oversight

Managing Preparedness Grants and Assessing National Capabilities: Continuing Challenges Impede FEMA's Progress

Published by the Government Accountability Office on 2012-03-20.

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

                             United States Government Accountability Office

GAO                          Testimony before the Subcommittee on
                             Emergency Preparedness, Response, and
                             Communications, Committee on
                             Homeland Security, House of
                             Representatives

                             MANAGING
For Release on Delivery
Expected at 10:00 a.m. EDT
Tuesday, March 20, 2012

                             PREPAREDNESS GRANTS
                             AND ASSESSING
                             NATIONAL CAPABILITIES
                             Continuing Challenges
                             Impede FEMA’s Progress
                             Statement of William O. Jenkins, Jr., Director
                             Homeland Security and Justice




GAO-12-526T
                                                March 20, 2012

                                                FEDERAL EMERGENCY MANAGEMENT
                                                AGENCY
                                                Continuing Challenges Impede Progress in Managing
Highlights of GAO-12-526T, a testimony
                                                Preparedness Grants and Assessing National
before the Subcommittee on Emergency            Capabilities
Preparedness, Response, and
Communications, Committee on Homeland
Security, House of Representatives


Why GAO Did This Study                          What GAO Found
From fiscal years 2002 through 2011,            DHS and FEMA have taken actions with the goal of enhancing management of
the federal government appropriated             preparedness grants, but better project information and coordination could help
over $37 billion to the Department of           FEMA identify and mitigate the risk of unnecessary duplication among grant
Homeland Security’s (DHS)                       applications. Specifically, DHS and FEMA have taken actions to streamline the
preparedness grant programs to                  application and award processes and have enhanced their use of risk
enhance the capabilities of state and           management for allocating grants. For example, in November 2011, GAO
local governments to prevent, protect           reported that DHS modified its risk assessment model for the Port Security Grant
against, respond to, and recover from           Program by recognizing that different ports have different vulnerability levels.
terrorist attacks. DHS allocated $20.3
                                                However, in February 2012, GAO reported that FEMA made award decisions for
billion of this funding to grant recipients
                                                four of its grant programs—the State Homeland Security Grant Program, the
through four of the largest
preparedness grant programs—the
                                                Urban Area Security Initiative, the Port Security Grant Program, and the Transit
State Homeland Security Program, the            Security Grant Program—with differing levels of information, which contributed to
Urban Areas Security Initiative, the            the risk of funding unnecessarily duplicative projects. GAO also reported that
Port Security Grant Program, and the            FEMA did not have a process to coordinate application reviews across the four
Transit Security Grant Program. The             grant programs. Rather, grant applications were reviewed separately by program
Post-Katrina Emergency Management               and were not compared across each other to determine where possible
Reform Act of 2006 requires the                 unnecessary duplication may occur. Thus, GAO recommended that (1) FEMA
Federal Emergency Management                    collect project information with the level of detail needed to better position the
Agency (FEMA) to develop a national             agency to identify any potential unnecessary duplication within and across the
preparedness system and assess                  four grant programs, weighing any additional costs of collecting this data and (2)
preparedness capabilities—capabilities          explore opportunities to enhance FEMA’s internal coordination and
needed to respond effectively to                administration of the programs to identify and mitigate the potential for any
disasters. FEMA could then use such a           unnecessary duplication. DHS agreed and identified planned actions to improve
system to help it prioritize grant              visibility and coordination across programs and projects. FEMA has proposed
funding. This testimony addresses the           consolidating the majority of its various preparedness grant programs into a
extent to which DHS and FEMA have               single, comprehensive preparedness grant program called the National
made progress in managing                       Preparedness Grant Program (NPGP) in fiscal year 2013; however, this may
preparedness grants and measuring
                                                create new challenges. For example, allocations under the NPGP would rely
preparedness by assessing capabilities
                                                heavily on a state’s risk assessment, but grantees have not yet received
and addressing related challenges.
GAO’s comments are based on                     guidance on how to conduct the risk assessment process. FEMA has established
products issued from April 2002                 a website to solicit input from stakeholders on how best to implement the
through February 2012 and selected              program.
updates conducted in March 2012.
                                                DHS and FEMA have had difficulty implementing longstanding plans and
What GAO Recommends                             overcoming challenges in assessing capabilities, such as determining how to
                                                validate and aggregate data from federal, state, local, and tribal governments.
GAO has made recommendations to
DHS and FEMA in prior reports to                For example, DHS first developed plans in 2004 to measure preparedness by
strengthen their management of                  assessing capabilities, but these efforts have been repeatedly delayed. In March
preparedness grants and enhance                 2011, GAO reported that FEMA’s efforts to develop and implement a
their assessment of national                    comprehensive, measurable, national preparedness assessment of capability
preparedness capabilities. DHS and              and gaps were not yet complete and suggested that Congress consider limiting
FEMA concurred and have actions                 preparedness grant funding until FEMA completes a national preparedness
underway to address them.                       assessment of capability gaps based on tiered, capability-specific performance
                                                objectives to enable prioritization of grant funding. In April 2011, Congress
                                                passed the fiscal year 2011 appropriations act for DHS that reduced funding for
View GAO-12-526T. For more information,
contact William O. Jenkins, Jr. at (202) 512-
                                                FEMA preparedness grants by $875 million from the amount requested in the
8777 or jenkinswo@gao.gov.                      President’s fiscal year 2011 budget. For fiscal year 2012, Congress appropriated
                                                $1.28 billion less than requested in the President’s budget.
                                                                                        United States Government Accountability Office
Chairman Bilirakis, Ranking Member Richardson, and Members of the
Subcommittee:

