAO-12-303 Preparedness Grant Programs
                                         planning or selection processes to prevent any unnecessary duplication.
                                         Table 3 further illustrates the challenge that FEMA would face in
                                         identifying potential duplication using the BSIR data for SHSP and UASI
                                         as recommended by the report. 35 For example, table 3 contains SHSP,
                                         UASI, and PSGP project information from a single jurisdiction in one of
                                         the five urban areas we reviewed and shows the level of detail that FEMA
                                         would have available to compare projects. The overlap in the descriptions
                                         of the project types and titles suggest that duplication could be occurring
                                         among three of the four grant programs, and warranted further analysis.

Table 3: Description of Project Information to Which FEMA Has Access for Four Projects in One Jurisdiction

Grant   Year   Project type              Project title                        Recipient               Description
UASI    2009   Critical Infrastructure   Public Safety Video                  Urban Area Working      Beginning with the 2006 UASI
                                                                                                                            a
               Protection                Initiative - assess                  Group                   Grant period, the City began the
                                         vulnerability of and/or                                      development of a public safety
                                         harden/protect critical                                      video system to improve situational
                                         infrastructure and key                                       awareness of public venues, critical
                                         assets                                                       assets, transportation and
                                                                                                      commerce corridors, and public
                                                                                                      safety areas of interest.
SHSP    2009   Critical Infrastructure   Assess vulnerability of              City/County             This will support the expansion of
               Protection                and/or harden/protect                Governmental            the Public Safety Video Program
                                         critical infrastructure and          Organization            that is currently under development.
                                         key assets
SHSP    2009   Critical Infrastructure   Assess vulnerability of              City/County             This project will assist the County
               Protection                and/or harden/protect                Governmental            Sheriff’s Office in achieving the goal
                                         critical infrastructure and          Organization            of reducing vulnerability of a Critical
                                         key assets                                                   Infrastructure/Key Resource
                                                                                                      adjacent to a specific critical
                                                                                                      waterway.
PSGP    2009   Maritime Domain         CCTV Surveillance                      Port Authority          Many of the CCTV surveillance
               Awareness/Improvised    Cameras Replacement                                            cameras that have been installed at
                                              c
               Explosive Device        Program                                                        the Port Authority’s facilities are at
               Prevention, Protection,                                                                or near the end of their useful life.
               Response, and Recovery                                                                 This program will initiate the
                           b
               Capabilities                                                                           systematic replacement of these
                                                                                                      CCTV cameras.
                                         Source: FEMA BSIR for UASI and SHSP; FEMA IJ for PSGP.




                                         35
                                            Port and transit projects are not included in the BSIR, thus information was obtained
                                         from spreadsheets which contain IJ data. According to a FEMA section chief, the BSIR
                                         system was designed for state-level reporting as opposed to reporting from the variety of
                                         different subrecipients that receive PSGP and TSGP funds more directly. TSGP projects
                                         were listed in the BSIR prior to fiscal year 2009 when they were administered by state
                                         SAAs.




                                         Page 23                                                  GAO-12-303 Preparedness Grant Programs
                                         a
                                             Identifying information was removed.
                                         b
                                             PSGP project types are not directly comparable to BSIR project type categories.
                                         c
                                             “CCTV” refers to Closed Circuit Television.


                                         After identifying the projects that appeared to be potentially duplicative,
                                         we contacted the SAA and FA for this state, and officials provided us with
                                         extended narratives, coordination details, and subrecipient lists. It was not
                                         until we reviewed this additional, more detailed information that we could
                                         ascertain that these four projects were not duplicative, but rather were
                                         part of a larger, coordinated public safety interoperability and video
                                         initiative taking place in the region.

                                         Table 4 below contains a second example of project data associated with
                                         BSIR and IJ information from a single jurisdiction in one of the five urban
                                         areas we reviewed. Again, we identified the potential for duplication
                                         because of the similarities in funded projects for both the SHSP and
                                         TSGP. Both of the projects identified below are related to the purchase of
                                         chemical, biological, radiological, and nuclear detection equipment
                                         (CBRNE). However, upon examining additional state-provided information
                                         and the TSGP IJ, we had sufficient information to determine that these
                                         projects were distinct and involved separate equipment. However, as with
                                         the previous example in table 3, FEMA would not be able to make these
                                         determinations using only BSIR data.

Table 4: Description of Project Information to Which FEMA Has Access—Example #2

Grant   Year   Project type              Project title                          Recipient             Description
SHSP    2009   Enhance capabilities to   Project A – CBRNE Support              City/County           Purchase of equipment to support
               respond to all-hazards                                           Governmental          response capabilities for CBRNE
               events                                                           Organization          events.
                         a
TSGP    2009   Equipment                 Install CBRNE in Subway                Transit Agency        Install CBRNE in subway.
                                         Source: FEMA BSIR for SHSP; FEMA IJ for TSGP.
                                         a
                                             TSGP project types are not directly comparable to BSIR project type categories.


