Department of Health and Human Services 
OFFICE OF 
 
  INSPECTOR GENERAL 
 
 
 
 
 
 
S S B
UPERSTORM  ANDY  LOCK 
 
 
G   : F B
RANTS    UNDS  ENEFITED 
 
S  R
TAT ES   ECONSTRUCTION AND 
 
S S E ,
O CIAL  ERVICE  FFORTS  
T ACF G
HOUGH  S  UIDANCE 
C I  
OULD BE  MPROVED
 
Suzanne Murrin 
Deputy Inspector General for 
Evaluation and Inspections 
 
September 2016 
OEI-09-15-00200   
   
EXECUTIVE SUMMARY:  SUPERSTORM SANDY BLOCK GRANTS:  FUNDS 
BENEFITED STATES RECONSTRUCTION AND SOCIAL SERVICE EFFORTS, 
THOUGH ACFS GUIDANCE COULD BE IMPROVED, OEI-09-15-00200  
 
WHY WE DID THIS STUDY  
Five States received almost $475 million in Social Services Block Grant funding to help cover 
social service and reconstruction expenses resulting directly from Superstorm Sandy.  When 
Congress made funds available to States to help pay for their Superstorm Sandy-related 
expenses, it noted that such funds were susceptible to significant improper payments.  
Therefore, the Office of Management and Budget instructed Federal agencies to establish 
additional oversight of the funds.  This evaluation examined States experiences using 
Superstorm Sandy Social Service Block Grant (Sandy SSBG) funds and Administration for 
Children and Families (ACF) oversight of these funds.     
 
HOW WE DID THIS STUDY 
We conducted interviews with, and reviewed documentation from ACF, the five States affected 
by Superstorm Sandy, and selected organizations that received Superstorm Sandy SSBG funds 
(sub-recipients).  Our review covers States activities and ACFs oversight from July 1, 2013, 
when almost all Sandy SSBG funds were disbursed to States, through September 30, 2015. 
 
WHAT WE FOUND 
Sandy SSBG funds assisted States recoveries by supporting reconstruction and social service 
activities.  However, ACFs guidance limited the effectiveness of State planning and use of the 
funds and, therefore, could be improved for future disasters.  As with past natural disasters, 
supplemental disaster funding was important in helping States meet both immediate and longer-
term needs.  The five SSBG-recipient States spent most of the funds on housing services and 
health services; the repair, renovation, and rebuilding of health facilities; and counseling 
services.  Despite some delays, generally the funds were available to States when needed.  
Further, the grants terms were flexible enough for States to use the funds for a variety of storm-
related activities and to modify their plans as needed.  However, the initial deadline that ACF 
established did not allow States the time they needed to use the Sandy SSBG funds for 
reconstruction and other longer-term needs.  Also, States reported wanting more direction from 
ACF on allowable Sandy SSBG activities and more clarity about the type of documentation that 
ACF would expect during program integrity reviews.  Nonetheless, States indicated that ACF 
worked closely with them as they planned and implemented their recovery activities.  In 
addition, ACF implemented required reviews to account for Sandy SSBG funds and identify 
improper payments.    
 
WHAT WE RECOMMEND  
We recommend that ACF (1) take additional steps to ensure, within the scope of the legislation, 
that States are given an appropriate amount of time to expend any future supplemental SSBG 
awards (2) conduct a post-grant review to identify lessons learned and best practices and  
(3) prepare guidance about supplemental SSBG documentation requirements.  ACF concurred 
with all of our recommendations.      
   
TABLE OF CONTENTS 
 
Objectives ....................................................................................................1 
Background ..................................................................................................1 
Methodology ................................................................................................5 
Findings........................................................................................................7 
Sandy SSBG funds assisted States immediate and longer-term 
recovery............................................................................................7 
The initial deadline that ACF established for expending Sandy  
SSBG funds did not allow States the time they needed to use  
the funds ...........................................................................................9 
States reported wanting more direction from ACF on  
allowable Sandy SSBG activities and documentation 
requirements ...................................................................................10 
ACF implemented required reviews to account for Sandy  
SSBG funds and identify improper payments ............................... 11 
Conclusion and Recommendations ............................................................15 
Agency Comments and Office of Inspector General Response .....17 
Appendix A:  State-specific Sandy SSBG Expenditures by Service 
Category, Through September 2015. .........................................................18 
Appendix B:  State Agencies that Participated in OIG Interviews ............19 
Appendix C:  Agency Comments ..............................................................20 
Acknowledgments......................................................................................23 
   