I appreciate the opportunity to participate in today’s hearing and to
discuss the efforts of the Federal Emergency Management Agency
(FEMA)—a component of the Department of Homeland Security (DHS)—
to manage preparedness grants and measure and assess national
capabilities to respond to a major disaster. From fiscal years 2002
through 2011, the federal government appropriated over $37 billion to a
variety of DHS homeland security preparedness grant programs to
enhance the capabilities of state, territory, local, and tribal governments to
prevent, protect against, respond to, and recover from terrorist attacks
and other disasters. 1 DHS allocated more than half of this total—$20.3
billion—to grant recipients through four of the largest preparedness
programs—the State Homeland Security Program, the Urban Areas
Security Initiative, the Port Security Grant Program, and the Transit
Security Grant Program.

Congress enacted the Post-Katrina Emergency Management Reform Act
of 2006 (Post-Katrina Act) in the aftermath of Hurricane Katrina. 2 In
response to the Act, DHS centralized most of its preparedness programs
under FEMA’s Grant Programs Directorate to better integrate and
coordinate grant management. The Act also requires that FEMA develop
a national preparedness system and assess preparedness capabilities—
capabilities needed to respond effectively to disasters—to determine the
nation’s preparedness capability levels and the resources needed to
achieve desired levels of capability. 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).
2
  The Post-Katrina Act was enacted as Title VI of the Department of Homeland Security
Appropriations Act, 2007, Pub. L. No. 109-295, 120 Stat. 1355 (2006). The provisions of
the Post-Katrina Act became effective upon enactment, October 4, 2006, with the
exception of certain organizational changes related to FEMA, most of which took effect on
March 31, 2007.
3
    6 U.S.C. §§ 744, 749.




Page 1                                                                       GAO-12-526T
Over the last decade, we identified and reported on issues related to
DHS’s and FEMA’s management of four of the largest preparedness
grants and the challenges associated with assessing national
preparedness capabilities. In April 2002, shortly after the terrorist attacks
of September 11, 2001, we identified the need for goals and performance
indicators to guide the nation’s preparedness efforts and help to
objectively assess the results of federal investments. 4 After DHS began
operations in March 2003, and leading up to catastrophic damage caused
by Hurricanes Katrina and Rita in August and September 2005, our
reports focused on challenges in managing preparedness grant funds to
states and urban areas and minimizing the time it takes to distribute grant
funds and associated efforts to streamline the process while ensuring
appropriate planning and accountability for effective use of the funds. 5
After the renewed focus on all-hazards preparedness prompted by the
2005 hurricanes, we reported in 2007 and 2008 on the extent to which
DHS was using a risk-based approach in its grants distribution
methodology for states and urban areas. 6 Our reports in 2009, 2010, and
2011 analyzed the use of risk assessment in the management of transit
and port security grants 7 and the impact of preparedness grants in


4
 GAO, National Preparedness: Integration of Federal, State, Local, and Private Sector
Efforts Is Critical to an Effective National Strategy for Homeland Security, GAO-02-621T
(Washington, D.C.: Apr. 11, 2002).
5
  GAO, Emergency Preparedness: Federal Funds for First Responders, GAO-04-788T
(Washington, D.C.: May 13, 2004); Homeland Security: Management of First Responder
Grant Programs Has Improved, but Challenges Remain, GAO-05-121 (Washington, D.C.:
Feb. 2, 2005); Homeland Security: Management of First Responder Grant Programs and
Efforts to Improve Accountability Continue to Evolve, GAO-05-530T (Washington, D.C.:
Apr. 12, 2005); and Homeland Security: DHS’s Efforts to Enhance First Responders’ All-
Hazards Capabilities Continue to Evolve GAO-05-652 (Washington, D.C.; July 11, 2005).
6
  GAO, Homeland Security Grants: Observations on Process DHS Used to Allocate Funds
to Selected Urban Areas GAO-07-381R (Washington, D.C.; Feb 7, 2007); Homeland
Security: 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); and Homeland Security: DHS Risk-
Based Grant Methodology Is Reasonable, But Current Version’s Measure of Vulnerability
is Limited, GAO-08-852, (Washington, D.C.; Jun 27, 2008).
7
  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.: July 8, 2009); Surface Transportation Security: TSA Has
Taken Actions to Manage Risk, Improve Coordination, and Measure Performance, but
Additional Actions Would Enhance Its Efforts, GAO-10-650T (Washington, D.C.: Apr. 21,
2010); Port Security Grant Program: Risk Model, Grant Management, and Effectiveness
Measures Could Be Strengthened, GAO-12-47 (Washington, D.C.: Nov. 17, 2011).