                                         Based on our analysis using BSIR and IJ project data, we were able to
                                         ascertain that over 90 percent of the projects we reviewed had sufficient
                                         detail to determine that the projects (1) were substantively different and
                                         not likely duplicative, or (2) involved coordination to prevent any
                                         unnecessary duplication. Furthermore, our subsequent analysis using
                                         additional information from state and local grant recipients indicated that
                                         none of these projects were duplicative. Nonetheless, we believe that
                                         more detailed project information could be of value to FEMA in its grant
                                         review process since, as demonstrated above, the information currently



                                         Page 24                                                  GAO-12-303 Preparedness Grant Programs
being considered does not always allow for the necessary differentiation
between projects funded by the four grant programs. Moreover, FEMA––
through its own internal analysis––and the OIG have both separately
concluded in recent years that FEMA should use more specific project-
level data in making grant award decisions, especially for SHSP and
UASI, in order to identify and mitigate potential duplication. Specifically, in
a March 2010 report, the OIG noted that the level of detail in IJs and in
other grant program applications was not sufficient for FEMA to identify
duplication and redundancy. 36 In its written comments to the OIG, the
DHS Office of Infrastructure Protection concurred with this assessment,
noting that a SHSP IJ “was little more than a checklist of previous funding
with a brief strategy narrative.” Further, Standards for Internal Control in
the Federal Government state that program managers need operational
and financial data to determine whether they are meeting their goals for
accountability for effective and efficient use of resources.

FEMA has acknowledged the agency’s difficulties in effectively using
grants data and is taking steps to improve its data collection and
utilization through resolving staffing shortages by filling key grants
management personnel vacancies, and taking steps to implement a new
data management system. As part of this effort, FEMA introduced a new
non disaster grant management system (ND Grants) for the fiscal year
2011 grant cycle, and the system is scheduled for completion by fiscal
year 2014. Agency officials stated that this system, once completed, will
help FEMA to manage all of its preparedness grants, and has an explicit
goal of enhancing project-level data collection. In addition, the ND Grants
system is anticipated to consolidate data from multiple systems and
facilitate greater utilization and sharing of information. 37 However,
according to FEMA documentation, FEMA has not yet determined all of
its specific data needs for ND Grants. As FEMA continues to develop the
ND Grants system it will be important that it collects the level of data
needed to compare projects across grant programs to limit the risk of
funding duplicative projects.




36
     DHS, Efficacy of DHS Grant Programs, OIG-10-69 (Washington, D.C.: Mar. 22, 2010).
37
   This system will replace the 13 legacy grant data systems and other processes that
FEMA inherited from agencies that previously administered homeland security
preparedness grants, such as the Department of Justice.




Page 25                                         GAO-12-303 Preparedness Grant Programs
                       We believe that the recommendation of the FEMA report to better use
                       more specific project-level data through the BSIR, 38 for the SHSP and
                       UASI programs, is a step in the right direction, although our analysis
                       demonstrated BSIR data alone do not include enough detail needed to
                       identify potential duplication. The Director of GPD’s Preparedness Grants
                       Division reported in September 2011 that the report recommendations
                       were still under consideration and thus FEMA had not yet determined the
                       specifics of future data requirements. Thus, the agency’s goal to improve
                       data collection by collecting project-level information through its ND
                       Grants system is a worthwhile action. This effort could provide the level of
                       detail that FEMA needs to identify possible unnecessary duplication
                       within and across all four grant programs. We recognize that collecting
                       more detailed project information through ND Grants could involve
                       additional costs. However, collecting information with this level of detail
                       could help FEMA better position itself to assess applications and ensure
                       that it is using its resources effectively.


                       FEMA, as well as state and local stakeholders, have taken steps to
Enhanced Federal       improve coordination in selecting and administering the four grant
Coordination Could     programs, but additional FEMA action could help reduce the risk of
                       duplication among these programs. Federal efforts to improve
Help Reduce the Risk   coordination range from improving visibility across grants to gathering
of Duplication         additional information about grant spending. The Director of GPD’s
                       Preparedness Grants Division discussed multiple projects that FEMA had
                       initiated to potentially improve coordination in the grants management
                       area. He told us that at the federal level, there is an effort within FEMA to
                       increase planning and training exercises in order to increase its ability to
                       track what projects are being funding by which grants. He added that this
                       FEMA-led initiative is currently assessing public information on grants to
                       reduce the risk of duplication. FEMA has a variety of reporting tools and
                       guidelines that FEMA personnel have recently been working with to
                       improve coordination and linkages between programs. For example,
                       FEMA has started using Threat and Hazard Identification Risk
                       Assessments (THIRA) as a way to increase FEMA’s ability to link



                       38
                          As noted above, FEMA would collect more specific BSIR data at the application stage
                       of the grants cycle instead of higher level “investment” descriptions. This more specific
                       project-level data could include more detailed data elements related to funding; target
                       capabilities addressed; and proposed solution categories, such as planning, organization,
                       training, exercises, equipment, and management and administration.