   
OBJECTIVES 
To examine:  
(1) States experiences using Superstorm Sandy Supplemental Social 
Services Block Grant (SSBG) funds, and   
(2) The Administration for Children and Families (ACF) oversight of 
Superstorm Sandy Supplemental SSBG funds. 
BACKGROUND  
Supplemental SSBG funds have been important in helping States address 
their social service and reconstruction expenses following recent natural 
disasters.1  For example, in 2005, Congress authorized $550 million in 
supplemental SSBG funds to ACF for States expenses related to 
Hurricanes Katrina, Rita, and Wilma.2  In 2008, Congress authorized  
$600 million in supplemental SSBG funds to help States respond to 
hurricanes, floods, and other declared major disasters.3   
Superstorm Sandy made landfall on October 29, 2012, causing more than 
$50 billion in damages to coastal portions of the mid-Atlantic and 
northeastern United States.4  On January 29, 2013, the President signed 
into law the Disaster Relief Appropriations Act of 2013 (the Act), which 
provided the Department of Health and Human Services (HHS) with about 
$800 million in funding to aid individuals and communities affected by 
Superstorm Sandy.5  Of the $800 million, $500 million was transferred to 
ACF as supplemental SSBG funding.  Automatic spending cuts imposed 
by the Budget Control Act of 2011 reduced this amount to  
____________________________________________________________ 
1 This report focuses specifically on supplemental SSBG funds.  More broadly, SSBG 
funds, authorized in 1981, are a flexible source of annual funding that States use to meet 
their social service needs.  42 U.S.C 1397-1397f.     
2 Department of Defense, Emergency Supplemental Appropriations to Address 
Hurricanes in the Gulf of Mexico, and Pandemic Influenza Act of 2006.  P.L. 109-148.  
Dec. 30, 2005, Chapter 6. 
3 Consolidated Security Disaster Assistance, and Continuing Appropriations Act if 2009. 
P. L. No. 110-329.  Sept. 30, 2008, Chapter 7. 
4 National Oceanic and Atmospheric Administration, Service Assessment:  
Hurricane/Post-Tropical Cyclone Sandy, October 2229, 2012, pg. 1, May 2013. 
Accessed at http://www.nws.noaa.gov/os/assessments/pdfs/Sandy13.pdf on  
May 20, 2016. 
5 P. L. No. 113-2, January 29, 2013. 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  1 
     
   
   
$474.5 million.6  Because all Superstorm Sandy disaster assistance funds 
were designated as susceptible to significant improper payments, the 
Office of Management and Budget required Federal agencies to establish 
additional oversight of these funds.7   
Supplemental SSBG Funds for Superstorm Sandy 
New York and New Jersey, the States most affected by Superstorm Sandy, 
together received about 97 percent of the Sandy SSBG funds.  HHS 
allocated these funds based on States relative share of individuals 
registered for Federal Emergency Management Agency (FEMA) 
Individual Assistance as of March 18, 2013.8  Connecticut, Maryland, and 
Rhode Island also received Sandy SSBG funds.   
Table 1 illustrates the Sandy SSBG funds allocated to each of the five 
States.  ACF, which administers and provides oversight of the SSBG 
program, disbursed almost all Sandy SSBG funds to States by  
July 22, 2013.9 
Table 1:  Sandy SSBG Funds Allocated to the Five States 
 
State Share of Sandy 
State  Award Amount 
SSBG Funds 
New York  $235,434,600  49.6% 
New Jersey  $226,794,105  47.8% 
Connecticut  $10,569,192  2.2% 
Maryland  $1,185,675  0.3% 
Rhode Island  $516,428  0.1% 
Total  $474,500,000  100% 
 
Source:  ACF, Supplemental Funds, Information Memorandum No. 01-2013, March 28, 2013.  
The Act authorized Sandy SSBG funds for States to address their 
necessary expenses resulting from Superstorm Sandy.  States were 
allowed to use Sandy SSBG funds in 28 broad service categories, such as 
____________________________________________________________ 
6 The Act provided about $50 billon in disaster assistance through 19 Federal agencies.  
P. L. No. 113-2, January 29, 2013.  Government Accountability Office, Improved 
Guidance on Designing Internal Control Plans Could Enhance Oversight of Disaster 
Funding, November 2013, GAO-14-58, pg. 1 & 28-32. 
7 P. L. No. 113-2, Section 904(b). 
8 ACF Information Memorandum, Transmittal No. 01-2013, Hurricane Sandy SSBG 
Supplemental Funds, March 28, 2013, pg. 2.   
9 ACFs responses to questions submitted by the Office of Inspector General (OIG).   
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  2 
     
   
   
case management, employment services, and housing services.10, 11  See the 
table in Appendix A for a complete list of allowable service categories.   
Prior to awarding Sandy SSBG funds to States, ACF required the States to 
submit SSBG supplemental funds pre-expenditure reports (Intended Use 
Plans) that described how they proposed to use the funds and their 
timelines for completing proposed activities.12  As shown in Figure 1, once 
ACF approved their Intended Use Plans, States could identify and approve 
grants to sub-recipients (e.g., individuals, families, or organizations).  
States then reimbursed approved sub-recipients for their Sandy-related 
expenses using Sandy SSBG funds.13    
Figure 1:  Sandy SSBG Funding Process 
Reimbursing Expenses
Planning Activities Approving Grants
States reimburse 
ACF approves States'  States approve grants 
sub-recipients, such as 
Intended Use Plans and  to sub-recipients, such 
individuals, families, 
disburses funding as individuals, families, 
and organizations, for 
and organizations  
their expenses
 
Source:  OIG summary based on interviews with and documents collected from ACF and State officials.
While Sandy SSBG funds could be used flexibly, they came with certain 
restrictions.  Under the Act, States could not use Sandy SSBG funds for 
expenses that were reimbursed by other payers such as FEMA or private 
insurance.14  Further, States could not use the Sandy SSBG funds to 
purchase supplies and/or equipment that will aid in future disasters, 
because the Sandy SSBG funds were intended to address necessary 
expenses resulting from Superstorm Sandy.15  Finally, States had a 
____________________________________________________________ 
10 ACF, Hurricane Sandy Expenditure Form, OMB NO. 0970-0234, Accessed at 
http://www.acf.hhs.gov/sites/default/files/ocs/hurricane_sandy_expenditure_form.pdf on 
January 22, 2016. 
11 States also could provide services that fell outside of the 28 defined categories and 
report these in Other categories such as health services, repair, renovation, and 
rebuilding of child care facilities, and repair, renovation, and rebuilding of health care 
facilities. 
12 ACF Information Memorandum, Transmittal No. 01-2013, Hurricane Sandy SSBG 
Supplemental Funds, March 28, 2013, p. 4.   
13 OIG interviews with officials from ACF and the five States affected by Sandy. 
14 P.L. No. 113-2, Title VIDepartment of Health and Human Services, Jan. 29, 2013. 
15 SSBG Q&As Hurricane Sandy Supplemental FY 2013, III.  Allowable Costs, 
April 13, 2013.  Accessed at http://www.acf.hhs.gov/programs/ocs/resource/ssbg-qas-
2013-sandy-supplemental on January 22, 2016. 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  3 
     