Page 2                                                                       GAO-12-526T
building national capabilities. During that same period, we reported on
FEMA’s limited progress in assessing national preparedness. 8 Our most
recent report, which we issued in February 2012 and are releasing today,
addresses FEMA’s management of four of the largest preparedness grant
programs—the State Homeland Security Program, the Urban Areas
Security Initiative, the Port Security Grant Program, and the Transit
Security Grant Program. 9

My remarks today are based on our work issued in the 10-year period
from April 2002 through February 2012 on the efforts of both DHS and,
more recently, FEMA, to manage preparedness grants; develop national
preparedness capabilities; implement a national framework for assessing
preparedness capabilities at the federal, state, and local levels; identify
capability gaps; and prioritize future national preparedness investments to
fill the most critical gaps. These remarks are also based on selected
updates conducted in March 2012 on FEMA’s proposal for consolidating
its various grant programs.

As requested, my testimony today focuses on the extent to which DHS
and FEMA have made progress in managing preparedness grants and
measuring national preparedness by assessing capabilities and
addressing related challenges. To conduct our work, we analyzed
documentation, such as DHS’s National Preparedness Goal and Core
Capabilities (the latest evolution of the Target Capabilities List), 10 and
interviewed relevant DHS, FEMA, state, and local officials. More detailed
information on our scope and methodology appears in our published



8
  GAO, National Preparedness: FEMA Has Made Progress, but Needs to Complete and
Integrate Planning, Exercise, and Assessment Efforts, GAO-09-369 (Washington, D.C.;
Apr. 30, 2009); Urban Area Security Initiative: FEMA Lacks Measures to Assess How
Regional Collaboration Efforts Build Preparedness Capabilities, GAO-09-651
(Washington, D.C.; Jul 2, 2009); FEMA Has Made Limited Progress in Efforts to Develop
and Implement a System to Assess National Preparedness Capabilities, GAO-11-51R
(Washington, D.C.: Oct 29, 2010); Opportunities to Reduce Potential Duplication in
Government Programs, Save Tax Dollars, and Enhance Revenue, GAO-11-318SP
(Washington, D.C. Mar. 1, 2011).
9
 GAO, Homeland Security: DHS Needs Better Project Information and Coordination
among Four Overlapping Grant Programs, GAO-12-303 (Washington, D.C.: Feb. 28,
2012).
10
   The Target Capabilities List is a list of 37 capabilities that federal, state, and local
stakeholders need to possess to respond to natural or manmade disasters; we first
reported on DHS’s efforts to develop the List in July 2005.




Page 3                                                                              GAO-12-526T
                      products. In addition, we conducted updates to our work in March 2012
                      by analyzing FEMA’s guidance and policies.

                      We conducted our work in accordance with generally accepted
                      government auditing standards. 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


                      DHS and FEMA have streamlined application and award processes,
FEMA Has Taken        enhanced the use of risk management principles in its grant programs,
Actions to Address    and proposed consolidation of its various grant programs to address grant
                      management concerns. In February 2012, we reported that better
Grant Management      coordination and improved data collection could help FEMA identify and
Concerns but Needs    mitigate potential unnecessary duplication among four overlapping grant
Better Coordination   programs—the Homeland Security Grant Program, the Urban Areas
                      Security Initiative, the Port Security Grant Program, and the Transit
                      Security Grant Program. FEMA has proposed changes to enhance
                      preparedness grant management, but these changes may create new
                      challenges.




                      Page 4                                                           GAO-12-526T
FEMA Has Streamlined     Since its creation in April 2007, FEMA’s Grant Programs Directorate
Application and Award    (GPD) has been responsible for the program management of DHS’s
Processes and Enhanced   preparedness grants. 11 GPD consolidated the grant business operations,
                         systems, training, policy, and oversight of all FEMA grants and the
Use of Risk Management
                         program management of preparedness grants into a single entity. GPD
Principles               works closely with other DHS entities to manage grants, as needed,
                         through the grant life cycle, shown in figure 1. For example, GPD works
                         with the U.S. Coast Guard for the Port Security Grant Program and the
                         Transportation Security Administration for the Transit Security Grant
                         Program.




                         11
                            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).




                         Page 5                                                                    GAO-12-526T
Figure 1: General Grant Life Cycle




                                     Since 2006, DHS has taken a number of actions to improve its risk-based
                                     grant allocation methodology.

                                     •   Specifically, in March 2008, we reported that DHS had adopted a
                                         more sophisticated risk-based grant allocation approach for the Urban
                                         Areas Security Initiative to (1) determine both states’ and urban areas’
                                         potential risk relative to other areas that included empirical analytical
                                         methods and policy judgments, and (2) assess and score the



                                     Page 6                                                            GAO-12-526T
      effectiveness of the proposed investments submitted by the eligible
      applicants and determine the final amount of funds awarded. 12

•     We also reported that DHS’s risk model for the Urban Areas Security
      Initiative could be strengthened by measuring variations in
      vulnerability. 13 Specifically, we reported that DHS had held
      vulnerability constant, which limited the model’s overall ability to
      assess risk and more precisely allocate funds. Accordingly, we
      recommended that DHS and FEMA formulate a method to measure
      vulnerability in a way that captures variations in vulnerability, and
      apply this vulnerability measure in future iterations of this risk-based
      grant allocation model. DHS concurred with our recommendations
      and FEMA took actions to enhance its approaches for assessing and
      incorporating vulnerability into risk assessment methodologies for this
      program. Specifically, FEMA created a risk assessment that places
      greater weight on threat and calculates the contribution of vulnerability
      and consequence separately. 14

•     In June 2009, we reported that DHS used a risk analysis model to
      allocate Transit Security Grant Program funding and awarded grants
      to higher-risk transit agencies using all three elements of risk—threat,
      vulnerability, and consequence. 15 Accordingly, we recommended that
      DHS formulate a method to measure vulnerability in a way that
      captures variations in vulnerability, and apply this vulnerability
      measure in future iterations of this risk-based grant allocation model.
      DHS concurred with our recommendations and FEMA took actions to
      enhance its approach for assessing and incorporating vulnerability
      into risk assessment methodologies for this program.