                       Page 26                                         GAO-12-303 Preparedness Grant Programs
spending at the local and federal levels. 39 The Director of GPD’s
Preparedness Grants Division said that the guidance for reporting this
linkage to the local level is still being discussed, with NPD taking the lead,
as it currently is only required at the state level.

Officials in four of the five states we visited had taken steps to improve
coordination across grant programs. State steps to improve coordination
range from tracking equipment purchases to enhancing administrative
tools. For example, in Texas, jurisdictions must register all deployable
equipment purchased through a homeland security grant and costing
more than $5,000 on a statewide registry known as the Texas Regional
Response Network. The purpose of the network is to raise awareness
about the assets that neighboring jurisdictions might have available for
use by another jurisdiction during an emergency. According to a Texas
official familiar with the initiative, the registry was established with the
recognition that sharing deployable equipment would be cost effective
since it would be difficult for every jurisdiction to maintain every piece of
equipment that might be needed in an emergency. In New Jersey, the
SAA’s office developed a Grants Tracking System, a web-enabled
application to capture and track each subgrantee’s state-approved
Homeland Security Grant Program–funded projects which includes SHSP
and UASI. The Grant Tracking System is the state’s primary oversight
mechanism to monitor the progress of each county, city, and state agency
toward completing or procuring their budgeted projects or equipment. The
system permits the SAA to review every program that receives funding,
which allows for increased coordination across grants and efficiencies in
procurement and helps alleviate the risk of funding duplicative grants. The




39
   Threat and Hazard Identification Risk Assessments (THIRA) establish a foundation to
justify and guide preparedness activities and investments. THIRAs should include the
range of threats and hazards faced by an applicant. The assessment should be based on
analysis of the relative consequences of the various threats and hazards with
consideration of empirical data to the maximum degree possible. An effective THIRA will
allow the applicant to compare and prioritize risks, even if they are dissimilar, by
identifying possible threats and hazards faced with respective probability estimates of their
occurrence. THIRA findings should be incorporated into each applicant‘s preparedness
strategy, planning, Investment Justification, and assessment documentation and address
capability gaps identified during the THIRA process.




Page 27                                           GAO-12-303 Preparedness Grant Programs
system was included as a best practice in the OIG’s 2011 audit of New
Jersey’s grant programs. 40

Officials in all five localities we visited commented that they rely on
informal structures to coordinate or identify potential unnecessary
duplication––such as having the USCG Captain of the Port involved in a
UAWG committee. Additionally, officials from three locations we visited
also noted having tried to set up more formal coordination structures. For
example, the UAWG in one Texas locality set up a peer-to-peer network
with other UASI regions around the state to exchange information. A
county official from a UAWG in Washington State reported that they have
set up monthly small group meetings with officials from surrounding
counties who deal with SHSP and UASI in an effort to exchange
information and improve coordination.

While FEMA, states, and local government have taken steps to improve
coordination, our review of FEMA’s internal coordination showed that the
agency lacks a process to coordinate reviews across the four grant
programs. GPD has divided the administration of the grant programs into
two separate branches: UASI and SHSP are administered by the
Homeland Security Grant Program branch while PSGP and TSGP are
administered by the Transportation Infrastructure Security branch. The
result of this structure is that grant applications are reviewed separately
by program but are not compared across each other to determine where
possible unnecessary duplication may occur. As we noted earlier, each
grant program we reviewed has similar goals, allowable costs, and
geographic proximity. Due to this structure, these four programs share
applicants as state and local entities seek to maximize grant dollars for
their projects. However, since the review process for grant applications
falls within each separate branch and grant program––and since there is
no process in place to ensure that grant information is exchanged in the
review process—FEMA cannot identify whether grant monies are being
used for any unnecessary duplicative purposes. Similarly, in 2010, the
OIG noted that FEMA does not have an overarching policy to coordinate




40
   DHS-OIG, The State of New Jersey’s Management of State Homeland Security
Program and Urban Areas Security Initiative Grants Awarded During Fiscal Years 2007
through 2009, OIG-11-112 (Sept. 26, 2011).