   
   
deadline for expending their funds.16  Initially, ACF instructed States to 
expend Sandy SSBG funds by September 30, 2015, but ACF later 
extended the deadline to September 30, 2017.17, 18     
The Office of Management and Budget (OMB) required Federal agencies, 
such as ACF, to ensure that all Superstorm Sandy disaster funds 
appropriated under the Act were used only for their intended purposes.19  
The OMB memorandum instructed each Federal agency to supplement its 
existing internal control plan by considering elements including  
(1) implementing more expansive reviews and increased monitoring and 
oversight of grantees and (2) calculating an improper payment rate for the 
funds.  In March 2013, ACF issued guidance that contained its oversight 
plans, as well as other information.  These plans included pre-expenditure, 
post-expenditure, and progress reporting requirements for States and 
program integrity reviews by ACF.20  
Related Work 
This evaluation builds on OIGs body of work related to Superstorm 
Sandy.  Most relevant to this report, in July 2014, OIG found that HHS 
(Department-wide) included elements specified by OMB when it designed 
its internal controls for overseeing Superstorm Sandy disaster funds.21  
OIG also has released a series of audits at the grantee level, examining 
how grantees and sub-recipients accounted for and expended the 
____________________________________________________________ 
16 P.L. No. 113-2, Jan. 29, 2013.  Section 904(c). 
17 ACF Information Memorandum, Transmittal No. 01-2013, Hurricane Sandy SSBG 
Supplemental Funds, March 28, 2013, p. 6.   
18 ACF, Information Memorandum, Transmittal No. 1-2015, Revision of Project Period 
and Reporting of Hurricane Sandy SSBG Supplemental Funds Expenditures and 
Recipients and Closeout Requirements, June 12, 2015, p. 1.  
19 OMB, Memorandum for the Heads of Executive Departments and Agencies, 
Accountability for Funds Provided by the Disaster Relief Appropriations Act, M-13-07, 
March 12, 2013.   
20 ACF Information Memorandum, Transmittal No. 01-2013, Hurricane Sandy SSBG 
Supplemental Funds, March 28, 2013.   
21 OIG, The Department of Health and Human Services Designed Its Internal Controls 
Over Hurricane Sandy Disaster Relief Funds To Include Elements Specified by the 
Office of Management and Budget, A-02-13-02010, July 2014.   
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  4 
     
   
   
Superstorm Sandy disaster assistance funds.22, 23, 24, 25  In its March 2016 
audit, OIG found that one grantee claimed almost $60,000 in unallowable 
costs.  However, in other audits, OIG found that grantees appropriately 
budgeted and claimed disaster assistance funds.  Other reports issued by 
OIG include examinations of the responses of hospitals and child care 
providers after Superstorm Sandy, issued in 2014 and 2015,  
respectively.26, 27 
METHODOLOGY 
Data Collection and Analysis 
Between July and November 2015, we collected information from ACF, 
the five States that received Sandy SSBG funds, and selected sub-
recipients.  We report on States activities and ACFs oversight through 
September 2015.    
States experiences using funds.  To examine States experiences using 
Sandy SSBG funds, we interviewed and collected documentation from 
ACF staff and officials from the five States that received Sandy SSBG 
funds.  See Appendix B for the list of State agencies whose officials 
participated in our interviews.  From ACF, we collected States initial and 
amended Intended Use Plans, post-expenditure reports, and progress 
reports and analyzed this information to determine how States used their 
Sandy SSBG funds.  We conducted onsite visits to New York and  
New Jersey and held conference calls with officials from Connecticut, 
Maryland, and Rhode Island to collect information about how they 
developed their Intended Use Plans and distributed funds to affected 
____________________________________________________________ 
22 OIG, New York University School of Medicine Budgeted Costs That Were 
Appropriate and Claimed Allowable Hurricane Sandy Disaster Relief Act Funds,  
A-02-14-02011, December 2015. 
23 OIG, Link2Health Solutions, Inc., Budgeted Costs That Were Not Appropriate and 
Claimed Some Unallowable Hurricane Sandy Disaster Relief Act Funds, A-02-14-02013, 
March 2016. 
24 OIG, Bayview Nursing and Rehabilitation Center Claimed Allowable Hurricane Sandy 
Disaster Relief Act Funds, A-02-15-02010, April 2016. 
25 OIG, New York Implemented Effective Internal Controls Over Hurricane Sandy Social 
Services Block Grant Funds and Appropriately Budgeted and Claimed Allowable Costs, 
A-02-14-02009, May 2016. 
26 OIG, Hospital Emergency Preparedness and Response During Superstorm Sandy,  
OEI-06-13-00260, September 2014.   
27 OIG, The Response to Superstorm Sandy Highlights the Importance of Recovery 
Planning for Child Care Nationwide, OEI-04-14-00410, December 2015. 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  5 
     