•     In November 2011, we reported that DHS had made modifications to
      enhance the Port Security Grant Program’s risk assessment model’s
      vulnerability element for fiscal year 2011. 16 Specifically, DHS modified



12
     GAO-08-488T.
13
     GAO-08-852.
14
  U.S. Department of Homeland Security, Fiscal Year 2011 Homeland Security Grant
Program Guidance and Application Kit, (Washington, D.C., May 2011.)
15
     GAO-09-491.
16
     GAO-12-47.




Page 7                                                                  GAO-12-526T
                                 the vulnerability equation to recognize that different ports have
                                 different vulnerability levels. We also reported that FEMA had taken
                                 actions to streamline the Port Security Grant Program’s management
                                 efforts. For example, FEMA shortened application time frames by
                                 requiring port areas to submit specific project proposals at the time of
                                 grant application. According to FEMA officials, this change was
                                 intended to expedite the grant distribution process. Further, we
                                 reported that to speed the process, DHS took actions to reduce
                                 delays in environmental reviews, increased the number of GPD staff
                                 working on the Port Security Grants, revised and streamlined grant
                                 application forms, and developed time frames for review of project
                                 documentation. 17


FEMA Needs Better          Despite these continuing efforts to enhance preparedness grant
Coordination and           management, we identified multiple factors in our February 2012 report
Improved Data Collection   that contributed to the risk of FEMA potentially funding unnecessarily
                           duplicative projects across the four grant programs we reviewed—the
to Reduce Risk of          Homeland Security Grant Program, the Urban Areas Security Initiative,
Unnecessary Duplication    the Port Security Grant Program, and the Transit Security Grant
                           Program. 18 These factors include overlap among grant recipients, goals,
                           and geographic locations, combined with differing levels of information
                           that FEMA had available regarding grant projects and recipients. We also
                           reported that FEMA lacked a process to coordinate application reviews
                           across the four grant programs.

                           Overlap among grant recipients, goals, and geographic locations
                           exist. The four grant programs we reviewed have similar goals and fund
                           similar activities, such as equipment and training in overlapping
                           jurisdictions, which increases the risk of unnecessary duplication among
                           the programs. For instance, each state and eligible territory receives a
                           legislatively-mandated minimum amount of State Homeland Security
                           Program funding to help ensure that geographic areas develop a basic
                           level of preparedness, while the Urban Areas Security Initiative grants
                           explicitly target urban areas most at risk of terrorist attack. However,
                           many jurisdictions within designated Urban Areas Security Initiative
                           regions also apply for and receive State Homeland Security Program
                           funding. Similarly, port stakeholders in urban areas could receive funding


                           17
                                GAO-12-47.
                           18
                                GAO-12-303.




                           Page 8                                                              GAO-12-526T
for equipment such as patrol boats through both the Port Security Grant
Program and the Urban Areas Security Initiative, and a transit agency
could purchase surveillance equipment with Transit Security Grant
Program or Urban Areas Security Initiative funding. While we understand
that some overlap may be desirable to provide multiple sources of
funding, a lack of visibility over grant award details around these
programs increases the risk of unintended and unnecessary duplication.

FEMA made award decisions for all four grant programs with
differing levels of information. In February 2012, we reported that
FEMA’s ability to track which projects receive funding among the four
grant programs varied because the project information FEMA had
available to make award decisions—including grant funding amounts,
grant recipients, and grant funding purposes—also varied by program due
to differences in the grant programs’ administrative processes. For
example, FEMA delegated some administrative duties to stakeholders for
the State Homeland Security Program and the Urban Areas Security
Initiative, thereby reducing its administrative burden. However, this
delegation also contributed to FEMA having less visibility over some grant
applications. FEMA recognized the trade-off between decreased visibility
over grant funding in exchange for its reduced administrative burden.

Differences in information requirements also affected the level of
information that FEMA had available for making grant award decisions.
For example, for the State Homeland Security Program and Urban Areas
Security Initiative, states and eligible urban areas submit investment
justifications for each program with up to 15 distinct investment
descriptions that describe general proposals in wide-ranging areas such
as “critical infrastructure protection.” 19 Each investment justification
encompasses multiple specific projects to different jurisdictions or entities,
but project-level information, such as a detailed listing of subrecipients or
equipment costs, is not required by FEMA. In contrast, Port Security and
Transit Security Grant Program applications require specific information
on individual projects such as detailed budget summaries. As a result,


19
   Investment justifications are one component of the State Homeland Security Grant
Program, the Urban Areas Security Initiative, the Port Security Grant Program, and the
Transit Security Grant Program applications for grant funding. They provide narrative
information on proposed activities (investments) that are to be accomplished with the
grant funds. The investment justifications must demonstrate how proposed investments
address gaps and deficiencies in current capabilities, and also demonstrate adherence to
program guidance.