Page 28                                       GAO-12-303 Preparedness Grant Programs
grant programs and outline roles and responsibilities for coordinating
applications across grant programs. 41

Standards for Internal Control in the Federal Government call for
agencies to have the information necessary to achieve their objectives
and determine whether they are meeting their agencies’ strategic goals.
FEMA’s strategic goals for fiscal years 2009 through 2011 included
teaming with internal and external stakeholders to build partnerships and
increase communication, and to streamline, standardize, and document
key processes to promote collaboration and consistency across regions
and programs. Because the four grant programs are being reviewed by
two separate divisions, yet have similar allowable costs, coordinating the
review of grant projects internally could allow FEMA to have more
complete information about grant applications across the four different
programs. This is necessary to identify overlap and mitigate the risk of
duplication across grant applications. One of FEMA’s section chiefs noted
that the primary reasons for the current lack of coordination across
programs are the sheer volume of grant applications that need to be
reviewed and FEMA’s lack of resources to coordinate the grant review
process. She added that FEMA reminds grantees not to duplicate grant
projects; however, due to volume and the number of activities associated
with grant application reviews, FEMA lacks the capabilities to cross-check
for unnecessary duplication. We recognize the challenges associated with
reviewing a large volume of grant applications, but to help reduce the risk
of funding duplicative projects, FEMA could benefit from exploring
opportunities to enhance its coordination of project reviews while also
taking into account the large volume of grant applications it must process.




41
     OIG-10-69.




Page 29                                 GAO-12-303 Preparedness Grant Programs
Some Performance
Measures Exist for
Individual Grant
Programs, but Work
Remains to Assess
Grant Effectiveness

DHS Has Some                 DHS implemented some performance measures for SHSP and UASI in
Performance Measures,        the fiscal year 2011 grant guidance, but has not yet implemented
but Until Additional         comparable measures for PSGP and TSGP. Moreover, the type of
                             measures DHS published in the SHSP and UASI guidance do not
Measures Are                 contribute to DHS’s ability to assess the effectiveness of these grant
Implemented It Cannot        programs, but instead provide DHS with information to help it measure
Assess Grant Effectiveness   completion of tasks or activities. DHS has efforts underway to develop
                             additional measures to help it assess grant program effectiveness;
                             however, until these measures are implemented, it will be difficult for DHS
                             to determine the effectiveness of grant-funded projects, which totaled
                             $20.3 billion from fiscal years 2002 through 2011.

                             As a part of its risk management framework, the National Infrastructure
                             Protection Plan calls for agencies to measure progress in security
                             improvements against sector goals using both output measures, which
                             track the progression of tasks associated with a program or activity, and
                             outcome measures, which help an agency evaluate the extent to which a
                             program achieves sector goals and objectives—that is, their
                             effectiveness. The measures that DHS implemented for SHSP and UASI
                             through the fiscal year 2011 guidance are output measures. For example,
                             some of the output measures implemented for SHSP and UASI include:
                             (1) the percentage of fusion center 42 analysts that require secret
                             clearances that have them (or have submitted requests for them); (2) the



                             42
                                Since 2001, all 50 states and some local governments have established fusion centers
                             to address gaps in terrorism-related information sharing that the federal government
                             cannot address alone and to provide a mechanism for information sharing within the state.
                             For more information on fusion centers, see GAO, Information Sharing: Federal Agencies
                             Are Helping Fusion Centers Build and Sustain Capabilities and Protect Privacy, but Could
                             Measure Results, GAO-10-972 (Washington, D.C.: Sept. 29, 2010).




                             Page 30                                         GAO-12-303 Preparedness Grant Programs
percentage of SHSP and UASI funded personnel who are engaged in the
Nationwide Suspicious Activity Reporting Initiative 43 and have completed
the training; and, (3) the approval of a State Hazard Mitigation Plan that
includes a THIRA that has been coordinated with UASI(s) located in the
state.

Implementing output measures for the SHSP and UASI grant programs
provides value and is a step in the right direction because they allow
FEMA to track grant-funded activities. However, outcome measures
would be more useful to FEMA in determining the effectiveness of these
grant programs. As of February 2012, DHS had not implemented
outcome measures for any of the four grant programs in our review. Our
previous work has underscored how the absence of outcome measures
has negatively impacted DHS’s ability to assess the achievement of
desired program outcomes to further homeland security preparedness
goals. 44 Additionally, the National Infrastructure Protection Plan instructs
agencies to track progress towards strategic goals and objectives by
measuring results or outcomes, and it states that aligning outcome
measures to goals and objectives is the key to performance
management. As shown in table 5 below, FEMA had efforts under way in
2010 and 2011 to develop outcome measures for the four grant programs
in our review.




43
   The federal government is working with state, local, and tribal government agencies to
implement the Nationwide Suspicious Activity Reporting initiative. This effort is intended to
establish a nationwide capability to gather and share information about suspicious
incidents to enable rapid identification and mitigation of potential terrorist threats.
44
   GAO, DHS Improved its Risk-Based Grant Programs' Allocation and Management
Methods, But Measuring Programs' Impact on National Capabilities Remains a Challenge,
GAO-08-488T (Washington D.C.: Mar. 11, 2008).