   
   
individuals.  We also collected information about the challenges that States 
experienced using and accounting for their funds.   
While onsite in New York and New Jersey, we visited a purposive sample 
of nine sub-recipients (four sub-recipients in New York and five in New 
Jersey) to discuss their use of Sandy SSBG funds.28  For our sample 
selection, we focused on sub-recipients that received or provided services 
representing the largest Sandy SSBG expenditures in each State.  We used 
the information and documentation collected during these visits to 
describe sub-recipients experiences using and accounting for Sandy 
SSBG funds.   
ACFs oversight of Sandy SSBG funds.  To examine ACFs oversight, we 
interviewed and collected documentation from ACF staff about their 
review and monitoring of Sandy SSBG funds.  We conducted structured 
interviews with staff from ACF and its contractors to determine the type of 
reviews they conducted for Sandy SSBG funds.  We also collected reports 
and other documents describing the results of ACFs State and sub-
recipient reviews.  We reviewed these reports to examine the extent to 
which ACF identified improper uses of Sandy SSBG funds and how it 
responded to these findings.  
Limitations 
Because we collected information from a purposive sample of sub-
recipients in New Jersey and New York, the experiences of sub-recipients 
are not representative of all sub-recipients that received Sandy SSBG 
funds.  Also, although we examined the nature and extent of ACFs 
oversight activities, we did not assess the effectiveness of those activities 
or the accuracy of ACFs calculated error rate.   
Standards 
This study was conducted in accordance with the Quality Standards for 
Inspection and Evaluation issued by the Council of the Inspectors General 
on Integrity and Efficiency.    
____________________________________________________________ 
28 New York and New Jersey each provided OIG a list of Sandy SSBG sub-recipients as 
of March 2015.  We selected our sample of sub-recipients from the 479 New York and 
250 New Jersey Sandy SSBG sub-recipients included on those lists. 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  6 
     
   
   
FINDINGS  
Sandy SSBG funds assisted States immediate and 
longer-term recovery  
Overall, State officials reported that they were able to use Sandy SSBG 
funds to address their priority disaster-related expenses.  ACF approved 
most of their proposed activities and made the funds available when needed.  
Further, State officials indicated that the flexible terms of Sandy SSBG 
grants helped them coordinate disaster assistance from multiple sources.  
States used Sandy SSBG funds to supplement other funding that, in some 
cases, came with more restrictions.  
By September 2015, the time of our review, States had expended two-thirds 
($316 million of $475 million) of the Sandy SSBG funds available to them.  
As a group, States spent most of the funds on housing services, health 
services; the repair, renovation, and rebuilding of health facilities; and 
counseling services.  Table 2 highlights some of the activities that States 
completed using Sandy SSBG funds.  During this time period, all five States 
used at least some of their Sandy SSBG funds for housing and case 
management services.  (See Appendix A for State-specific expenditure 
amounts by service type).   
Superstorm Sandy Damage Sandy SSBG Funded-Renovation
Source:  Sandy SSBG sub-recipient.  Used With Permission.   
 
Officials from New York and New Jersey, the States most affected by the 
storm, reported the greatest variety of uses for Sandy SSBG funds.  Each 
used Sandy SSBG funds in at least half of the 28 main service categories.  
Unlike the other three States, New York and New Jersey used Sandy SSBG 
funds to provide family violence prevention and intervention services, 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  7 
     
   
   
education and training, and employment services to address longer-term 
needs of residents affected by the storm.   
  Table 2:  Examples of States Sandy SSBG-funded Activities  
 
   State Activities  
  Repair, renovation, and rebuilding of health and child care facilities  
  Uncompensated operational expenses incurred by health facilities, child care 
New York 
providers, and food banks during and after Superstorm Sandy 
  Social and support services, including child care and housing services 
  Assistance with mortgage and rent payments, utilities, and appliances 
  Housing and supportive services for individuals with serious mental illness 
New Jersey 
  Home repair grants for seniors 
  Employment services for displaced homemakers 
  Repairs and renovations to docks and pilings damaged by Superstorm 
Sandy 
Connecticut 
  Case management, counseling, housing, and referral services 
  Unreimbursed expenditures covered by a damaged preschool 
  Housing and transportation services 
  Legal services 
Maryland 
  Summer camp focused on disaster resilience for affected children 
  Repairs to equipment and structures used by watermen 
  Case management and housing services 
  Post-hurricane clean-up to allow families to return to home   
Rhode Island 
  Information and referral services 
 
 
Source:  States Intended Use Plans and Progress Reports. 
States redirected Sandy funds as circumstances changed.  All five States 
amended their initial Intended Use Plans.  After receiving approval from 
ACF, States reallocated some Sandy SSBG funds to other previously 
approved or newly identified activities.  New Jersey officials reported that 
the flexibility to move funds from one activity to another was helpful as 
they learned more about the types of assistance people needed to recover 
from the storm.  For example, New Jersey redirected funds to expand 
mental health services and its homeowner and renter assistance program for 
individuals affected by Superstorm Sandy.  Similarly, New York redirected 
funds to existing Sandy SSBG programs related to child care, food and 
nutrition, and mental health services, as well as to a new program to provide 
housing for vulnerable populations affected by the storm. 
States used different strategies for distributing Sandy SSBG funds, which 
also helped them address their needs.  For example, New Jersey officials 
reported that using the States existing infrastructure and working with 
providers with a proven record allowed it to get assistance where it was 
needed more quickly.  Connecticut opened the funds up to a wide pool of 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  8 
     