Page 9                                                                      GAO-12-526T
FEMA has a much clearer understanding of what is being requested and
what is being funded by these programs.

FEMA has studied the potential utilization of more specific project-level
data for making grant award decisions, especially for the State Homeland
Security Program and Urban Areas Security Initiative. 20 However, while
our analysis of selected grant projects determined that this additional
information was sufficient for identifying potentially unnecessary
duplication for nearly all of the projects it reviewed, the information did not
always provide FEMA with sufficient detail to identify and prevent the risk
of unnecessary duplication. While utilizing more specific project-level data
would be a step in the right direction, at the time of our February 2012
report, FEMA had not determined the specifics of future data
requirements.

FEMA lacked a process to coordinate application reviews across the
four grant programs. In February 2012, we reported that grant
applications were reviewed separately by program and were not
compared across each other to determine where possible unnecessary
duplication may occur. Specifically, FEMA’s Homeland Security Grant
Program branch administered the Urban Areas Security Initiative and
State Homeland Security Program while the Transportation Infrastructure
Security branch administered the Port Security Grant Program and
Transit Security Grant Program. We and the DHS Inspector General
concluded that coordinating the review of grant projects internally would
give FEMA more complete information about applications across the four
grant programs, which could help FEMA identify and mitigate the risk of
unnecessary duplication across grant applications. 21

In our February 2012 report, we note that one of FEMA’s section chiefs
said that the primary reasons for the current lack of coordination across



20
  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 regarding future data collection policies. FEMA utilized the
working group’s analysis and recommendations in a May 2011 Report to Congress.
21
   GAO, More Efficient and Effective Government: Opportunities to Reduce Duplication,
Overlap and Fragmentation, Achieve Savings, and Enhance Revenue GAO-12-449T
(Washington, D.C.; Feb 28, 2012); and Department of Homeland Security Office of
Inspector General, Efficiency of DHS Grant Programs, OIG-1069 (Washington, D.C.: Mar.
22, 2010).




Page 10                                                                          GAO-12-526T
                        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.

                        Thus, we recommended that FEMA take actions to identify and mitigate
                        any unnecessary duplication in these programs, such as collecting more
                        complete project information as well as exploring opportunities to
                        enhance FEMA’s internal coordination and administration of the
                        programs. In commenting on the report, DHS agreed and identified
                        planned actions to improve visibility and coordination across programs
                        and projects. We also suggested that Congress consider requiring DHS
                        to report on the results of its efforts to identify and prevent duplication
                        within and across the four grant programs, and consider these results
                        when making future funding decisions for these programs.


FEMA Has Proposed       In the President’s Fiscal Year 2013 budget request to Congress, FEMA
Changes to Enhance      has proposed consolidating its various preparedness grant programs—
Preparedness Grant      with the exception of the Emergency Management Performance Grants
                        and Assistance to Fire Fighters Grants—into a single, comprehensive
Management, but these   preparedness grant program called the National Preparedness Grant
Changes May Create      Program (NPGP) in fiscal year 2013. FEMA also plans to enhance its
Challenges              preparedness grants management through a variety of proposed
                        initiatives to implement the new consolidated program.

                        According to FEMA, the new NPGP will require grantees to develop and
                        sustain core capabilities outlined in the National Preparedness Goal
                        rather than work to meet mandates within individual, and often
                        disconnected, grant programs. 22 NPGP is intended to focus on creating a
                        robust national response capacity based on cross-jurisdictional and



                        22
                          U.S. Department of Homeland Security, National Preparedness Goal, (Washington,
                        D.C., Sept. 2011.)




                        Page 11                                                                 GAO-12-526T
readily deployable state and local assets. According to FEMA’s policy
announcement, consolidating the preparedness grant programs will
support the recommendations of the Redundancy Elimination and
Enhanced Performance for Preparedness Grants Act, and will streamline
the grant application process. This will, in turn, enable grantees to focus
on how federal funds can add value to their jurisdiction’s unique
preparedness needs while contributing to national response capabilities.
To further increase the efficiency of the new grant program, FEMA plans
to issue multi-year guidelines, enabling the agency to focus its efforts on
measuring progress towards building and sustaining national capabilities.
The intent of this consolidation is to eliminate administration redundancies
and ensure that all preparedness grants are contributing to the National
Preparedness Goal. For fiscal year 2013, FEMA believes that the
reorganization of preparedness grants will allow for a more targeted
grants approach where states build upon the capabilities established with
previous grant money and has requested $1.54 billion for the National
Preparedness Grant Program.

FEMA’s Fiscal Year 2013 Grants Drawdown Budget in Brief also
proposes additional measures to enhance preparedness grant
management efforts and expedite prior years’ grant expenditures. For
example, to support reprioritization of unobligated prior year funds and
focus on building core capabilities, FEMA plans to:

•   allow grantees to apply prior years’ grant balances towards more
    urgent priorities, promising an expedited project approval by FEMA’s
    Grant Programs Directorate;
•   expand allowable expenses under the Port Security Grant Program
    and Transit Security Grant Program, for example, by allowing
    maintenance and sustainment expenses for equipment, training, and
    critical resources that have previously been purchased with either
    federal grants or any other source of funding to support existing core
    capabilities tied to the five mission areas contained within the National
    Preparedness Goal.