Page 31                                           GAO-12-303 Preparedness Grant Programs
Table 5: Selected DHS Grant Program Initiatives to Develop Outcome-Based Performance Measures

Grant program
affected         Initiative name         Initiative description                      Expected result           Status
 SHSP            National Academy of     The Redundancy Elimination                  Three to seven            NAPA began work on this
 UASI            Public Administration   and Enhanced Performance for                proposed measures and     project in January 2011, with
                                                                    b
                 (NAPA) Study            Preparedness Grants Act                     an implementation         performance measure
                                         directed the Administrator of               roadmap.                  implementation scheduled for
                                         FEMA to enter into a contract                                         December 2011. In October
                                         with NAPA to assist the                                               2011, NAPA provided FEMA
                                         administrator in studying,                                            with a copy of the final report,
                                         developing, and implementing                                          according to FEMA officials.
                                         performance measures to                                               As of December 2011, FEMA
                                         assess the effectiveness of                                           officials stated that the results
                                         SHSP and UASI, among other                                            of the NAPA study are under
                                         things.                                                               review within FEMA and no
                                                                                                               measures have been
                                                                                                               implemented.
        a
PSGP             FEMA Task Force on      In January 2010, GPD formed a               Development of            As of December 2011, the
TSGP             Performance             task force to develop measures              program-specific          Director of the National
                 Measures                to assess the effectiveness of              performance measures      Preparedness Assessment
                                         PSGP and TSGP. In December                  for PSGP and TSGP.        Division (NPAD) within NPD
                                         2010, this effort was transferred                                     told us that NPD had
                                         to NPD.                                                               developed draft performance
                                                                                                               measures for the PSGP and
                                                                                                               TSGP and that those
                                                                                                               measures were undergoing
                                                                                                               review within FEMA. As a
                                                                                                               result, the official told us that it
                                                                                                               is unclear if FEMA would
                                                                                                               include these measures in its
                                                                                                               fiscal year 2012 grant
                                                                                                                          c
                                                                                                               guidance.
                                         Source: GAO analysis of FEMA information.
                                         a
                                          For more information about FEMA’s efforts to measure the effectiveness of the PSGP, see
                                         GAO-12-47.
                                         b
                                             Pub. L. No. 111-271, § 2(a), 124 Stat. 2852 (2010) (codified at 6 U.S.C. § 613(d)).
                                         c
                                           On February 17, 2012, FEMA released the fiscal year 2012 Funding Opportunity Announcement for
                                         the PSGP and TSGP. However, this guidance did not contain performance measures.


                                         FEMA has taken steps to develop outcome-based measures through
                                         these initiatives; however, as of February 2012, FEMA had not completed
                                         its efforts. According to FEMA officials, DHS leadership has identified
                                         performance measurement as a high priority issue, and is developing a
                                         more quantitative approach for using grant expenditure data to monitor
                                         program effectiveness. 45 Further, senior FEMA officials have noted


                                         45
                                              GAO-08-488T.




                                         Page 32                                                   GAO-12-303 Preparedness Grant Programs
challenges to measuring preparedness. For example, they have noted
that SHSP and UASI fund a wide range of different preparedness
activities, which makes it difficult to devise applicable measures. Thus, if
measures are too broad they are meaningless and if too narrow they may
not adequately capture the effectiveness of a range of activities. Senior
FEMA officials noted another challenge in that grant program goals are
purposefully broad to accommodate a broad constituency. For example,
SHSP is administered in all states. However, the security conditions and
preparedness needs of a state such as North Dakota are very different
from those of New York, yet the grant goals, guidance, and measures
would be the same for both locales.

FEMA provided us with its Performance Measure Implementation Plan, 46
an internal plan that FEMA uses for developing measures for all
preparedness grants; however, this plan provides insufficient detail to
guide these efforts. This plan identifies the output measures that were
included in the fiscal year 2011 guidance for SHSP and UASI. Further the
plan notes that NPD’s National Preparedness Assessment Division
(NPAD) has developed new performance measures that seek to better
capture the outcomes and overall effectiveness of preparedness grants,
rather than the outputs captured by current measures; however, it does
not specify what outcome measures were developed. 47 Instead, the
implementation plan provides a general approach to performance
measurement as well as a list of key milestones to implement the new
performance measures and refine existing measures. In addition, the
implementation plan notes that it is NPAD’s goal to develop one or two
measures per grant program that are both output and outcome based.
However, the associated activities and milestones listed in the plan do not
reference specific grant programs or project details. As a result, it is
unclear what grants, or what measures, are being addressed for each
milestone. According to FEMA’s current implementation plan, all
performance measures should have been implemented in December
2011; however, FEMA officials reported in December 2011 that outcome
measures for the four programs had not yet been implemented.