   
   
potential service providers, whereas Maryland decided to set up a State-run 
program to fund services.   
The initial deadline that ACF established for expending 
Sandy SSBG funds did not allow States the time they 
needed to use the funds 
Both ACFs initial guidance for expending Sandy SSBG funds and the 
announcement to extend the deadlineissued about 3 months before the 
original deadlinelimited how States used the funds.  ACF initially 
instructed States that Sandy SSBG funds must be expended by  
September 30, 2015.  ACF reported that, in establishing the initial deadline, 
it focused on ensuring the timely and efficient delivery of disaster 
assistance.  In response to States need for additional time to use the Sandy 
SSBG funds, ACF reinterpreted the statutory deadline and issued revised 
instructions to States in June 2015.  The revised instructions indicated that 
Sandy SSBG funds could be expended through September 20172 years 
beyond the original deadline.  However, State officials reported that they 
were winding down some programs before they learned that ACF would 
revise the spending deadline.  For example, New Jersey officials noted that 
some Sandy SSBG-funded programs stopped accepting applications in 
anticipation of the initial deadline.  Further, these officials indicated that 
they would have planned their Sandy activities differently if they had 
known earlier that the funds would be available for expenditure through 
September 2017.  
The initial deadline for expending funds made it difficult for States and sub-
recipients to hire new staff focused on Sandy-related efforts.  State officials 
and sub-recipients reported that the initial deadline restricted the pool of 
qualified candidates for available positions to only those willing to consider 
a job ending by September 2015.  In some cases, it would have taken 
through 2013 to recruit and screen job candidates, so some Sandy SSBG- 
funded new hires would have been employed for less than 2 years.   
Additionally, the September 2015 deadline limited States and sub-
recipients ability to address longer term needs.  For example, State officials 
and sub-recipients noted that many effects of the storm continued or grew 
well after the initial impact, including housing shortages, mental health 
issues, and family disruptions.  In some cases, sub-recipients were able to 
extend their Sandy SSBG-funded activities to meet continuing needs.  Other 
activities ended as initially planned. 
 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  9 
     
   
   
States reported wanting more direction from ACF on 
allowable Sandy SSBG activities and documentation 
requirements    
State officials reported that, although ACF provided general guidance 
about Sandy SSBG funds, they wanted more direction from ACF about 
allowable activities and documentation requirements.  State officials and 
sub-recipients reported that they were not always clear about how they 
could use their Sandy SSBG funds or the type of documentation that ACF 
would expect from grantees to support their Sandy SSBG reimbursements 
during program integrity reviews.  
Given the flexibility of the Sandy SSBG grant, ACF did not prepare detailed 
guidance for States before they began planning their activities.  
Supplemental SSBG funds are designed to allow States to identify their own 
activities and related eligibility and documentation requirements.  Although 
ACF did not prepare detailed guidance, in an April 2013 webinar, it 
provided States general information on SSBG program goals as well as 
allowable activities for both general and disaster-specific SSBG service 
categories.  ACF also compiled a list of questions and answers from 
discussions with individual States and, from April 2013 to November 2014, 
issued a series of guidance documents to share with the States that received 
Sandy SSBG funds. 
To assist States in developing their programs, ACF reported facilitating 
State-to-State technical assistance on using supplemental SSBG 
funds.  ACF held monthly meetings with staff from the five States to 
respond to questions and provide an opportunity for States to exchange 
information about their programs.  ACF also reported connecting the five 
States that received Sandy funds to other States with supplemental SSBG 
experience to discuss lessons learned and recommendations from prior 
disasters.     
Despite ACFs general guidance and support of State-to-State technical 
assistance, States remained uncertain about whether SSBG Sandy funds 
would cover certain proposed activities.  This resulted in delays while States 
worked with ACF to get their Intended Use Plans approved.  Even after 
ACF approved States Intended Use Plans, some States needed more 
direction about allowable activities before soliciting, contracting with, or 
reimbursing sub-recipients.  For example, State officials and sub-recipients 
still had questions about whether certain expenses, such as vehicles costs, or 
past-due rent or electric bills, could be reimbursed with Sandy SSBG funds.  
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  10 
     
   
   
State officials and their sub-recipients reported that Sandy SSBG 
documentation requirements for program integrity purposes were not 
clear.  In some cases, State officials and sub-recipients did not always 
know what documentation ACF would expect as evidence that sub-
recipients were eligible to receive Sandy SSBG funds.  For example, sub-
recipients were not always clear about what documentation was needed to 
prove that their clients lived in affected areas.  In other cases, sub-
recipients did not know and/or collect the type of documentation needed to 
support claims for Sandy SSBG reimbursement.  Some recipients, such as 
small providers of child care, did not routinely collect and maintain the 
type of documents needed to support their Sandy SSBG claims.  State 
officials also reported that they were unable to adequately prepare for 
ACFs program integrity reviews because they lacked information about 
the review standards, including expected documentation.   
ACF implemented required reviews to account for 
Sandy SSBG funds and identify improper payments  
ACFs oversight of Sandy funds represented a departure from its established 
practices for oversight of SSBG funds.  Historically, ACFs oversight of 
SSBG funds focused on States annual reporting of their SSBG plans and 
expenditures.  With Sandy SSBG funds, ACF required additional reporting 
by States.  States submitted amendments, as necessary, to their Intended Use 
Plans and quarterly reports detailing their Sandy SSBG expenditures and 
progress.  ACF further expanded its existing oversight of SSBG funds by 
conducting program integrity reviews to examine States internal controls 
and potentially improper payments.  Table 3 illustrates how ACF expanded 
its oversight for each State that received Sandy SSBG funds.  During these 
reviews, ACF visited States and/or collected documentation to examine 
their compliance with program requirements.   
 