The changes FEMA has proposed for its fiscal year 2013 National
Preparedness Grants program may create new management challenges.
As noted by Chairman Bilirakis in last month’s hearing by the House
Homeland Security Committee’s Subcommittee on Emergency
Preparedness, Response, and Communications, allocations under the




Page 12                                                           GAO-12-526T
new grant program would rely heavily on a state’s Threat and Hazard
Identification and Risk Assessment (THIRA). 23 However, nearly a year
after the THIRA concept was first introduced as part of the fiscal year
2011 grant guidance, grantees have yet to receive guidance on how to
conduct the THIRA process. As we reported in February 2012, questions
also remain as to how local stakeholders would be involved in the THIRA
process at the state level. In March 2012, FEMA’s GPD announced that
FEMA has established a website to solicit input from stakeholders on how
best to implement the new program. According to Chairman Bilirakis, it is
essential that the local law enforcement, first responders, and emergency
managers who are first on the scene of a terrorist attack, natural disaster,
or other emergency be involved in the THIRA process. They know the
threats to their local areas and the capabilities needed to address them.
Finally, according to FEMA’s plans, the new National Preparedness Grant
Program will require grantees to develop and sustain core capabilities;
however, the framework for assessing capabilities and prioritizing national
preparedness grant investments is still not complete. As we noted in our
February 2012 report, 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. 24




23
   Threat and Hazard Identification and Risk Assessments (THIRA) are intended to be
tools that allow organizations at all levels of government to identify, assess, and prioritize
their natural and man-made risks to facilitate the identification of capability and resource
gaps, and allow organizations to track their year-to-year progress to address those gaps.
24
  GAO-12-303




Page 13                                                                           GAO-12-526T
                          DHS and FEMA have had difficulty in implementing longstanding plans to
FEMA Has Not Yet          develop and implement a system for assessing national preparedness
Completed National        capabilities. For example, DHS first developed plans in 2004 to measure
                          preparedness by assessing capabilities, 25 but these efforts have been
Preparedness              repeatedly delayed and are not yet complete. FEMA’s proposed revisions
Assessment Efforts to     to the new NPGP may help the agency overcome these continuing
Address Longstanding      challenges to developing and implementing a national preparedness
                          assessment.
Concerns
DHS and FEMA’s            Since 2004, DHS and FEMA have initiated a variety of efforts to develop
Longstanding Plans to     a system of measuring preparedness. From 2005 until September 2011,
Develop and Implement a   much of FEMA’s efforts focused on developing and operationalizing a list
                          of target capabilities that would define desired capabilities and could be
National Assessment of    used in a tiered framework to measure their attainment. In July 2005, we
Preparedness Have Not     reported that DHS had established a draft Target Capabilities List that
Been Fulfilled            provides guidance on the specific capabilities and levels of capability at
                          various levels of government that FEMA would expect federal, state,
                          local, and tribal first responders to develop and maintain. 26 DHS planned
                          to organize classes of jurisdictions that share similar characteristics—
                          such as total population, population density, and critical infrastructure—
                          into tiers to account for reasonable differences in capability levels among
                          groups of jurisdictions and to appropriately apportion responsibility for
                          development and maintenance of capabilities among levels of
                          government and across these jurisdictional tiers. According to DHS’s
                          Assessment and Reporting Implementation Plan, DHS intended to
                          implement a capability assessment and reporting system based on target
                          capabilities that would allow first responders to assess their preparedness
                          by identifying gaps, excesses, or deficiencies in their existing capabilities
                          or capabilities they will be expected to access through mutual aid. In
                          addition, this information could be used to (1) measure the readiness of
                          federal civil response assets, (2) measure the use of federal assistance at
                          the state and local levels, and (3) assess how federal assistance
                          programs are supporting national preparedness.


                          25
                            GAO, Homeland Security: Management of First Responder Grants in the National
                          Capital Region Reflects the Need for Coordinated Planning and Performance Goals,
                          GAO-04-433 (Washington, D.C.: May 28, 2004).
                          26
                             An example of a desired outcome for the target capability of mass prophylaxis—
                          prevention of or protective treatment for disease—was to effectively reach an entire
                          affected population in time to prevent loss of life and injury. GAO-05-852.




                          Page 14                                                                       GAO-12-526T
DHS’s efforts to implement these plans were interrupted by the 2005
hurricane season. In August 2005, Hurricane Katrina—the worst natural
disaster in our nation’s history—made final landfall in coastal Louisiana
and Mississippi, and its destructive force extended to the western
Alabama coast. Hurricane Katrina and the following Hurricanes Rita and
Wilma—also among the most powerful hurricanes in the nation’s
history—graphically illustrated the limitations at that time of the nation’s
readiness and ability to respond effectively to a catastrophic disaster; that
is, a disaster whose effects almost immediately overwhelm the response
capabilities of affected state and local first responders and require outside
action and support from the federal government and other entities. In
June 2006, DHS concluded that target capabilities and associated
performance measures should serve as the common reference system
for preparedness planning.