46
   According to FEMA, the Performance Measure Implementation Plan is an internal plan
that provides the agency’s general approach to performance measurement as well as a
key list of milestones for implementing the agency’s new performance measures and
refining its existing measures related to preparedness grants.
47
  The National Preparedness Assessment Division (NPAD) is responsible for evaluation
and assessment of preparedness grant programs, among other things.




Page 33                                       GAO-12-303 Preparedness Grant Programs
                             According to the Project Management Institute, best practices for project
                             management call for a variety of inputs and outputs when developing a
                             project schedule, including the basis for date estimates, a breakdown of
                             the work to be conducted for each program, resource capabilities and
                             availability, and external and internal dependencies. FEMA’s
                             implementation plan does not contain this level of detail and as a result, it
                             remains unclear what measures will be implemented for each grant
                             program and when this implementation will occur. Establishing
                             performance measures for these four programs is important given their
                             relatively large size and scope. We recognize the difficulties inherent in
                             developing outcome-based performance measures to assess the
                             effectiveness of these grant programs. However, DHS should continue to
                             work towards the development of these measures to improve its ability to
                             assess the effectiveness of these grant programs. Until DHS does so it
                             will be difficult for it to determine the extent to which its investment
                             through these programs––$20.3 billion from 2002 through 2011—is
                             effectively enhancing homeland security. A revised implementation plan
                             that includes more specific project schedule information and accurate
                             timelines for implementation could help guide efforts and keep the
                             development of these measures on track for successful and timely
                             implementation.


DHS Has Initiatives under    Apart from developing performance measures for each grant program,
Way to Evaluate Overall      DHS also has several initiatives under way to measure the collective
Effectiveness across Grant   effectiveness of its grant programs in achieving shared program goals, as
                             shown in table 6 below.
Programs, but Has Not
Completed These Efforts




                             Page 34                                  GAO-12-303 Preparedness Grant Programs
Table 6: FEMA Initiatives to Evaluate Overall Effectiveness across Grant Programs

                     Grants
                     affected (in
Action/program       this review)   Description                         Expected result                       Status
Revising             SHSP, UASI, Presidential Policy                    DHS is responsible for                In November 2011, FEMA
Preparedness         PSGP, TSGP Directive-8 (PPD-8)                     measuring the readiness of            released the National
Guidance                         replaces HSPD-8 and                    current national capabilities with    Preparedness System
                                 requires that a new                    clear, objective and quantifiable     description, which is designed to
                                 national preparedness                  performance measures. The             lay the groundwork for
                                 system include a                       structure of this measurement         strengthening the nation’s
                                 comprehensive system to                system will drive the                 resilience against all threats and
                                 assess national                        development of any future             hazards. The system description
                                 preparedness.                          performance measures.                 is the second deliverable called
                                                                                                              for by PPD-8. According to a
                                                                                                              DHS publication, further details
                                                                                                              on how the National
                                                                                                              Preparedness System will be
                                                                                                              implemented will be provided as
                                                                                                              the remaining PPD-8
                                                                                                              deliverables are developed.
Implementing the     SHSP, UASI, ND Grants is a web-based               According to FEMA, the ND             In fiscal year 2011, FEMA
ND Grants System     PSGP, TSGP system intended to                      Grants system is intended to          implemented portions of the ND
                                 provide FEMA and its                   consolidate FEMA’s disparate          Grants system. At this time, ND
                                 stakeholders with a                    data systems and improve the          Grants cannot collect or provide
                                 system that supports the               ability of FEMA grant managers        comprehensive information
                                 grants management                      to track grants through the           across grant programs.
                                 lifecycle and consolidates             review and approval process, a        According to FEMA, the system
                                 grant information.                     capability that will also assist      is scheduled for completion in
                                                                        with evaluating grant                 fiscal year 2014.
                                                                        performance.
Implementing Threat SHSP, UASI      THIRA requires                      The goal of THIRA is to create a      The THIRA was first called for
Hazard Identification               jurisdictions to add a              standardized system that              as part of the fiscal year 2011
Risk Assessment                     threat evaluation to the            establishes baseline risks and        Homeland Security Grant
(THIRA)                             existing Hazard                     capabilities at the local level and   Program.
                                    Identification Risk                 provides a justification for
                                    Assessment mitigation               investments in preparedness.
                                    process.
                                          Source: GAO analysis of FEMA information.



                                          As shown above, FEMA’S efforts to measure the collective effectiveness
                                          of its grants programs are recent and ongoing and thus it is too soon to
                                          evaluate the extent to which these initiatives will provide FEMA with the
                                          information it needs to determine whether these grant programs are
                                          effectively improving the nation’s security. While each grant program
                                          strives to identify and mitigate security concerns within its specific
                                          authority, improving the nation’s overall preparedness is dependent upon
                                          collectively addressing capability and security gaps across all programs
                                          and authorities. Thus, it is important to evaluate effectiveness across the
                                          four grant programs to determine the extent to which the security of the


                                          Page 35                                                   GAO-12-303 Preparedness Grant Programs
              nation as a whole has improved and to better ensure the effective use of
              scarce resources.