 
 
 
 
 
 
 
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Table 3:  ACFs Completed Program Integrity Reviews Through 
  
September 30, 2015
 
Quarterly Post- Quarterly  Internal  Improper 
expenditure  Progress  Controls  Payment 
Reports  Reports  Review  Review 
       
New York 
       
New Jersey 
        
Connecticut 
         
Maryland 
         
Rhode Island 
Source:  OIG analysis of interviews and documentation from ACF and States.  
As part of its expanded oversight, ACF conducted program integrity 
reviews of New York and New Jerseys internal controls.  These reviews 
focused on the two States that received most of the Sandy SSBG funds.29  
During the respective reviews, ACF found that most of the internal 
controls in both States were operating effectively.  However, ACF found 
that New Jersey did not always issue timely payments to sub-recipients 
and recommended that New Jersey revisit its preventive internal controls 
to ensure that invoices are paid on time.30  ACF also identified incomplete 
documentation by New York and its sub-recipients.  ACF recommended 
that New York ensure that all required forms and reports are completed 
and approved before accepting them from sub-recipients and submitting 
them to ACF.31   
Starting with the FY 2014 review period, ACF implemented improper 
payment reviews for Sandy SSBG funds, in line with OMBs guidance.32  
ACF focused its first improper payment review cycle on New Jersey, 
____________________________________________________________ 
29 ACFs review of New Jerseys internal controls covered the States activities from 
June 1, 2013 through July 31, 2014.  ACFs review of New Yorks internal controls 
covered the States activities from July 1, 2014 through October 30, 2015.   
30 ACF, FY 2014 Internal Control Review, State of New Jersey, Social Services Block 
Grant (Hurricane Sandy Supplemental Funds). 
31 ACF, FY 2015 Internal Control Review, New York State, Social Services Block Grant 
(Hurricane Sandy Supplemental Funds). 
32 ACFs FY 2014 improper payment review period covered July 1, 2013 through  
June 30 2014. 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  12 
     
   
   
which, at that time, was responsible for most Sandy SSBG expenditures.  
During the FY 2014 review period, ACF and its contractors examined the 
eligibility of individuals and households in New Jersey that received 
Sandy SSBG funds.  ACF initially calculated an error rate of about  
13 percent.33  However, ACF subsequently noted that many of these errors 
resulted from documentation that New Jersey maintained, but was not able 
to retrieve in time for the review.  Considering the additional 
documentation, the FY 2014 error rate would have been reduced to about 
5 percent.34  
For FY 2015, ACF expanded the number and breadth of its improper 
payment reviews and addressed some concerns raised in the first review 
cycle.  In this cycle, ACF conducted reviews of New Jersey, New York, 
and Connecticut, three States that received about 99 percent of all Sandy 
SSBG funds.35  Along with the eligibility reviews conducted for FY 2014, 
ACF and its contractors assessed the appropriateness of payments to sub-
recipients that provided benefits and services to individuals affected by 
Superstorm Sandy.  To address concerns raised in FY 2014, ACF 
modified its improper payment review methodology to allow States to 
respond to preliminary review findings and provide additional 
documentation, if available, to support claims.  For FY 2015, the error rate 
related to eligibility was about 1.2 percent and the error rate for payments 
to sub-recipients that provided benefits and services was about  
0.2 percent.36  Of the total errors, about $460,000 was associated with 
overpayments.37  ACF indicated that it would work with States to develop 
corrective actions plans.  ACF expected corrective actions to include 
enhanced State efforts to monitor and work with the most error prone sub-
recipients, as a means to address weaknesses in documentation and 
eligibility determinations, and payment recoveries.  
Supplementing ACFs program integrity reviews, States also implemented 
a variety of oversight activities for Sandy SSBG funds.  State officials 
____________________________________________________________ 
33 ACF, Social Services Block Grant, Hurricane Sandy Disaster Relief Funds, Improper 
Payments Report, Estimated Improper Payments and Payment Error Rate for Social 
Services Block Grant FY 2014 Report to the Office of Management and Budget,  
October 2014. 
34 HHS, FY 2015, Agency Financial Report, pg. 225 
35 ACF, Social Services Block Grant, Hurricane Sandy Disaster Relief Funds, Improper 
Payments Report, Estimated Improper Payments and Payment Error Rate for  
Social Services Block Grant FY 2015 Report to the Office of Management and Budget, 
October 2015. 
36 HHS, FY 2015, Agency Financial Report, p. 225. 
37 Ibid, pg. 227. 
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typically reported that they first screened prospective sub-recipients, 
whether individuals, service agencies, or facilities, for their eligibility to 
receive Sandy SSBG funds.  After approving awards, States required sub-
recipients to provide detailed documentation of their expenses, such as 
receipts, invoices, or employee pay records, before they released Sandy 
SSBG funds.  States tailored other oversight activities to the type of 
services and activities being funded.  For example, two States that funded 
reconstruction projects required onsite building inspections.  As part of 
their Sandy SSBG oversight, States also reviewed patient case records and 
verified the residences of individuals who received rent or other 
supportive services.   
   