In September 2006, we reported that numerous reports and our work
suggested that the substantial resources and capabilities marshaled by
federal, state, and local governments and nongovernmental organizations
were insufficient to meet the immediate challenges posed by the
unprecedented degree of damage and the resulting number of hurricane
victims caused by Hurricanes Katrina and Rita. 27 We also reported that
developing the capabilities needed for catastrophic disasters should be
part of an overall national preparedness effort that is designed to
integrate and define what needs to be done, where it needs to be done,
how it should be done, how well it should be done, and based on what
standards. 28

FEMA’s National Preparedness Directorate within its Protection and
National Preparedness organization was established in April 2007 and is
responsible for developing and implementing a system for measuring and
assessing national preparedness capabilities. Figure 2 provides an
illustration of how federal, state, and local resources provide capabilities
for different levels of “incident effect” (i.e., the extent of damage caused
by a natural or manmade disaster).




27
  GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and Accountability
Controls Will Improve the Effectiveness of the Nation’s Preparedness, Response, and
Recovery System, GAO-06-618 (Washington, D.C., Sept. 6, 2006.)
28
     GAO-06-618.




Page 15                                                                   GAO-12-526T
Figure 2: Conceptual Illustration for Assessing Capability Requirements and
Identifying Capability Gaps for National Preparedness:




In October 2006, Congress passed the Post-Katrina Act that required
FEMA, in developing guidelines to define target capabilities, to ensure
that such guidelines are specific, flexible, and measurable. 29 In addition,
the Post-Katrina Act calls for FEMA to ensure that each component of the
national preparedness system, which includes the target capabilities, is
developed, revised, and updated with clear and quantifiable performance
metrics, measures, and outcomes. 30 We recommended in September
2006, among other things, that DHS apply an all-hazards, risk
management approach in deciding whether and how to invest in specific
capabilities for a catastrophic disaster. 31 DHS concurred with this




29
     6 U.S.C. § 746.
30
     6 U.S.C. § 749(b).
31
     GAO-06-618.




Page 16                                                                GAO-12-526T
recommendation and FEMA said it planned to use the Target Capabilities
List to assess capabilities to address all hazards.

In September 2007, FEMA issued an updated version of the Target
Capabilities List to provide a common perspective in conducting
assessments that determine levels of readiness to perform critical tasks
and identify and address any gaps or deficiencies. According to FEMA,
policymakers need regular reports on the status of capabilities for which
they have responsibility to help them make better resource and
investment decisions and to establish priorities.

In April 2009, we reported that establishing quantifiable metrics for target
capabilities was a prerequisite to developing assessment data that can be
compared across all levels of government. 32 At the time of our review,
FEMA was in the process of refining the target capabilities to make them
more measurable and to provide state and local jurisdictions with
additional guidance on the levels of capability they need. Specifically,
FEMA planned to develop quantifiable metrics—or performance
objectives—for each of the 37 target capabilities that are to outline
specific capability targets that jurisdictions (such as cities) of varying size
should strive to meet, recognizing that there is not a “one size fits all”
approach to preparedness.

In October 2009, in responding to congressional questions regarding
FEMA’s plan and timeline for reviewing and revising the 37 target
capabilities, FEMA officials said they planned to conduct extensive
coordination through stakeholder workshops in all 10 FEMA regions and
with all federal agencies with lead and supporting responsibility for
emergency support-function activities associated with each of the 37
target capabilities. The workshops were intended to define the risk
factors, critical target outcomes, and resource elements for each
capability. The response stated that FEMA planned to create a Task
Force comprised of federal, state, local, and tribal stakeholders to
examine all aspects of preparedness grants, including benchmarking
efforts such as the Target Capabilities List. FEMA officials have described
their goals for updating the list to include establishing measurable target
outcomes, providing an objective means to justify investments and
priorities, and promoting mutual aid and resource sharing.



32
     GAO-09-369.




Page 17                                                             GAO-12-526T
                          In November 2009, FEMA issued a Target Capabilities List
                          Implementation Guide that described the function of the list as a planning
                          tool and not a set of standards or requirements. Finally, in 2011, FEMA
                          announced that the Target Capabilities List would be replaced by a new
                          set of national Core Capabilities. However, it is not clear how the new
                          approach will help FEMA overcome ongoing challenges to assessing
                          national preparedness capabilities discussed below.


FEMA Has Not Yet Fully    FEMA has not yet fully addressed ongoing challenges in developing and
Addressed Ongoing         implementing a system for assessing national preparedness capabilities.
Challenges to Assessing   For example, we reported in July 2005 that DHS had identified potential
                          challenges in gathering the information needed to assess capabilities,
National Preparedness     including determining how to aggregate data from federal, state, local,
Capabilities              and tribal governments and others and integrating self-assessment and
                          external assessment approaches. 33 In analyzing FEMA’s efforts to assess
                          capabilities, we further reported in April 2009 that FEMA faced
                          methodological challenges with regard to (1) differences in data available,
                          (2) variations in reporting structures across states, and (3) variations in
                          the level of detail within data sources requiring subjective interpretation.
                          As noted above, FEMA was in the process of refining the target
                          capabilities at the time of our review to make them more measurable and
                          to provide state and local jurisdictions with additional guidance on the
                          levels of capability they need. We recommended that FEMA enhance its
                          project management plan to include milestone dates, among other things,
                          a recommendation to which DHS concurred. In October 2010, we
                          reported that FEMA had enhanced its project management plan by
                          providing milestone dates and identifying key assessment points
                          throughout the project to determine whether project changes are
                          necessary. 34

                          Nonetheless, DHS and FEMA have had difficulty overcoming the
                          challenges we reported in July 2005 and April 2009 in establishing a
                          system of metrics to assess national preparedness capabilities. 35 As we
                          reported in October 2010, FEMA officials said that, generally, evaluation



                          33
                               GAO-05-652.
                          34
                               GAO-11-51R.
                          35
                               GAO-05-652 and GAO-09-369.