              From fiscal years 2002 through 2011, DHS has distributed about $20.3
Conclusions   billion through four homeland security preparedness grants that
              specifically target state, urban, port, and transit security. We recognize
              that even when programs overlap, they may have meaningful differences
              in their eligibility criteria or objectives, or they may provide similar types of
              services in different ways. However, because the four DHS programs in
              our review have similar goals, fund similar types of projects, and are
              awarded in many of the same urban areas, it will be important for FEMA
              to take additional measures to help ensure that the risk of duplication is
              mitigated. FEMA has delegated significant administrative duties to the
              SAA for the larger SHSP and UASI programs, and FEMA officials
              recognize the trade-off between decreased visibility over these grants and
              the reduced administrative burden on FEMA. However, the limited
              project-level information on how funds are being used and the lack of
              coordinated reviews of grant applications across programs, increases the
              risk that FEMA could fund duplicative projects. Additional action could
              help mitigate this risk. For example, as FEMA develops the ND Grants
              system, it will be important for the agency to ensure that information
              collected for all grant programs provides enough detail to allow for project
              comparisons in order to identify any unnecessary duplication. In addition,
              while some steps have been taken at the federal, state, and local levels to
              improve coordination in administering the four grant programs, additional
              actions could also help reduce the risk of duplication. For example,
              without a process to coordinate reviews across the four grant programs,
              FEMA lacks the information necessary to identify whether grant monies
              are being used for duplicative purposes, especially since all four grant
              programs are being reviewed separately, yet have similar allowable costs.
              Thus, to reduce the risk of duplication, FEMA could benefit from exploring
              opportunities to enhance its coordination of project reviews across grant
              programs. Additionally, since DHS’s existing output-based performance
              measures for the SHSP and UASI programs do not provide DHS with the
              information it needs to assess grant effectiveness and FEMA has not yet
              implemented outcome-based performance measures for any of the four
              programs, it will be difficult for FEMA to fully assess the effectiveness of
              these grant programs. Because the project plan FEMA has in place to
              guide its efforts to develop measures does not provide adequate
              information to determine what measures will be implemented for each
              grant program and when this implementation will occur, FEMA does not



              Page 36                                    GAO-12-303 Preparedness Grant Programs
                      have reasonable assurance that these measures will be implemented in a
                      timely way to help assess the programs’ effectiveness.


                      We are making three recommendations for the four grant programs. Two
Recommendations for   actions are recommended to help reduce the risk of duplication by
Executive Action      strengthening DHS’s administration and oversight of these programs, and
                      one action is recommended to better assess the effectiveness of these
                      programs.

                      To better identify and reduce the risk of duplication through improved data
                      collection and coordination, we recommend that the FEMA Administrator:

                      •   take steps, when developing ND Grants and responding to the May
                          2011 FEMA report recommendations on data requirements, to ensure
                          that FEMA collects project information with the level of detail needed
                          to better position the agency to identify any potential unnecessary
                          duplication within and across the four grant programs, weighing any
                          additional costs of collecting these data; and

                      •   explore opportunities to enhance FEMA’s internal coordination and
                          administration of the programs in order to identify and mitigate the
                          potential for any unnecessary duplication.
                      To better assess the effectiveness of these programs, we recommend
                      that the FEMA Administrator:

                      •   revise the agency’s Performance Measure Implementation Plan to
                          include more specific project schedule information and accurate
                          timelines in order to guide the timely completion of ongoing efforts to
                          develop and implement outcome-based performance measures for
                          the SHSP, UASI, PSGP, and TSGP grant programs.

                      We provided a draft of this report to DHS for comment. We received
Agency Comments       written comments on the draft report, which are reprinted in appendix II.
and Our Evaluation    DHS concurred with all three recommendations, and requested that the
                      first two recommendations be considered resolved and closed. While we
                      believe that DHS’s planned actions, if implemented, address the intent of
                      each recommendation, it is too soon to close any recommendation as
                      implemented. Specifically:




                      Page 37                                  GAO-12-303 Preparedness Grant Programs
•   DHS agreed with the recommendation that FEMA take steps to
    ensure that it collects sufficient project information to better identify
    any potential unnecessary duplication, and asked that, based on
    actions currently under way and other proposed changes, the
    recommendation be closed. DHS cited the elimination of seven
    programs in fiscal year 2012 and the proposed restructuring of most
    programs under a single National Preparedness Grant Program in
    fiscal year 2013 as steps to eliminate unnecessary duplication. DHS
    also cited modifying one reporting requirement in fiscal year 2012 to
    better capture program-specific performance measures. While we
    agree that program restructuring and the cited reporting requirement
    change could offer FEMA the opportunity to improve its grants data
    and thus its visibility across programs and projects, it is too soon to
    assess any positive impact, especially given that the outcome of the
    proposed fiscal year 2013 program restructuring is uncertain and is
    reliant on future congressional action. Furthermore, consolidating
    programs alone will not guarantee that the level of project-level detail
    collected by FEMA will be sufficient to identify unnecessary
    duplication of similar efforts in the same geographic areas. We will
    review the status of these efforts and additional supporting evidence
    in the future before closing this recommendation.