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CONCLUSION AND RECOMMENDATIONS 
Supplemental SSBG funds are intended to provide a flexible source of 
funding that allow States to identify and target their disaster-related needs.  
States were able to use the funds for services, such as housing and other 
assistance for affected individuals, and reimbursement to health facilities 
for their reconstruction expenses.  However, to take full advantage of 
available funding for future disasters, States and grantees must receive 
appropriate guidance about when funds expire, how they may use the 
funds, and what documents or other evidence they must maintain for 
program integrity purposes.  
Therefore, we recommend that ACF: 
Take additional steps to ensure, within the scope of the 
legislation, that States are given appropriate time to expend 
any future supplemental SSBG awards 
For future disasters, ACF should seek to give States as much time as 
allowed under authorizing legislation to expend supplemental SSBG funds 
to address long-term recovery-related needs.  Additional steps could 
include developing or revising procedures for staff responsible for 
preparing guidance to States about expenditure timeframes.  The goal 
would be to communicate the expenditure timeframes to States before they 
begin developing their Intended Use Plans, avoiding the need to revise 
timeframes later.   
ACF should conduct a post-grant review to identify lessons 
learned and best practices   
ACF should conduct a post-grant review to help it identify information to 
share with States about specific activities that they can reimburse using 
Sandy SSBG funds.  The broad SSBG service categories allow States to 
determine how they will target their funds, but may leave questions about 
whether specific activities are consistent with SSBG program goals and 
requirements.  Some of these questions can be answered by States that 
have experience using SSBG funds.  Therefore, ACF should conduct a 
post-grant review, in consultation with States that received Superstorm 
Sandy supplemental SSBG funding, to identify lessons learned and best 
practices.  ACF can use information learned from this review to provide 
more direction to States affected by future disasters.  This direction should 
include examples and clarifications to help States to more readily judge, in 
advance, which activities may be covered.   
   
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Prepare guidance about supplemental SSBG documentation 
requirements   
ACF should prepare guidance about the type of documentation that States 
and sub-recipients should maintain to support eligibility and claims for 
reimbursement.  ACFs new program integrity reviews for Sandy SSBG 
funds left some States and sub-recipients unsure about the type of 
documentation they would need to support their Sandy-related claims.  
ACF could use feedback from States and its findings from its Sandy SSBG 
program integrity reviews to clarify its expectations for documentation for 
areas about which sub-recipients have questions or concerns.        
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AGENCY COMMENTS AND OFFICE OF INSPECTOR GENERAL 
RESPONSE 
ACF concurred with all of our recommendations.  In its comments, ACF 
noted that it had worked to respond to State-identified needs and that, 
consistent with its statutory authority, had provided States the necessary 
flexibility to administer their Sandy SSBG funds.     
ACF concurred with our recommendation to take additional steps to 
ensure that States are given appropriate time to expend any future 
supplemental SSBG awards.  ACF noted the importance of early 
communication of deadlines to ensure the efficient and timely use of 
funds.  ACF also indicated that for future supplemental SSBG 
authorizations, it will implement measures that allow States the full 
timeframe available under the law to use the funds.  ACF added that it will 
conduct an internal administrative review to identify future strategies for 
releasing funds and issuing guidance on expenditure timeframes. 
ACF concurred with our recommendation to conduct a post-grant review 
to identify best practices and lessons learned.  ACF stated that it will 
continue to work with States to identify best practices, lessons learned, 
technical assistance, and guidance that can be shared with other States in 
the event that Congress authorizes disaster supplemental funding in the 
future.    
ACF also concurred with our recommendation to prepare guidance 
clarifying supplemental SSBG documentation requirements.  ACF stated 
that it plans to solicit feedback from States on guidance and technical 
assistance that can be provided to States in the future and work with key 
State officials to identify resources that can be made available to States 
quickly in connection with disaster supplemental funding in the future.  
OIG supports ACFs plans to work with States on guidance and technical 
assistance.  We reiterate that guidance for States should address the types 
of documentation needed to support eligibility and reimbursement for 
supplemental disaster funds.  
For the full text of ACFs comments, see Appendix C.   
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APPENDIX A 
State-specific Sandy SSBG Expenditures by Service Category, 
Through September 30, 2015 
  Rhode 
New York  New Jersey  Connecticut  Maryland  Total 
Island 
1. Adoption  0  0  0  0  0  0 
2. Case Management  $8,192,775  $2,158,016   $1,060,526  $71,181  $3,624  $11,486,122 
3. Congregate Meals  $1,876,145  $22,994   0  $245  0  $1,899,384 
4. Counselling  $522,279  $13,359,523   $742,167  0  0  $14,623,969 
5. Day Care, Adults  0  0  0  0  0  0 
6. Day Care, Children  $777,277  $412,297   0  0  0  $1,189,574 
7. Education & Training  $188,442  $2,702,151   0  0  0  $2,890,593 
8. Employment  $97,511  $910,228   0  0  0  $1,007,739 
9. Family Planning  0  0  0  0  0  0 
10. Foster Care, Adults  0  0  0  0  0  0 
11. Foster Care, Children  $39,178  0  0  0  0  $39,178 
12. Health-Related  $3,004,382  $6,446,487   0  $1,160  0  $9,452,029 
13. Home-Based  $347,698  0  0  $1,310  0  $349,008 
14. Home-Delivered Meals  0  $94,698   0  0  0  $94,698 
15. Housing  $1,180,262  $122,686,293   $744,916  $221,737  $85,476  $124,918,684 
16. Independent/Transitional Living  $40,151  0  0  0  0  $40,151 
17. Information & Referral  $2,619,642  $5,626,551   $88,372  0  $68,036  $8,402,601 
18. Legal  $3,578,024  $1,860,581   0  $4,192  0  $5,442,797 
19. Pregnancy & Parenting  0  0  0  0  0  0 
20. Prevention & Intervention  $1,345,644  $9,784,588   0  0  0  $11,130,232 
21. Protective, Adults  0  0  0  $632  0  $632 
22. Protective, Children  0  $1,801,167   0  0  0  $1,801,167 
23. Recreation  0  0  0  $138,757  0  $138,757 
24. Residential Treatment  $67,119  0  0  0  0  $67,119 
25. Special, Disabled  $592,251  $466,389   0  0  0  $1,058,640 
26. Special, Youth at Risk  $661,141  0  0  0  0  $661,141 
27. Substance Abuse  $68,964  $294,232   0  0  0  $363,196 
28. Transportation  $211,182  0  0  $490  0  $211,672 
Other  $26,422,566  $1,260,553   0  $228,060  0  $27,911,179 
Other, Health  $29,708,882  0  0  0  0  $29,708,882 
Other, 
$5,782,529  0  0  0  0  $5,782,529 
Mental Health 
Other, Repair, Renovation, & 
$2,133,088  $288,929   $1,159,000  0  0  $3,581,017 
Rebuilding-Child Care Facilities 
Other, Repair, Renovation, & 
$27,576,959  $942,754   0  0  0  $28,519,713 
Rebuilding-Health Care Facilities 
Other, Repair, Renovation, & 
$1,218,525  0  0  0  0  $1,218,525 
Rebuilding-Mental Health Facilities 
Other, Repair, Renovation, & 
$5,289,382  $5,946,364   $35,000  0  0  $11,270,746 
Rebuilding-Other 
Total Services  $123,541,998  $177,064,795   $3,829,981  $667,764  $157,136  $305,261,674 
Administrative Costs  $5,209,573  $5,428,810   $10,803  $28,191  0  $10,677,377 
Total Services plus 
$128,751,571  $182,493,605   $3,840,784  $695,955  $157,136  $315,939,051 
Administrative Costs 
 