                          Page 18                                                          GAO-12-526T
efforts they used to collect data on national preparedness capabilities
were useful for their respective purposes but that the data collected were
limited by data reliability and measurement issues related to the lack of
standardization in the collection of data.

FEMA officials reported that one of its evaluation efforts, the State
Preparedness Report, has enabled FEMA to gather data on the progress,
capabilities, and accomplishments of the preparedness program of a
state, the District of Columbia, or a territory. However, they also said that
these reports included self-reported data that may be subject to
interpretation by the reporting organizations in each state and not be
readily comparable to other states’ data. The officials also stated that they
have taken actions to address these limitations by, for example, creating
a Web-based survey tool to provide a more standardized way of
collecting state preparedness information that will help FEMA officials
validate the information by comparing it across states.

We reported in October 2010 that FEMA had an ongoing effort to develop
measures for target capabilities that would serve as planning guidance,
not requirements, to assist in state and local capability assessments.
FEMA officials had not yet determined how they planned to revise the
Target Capabilities List and said they were awaiting the completed
revision of Homeland Security Presidential Directive 8, which was to
address national preparedness. That directive, called Presidential Policy
Directive 8 on National Preparedness (PPD-8), was issued on March 30,
2011.

In March 2011, we reported that FEMA’s efforts to develop and
implement a comprehensive, measurable, national preparedness
assessment of capability and gaps were not yet complete and suggested
that Congress consider limiting preparedness grant funding until FEMA
completes a national preparedness assessment of capability gaps at
each level based on tiered, capability-specific performance objectives to
enable prioritization of grant funding. 36 In April 2011, Congress passed
the fiscal year 2011 appropriations act for DHS, which reduced funding
for FEMA preparedness grants by $875 million from the amount
requested in the President’s fiscal year 2011 budget. 37 The consolidated


36
     GAO-11-318SP.
37
     Pub. L. No. 112-10, § 1632, 125 Stat. 38, 143 (2011).




Page 19                                                           GAO-12-526T
appropriations act for fiscal year 2012 appropriated $1.7 billion for FEMA
Preparedness grants, $1.28 billion less than requested. 38 The House
committee report accompanying the DHS appropriations bill for fiscal year
2012 stated that FEMA could not demonstrate how the use of the grants
had enhanced disaster preparedness. 39

According to FEMA’s testimony in a hearing on the President’s Fiscal
Year 2013 budget request before the House Committee on Homeland
Security’s Subcommittee on Emergency Preparedness, Response, and
Communications, FEMA became the federal lead for the implementation
of PPD-8 in 2011. The new presidential policy directive calls for the
development of both a National Preparedness Goal and a National
Preparedness System (both of which were required by the Post-Katrina
Act in 2006). FEMA issued the National Preparedness Goal in September
2011, which establishes core capabilities for prevention, protection,
response, recovery, and mitigation that are to serve as the basis for
preparedness activities within FEMA, throughout the federal government,
and at the state and local levels. These new core capabilities are the
latest evolution of the Target Capabilities List. According to FEMA
officials, they plan to continue to organize the implementation of the
National Preparedness System and will be working with partners across
the emergency management community to integrate activities into a
comprehensive campaign to build and sustain preparedness. According
to FEMA, many of the programs and processes that support the
components of the National Preparedness System exist and are currently
in use, while others will need to be updated or developed.

For example, FEMA has not yet developed national preparedness
capability requirements based on established metrics for the core
capabilities to provide a framework for national preparedness
assessments. As I testified last year, until such a framework is in place,
FEMA will not have a basis to operationalize and implement its
conceptual approach for assessing federal, state, and local preparedness




38
   Pub. L. No. 112–74, 125 Stat. 786, 960 (2011). This total includes all grant programs in
the state and local programs account and the Emergency Management Performance
Grant program but does not include funding appropriated for firefighter assistance grant
programs.
39
     H.R. Rep. No. 112-91, at 106-08 (2011).




Page 20                                                                       GAO-12-526T
                     capabilities against capability requirements to identify capability gaps for
                     prioritizing investments in national preparedness.


                     Chairman Bilirakis, Ranking Member Richardson, and Members of the
                     Committee, this completes my prepared statement. I would be pleased to
                     respond to any questions that you may have at this time.


                     For further information about this statement, please contact William O.
Contacts and Staff   Jenkins Jr., Director, Homeland Security and Justice Issues, at (202) 512-
Acknowledgments      8777 or jenkinswo@gao.gov. Contact points for our Offices of
                     Congressional Relations and Public Affairs may be found on the last page
                     of this statement. In addition to the contact named above, the following
                     individuals from GAO’s Homeland Security and Justice Team also made
                     major contributions to this testimony: Chris Keisling, Assistant Director;
                     Allyson Goldstein, Dan Klabunde, Tracey King, and Lara Miklozek.




(441061)
                     Page 21                                                            GAO-12-526T
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