•   DHS agreed with the recommendation that FEMA explore
    opportunities to enhance internal coordination and administration of
    the programs to identify and mitigate the potential for any
    unnecessary duplication, and asked that, based on ongoing actions
    and plans, the recommendation be closed. For example, DHS stated
    that FEMA officials participate in an Intra-agency Grants Task Force
    to provide strategic links among FEMA grant programs, as well as a
    DHS-level task force to improve grants management across the
    department. DHS also stated that FEMA has formal memoranda of
    understanding with partner agencies/offices related to various grants
    administration roles and responsibilities, and continues to develop
    additional formal agreements. We view these as positive steps in
    coordinating grants administration within DHS and FEMA. However, it
    is not clear at this time that the various groups or formal agreements
    have specifically addressed preventing potential unnecessary
    duplication across programs or projects, or that this is a goal of the
    initiatives. We will review the status of these efforts and additional
    supporting evidence in the future before closing this recommendation.

•   DHS agreed with the recommendation to revise the agency’s
    Performance Measure Implementation Plan and stated that new


Page 38                                   GAO-12-303 Preparedness Grant Programs
    performance measures and a plan for data collection are in draft form.
    DHS also stated it will provide an update to the plan when decisions
    are finalized, and that these decisions will be informed by the outcome
    of the agency’s proposed changes to the fiscal year 2013 grant
    programs.

DHS also provided technical comments which we incorporated into the
report where appropriate.



As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies to the Secretary of
Homeland Security, appropriate congressional committees, and other
interested parties. In addition, the report will be available at no charge on
the GAO website at http://www.gao.gov. If you or your staff have any
questions concerning this report, please contact me at (201) 512-9627 or
maurerd@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs can be found on the last page of this report.
Key contributors to this report are listed in appendix III.




David C. Maurer
Director, Homeland Security and Justice Issues




Page 39                                  GAO-12-303 Preparedness Grant Programs
List of Requesters

The Honorable John D Rockefeller IV
Chairman
Committee on Commerce, Science and Transportation
United States Senate

The Honorable Joseph Lieberman
Chairman
The Honorable Susan Collins
Ranking Member
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Thomas Coburn
Ranking Member
Permanent Subcommittee on Investigations
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Peter King
Chairman
Committee on Homeland Security
House of Representatives

The Honorable Gus Bilirakis
Chairman
Subcommittee on Emergency Preparedness, Response, and
Communications
Committee on Homeland Security
House of Representatives




Page 40                             GAO-12-303 Preparedness Grant Programs
Appendix I: FEMA Grants Portfolio
              Appendix I: FEMA Grants Portfolio




              a
                SHSP, UASI, Metropolitan Medical Response System, Operation Stonegarden, and Citizen Corps
              Program collectively make up what FEMA terms the Homeland Security Grant Program. The 5
              interconnected programs shared the same grant guidance in fiscal year 2011, but each program had
              a separate funding allocation.




              Page 41                                             GAO-12-303 Preparedness Grant Programs
Appendix II: Comments from the Department
             Appendix II: Comments from the Department
             of Homeland Security



of Homeland Security




             Page 42                                     GAO-12-303 Preparedness Grant Programs
Appendix II: Comments from the Department
of Homeland Security




Page 43                                     GAO-12-303 Preparedness Grant Programs
Appendix II: Comments from the Department
of Homeland Security




Page 44                                     GAO-12-303 Preparedness Grant Programs
Appendix II: Comments from the Department
of Homeland Security




Page 45                                     GAO-12-303 Preparedness Grant Programs
Appendix III: GAO Contact and Staff
                  Appendix III: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

GAO Contact       David C. Maurer, (202) 512-9627 or Maurerd@gao.gov


                  In addition to the contacts above, Dawn Hoff, Assistant Director, and Dan
Staff             Klabunde, Analyst-in-Charge, managed this assignment. Chuck Bausell,
Acknowledgments   Juli Digate, David Lutter, Sophia Payind, and Katy Trenholme made
                  significant contributions to this report. David Alexander assisted with
                  design, methodology, and data analysis. Linda Miller and Jessica Orr
                  provided assistance with report development, Muriel Brown and Robert
                  Robinson provided graphic support, and Tracey King provided legal
                  assistance.




(440972)
                  Page 46                                GAO-12-303 Preparedness Grant Programs
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