Source:  States post-expenditure reports, through September 30, 2015. 
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APPENDIX B 
State Agencies that Participated in OIG Interviews 
 
New York 
Office of Children and Family Services (Lead Sandy SSBG Agency) 
      Division of Administration 
Financial Operations 
        Audit and Quality Control 
Contract Management 
 
New Jersey 
Department of Human Services (Lead Sandy SSBG Agency) 
      Office of Recovery 
Division of Mental Health and Addiction Services 
      Division of Aging Services 
      Division of Disability Services 
   
Department of Children and Families 
   
Department of Health 
 
Office of the Attorney General 
 
New Jersey Housing and Mortgage Finance Agency 
 
Connecticut 
Department of Social Services (Lead Sandy SSBG Agency) 
 
Maryland 
Department of Human Resources (Lead Sandy SSBG Agency) 
   
Rhode Island 
Department of Human Services (Lead Sandy SSBG Agency)  
   
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APPENDIX C 
Agency Comments 
   
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ACKNOWLEDGMENTS 
This report was prepared under the direction of Blaine Collins, Regional 
Inspector General for Evaluation and Inspections in the San Francisco 
regional office, and Michael Henry, Deputy Regional Inspector General.  
Camille Harper served as the team leader for this study and Christina 
Lester served as the lead analyst.  Central office staff who provided 
support include Clarence Arnold, Joanne Legomsky, Melicia Seay, and 
Sherri Weinstein.  
 
Sandy SSBG: Funds Benefited States Efforts, Though ACFs Guidance Could Be Improved (OEI-09-15-00200)  23 
     
   
Office of Inspector General
http://oig.hhs.gov  
 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95452, as  
amended, is  to protect the integrity of the Department of  Health and Human Services  
(HHS) programs, as  well  as the health  and welfare of individuals served by those programs.  
This statutory mission is carried  out through a nationwide network of audits, investigations,  
and inspections conducted by the following operating components: 
Office of Audit Services 
The Office  of  Audit Services  (OAS) provides auditing services  for HHS, either by  conducting  
audits  with its own audit resources or by  overseeing  audit work done by others.  Audits  
examine the performance of HHS programs and/or its grantees and contractors in carrying  
out their respective responsibilities and are intended  to provide independent assessments of 
HHS programs and operations.  These assessments help reduce waste, abuse, and  
mismanagement and promote economy and efficiency  throughout  HHS. 
Office of Evaluation and Inspections 
The Office  of  Evaluation and Inspections (OEI)  conducts national evaluations to  provide 
HHS, Congress, and the public with timely, useful, and reliable information on significant 
issues.  These evaluations focus on preventing fraud,  waste, or abuse  and promoting  
economy, efficiency, and effectiveness of departmental programs.  To promote impact, OEI 
reports also present practical recommendations for improving program operations.  
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative investigations  
of fraud and misconduct  related to HHS programs, operations, and individuals.  With  
investigators working in all 50 States and the District of Columbia, OI  utilizes its resources 
by actively  coordinating with the Department  of Justice  and other Federal, State, and local 
law enforcement authorities.  The investigative efforts of OI often lead to  criminal 
convictions, administrative sanctions,  and/or  civil monetary  penalties.  
Office of Counsel to the Inspector General 
The Office of Counsel to the  Inspector  General (OCIG) provides general legal services to 
OIG, rendering  advice and opinions on HHS programs and operations and  providing all  
legal support for OIGs  internal operations.  OCIG represents  OIG in all civil and 
administrative fraud and  abuse cases involving HHS programs, including False Claims Act, 
program exclusion, and civil monetary penalty cases.  In  connection with these cases, OCIG 
also negotiates and monitors corporate integrity agreements.  OCIG renders advisory 
opinions, issues compliance program  guidance, publishes fraud alerts, and provides other  
guidance  to  the health care industry concerning the anti-kickback statute and other  OIG  
enforcement authorities.