FEMA Did Not Provide
Sufficient Oversight ofProject Airbridge

February 7, 2023
OIG-23-14

OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Washington, DC 20528 / www.oig.dhs.gov)HEUXDU\MEMORANDUM FOR:

The Honorable Deanne Criswell
Administrator
Federal Emergency Management

FROM:

Joseph V. Cuffari, Ph.D. JOSEPH V Digitally signed by
JOSEPH V CUFFARI
Inspector General
Date: 2023.02.03

CUFFARI 14:58:19 -07'00'

SUBJECT:

FEMA Did Not Provide Sufficient Oversight ofProject Airbridge

For your action is our final report, FEMA Did Not Provide Sufficient Oversight ofProject Airbridge. We incorporated the formal comments provided by youroffice.
The report contains two recommendations aimed at improving the overall
effectiveness of future public/private partnerships. Your office concurred withboth recommendations. Based on information provided in your response to
the draft report, we consider recommendations 1 and 2 open and resolved.
Once your office has fully implemented the recommendations, please submit aformal closeout letter to us within 30 days so that we may close therecommendations. The memorandum should be accompanied by evidence ofcompletion of agreed-upon corrective actions and of the disposition of any
monetary amounts.
Please send your response or closure request to
OIGAuditsFollowup@oig.dhs.gov.
Consistent with our responsibility under the Inspector General Act of 1978, as
amended, we will provide copies of our report to congressional committees
with oversight and appropriation responsibility over the Department ofHomeland Security. We will post the report on our website for publicdissemination.
If you have any questions please call me at (202) 981-6000, or your staff may
call Bruce Miller, Deputy Inspector General for Audits.

www.oig.dhs.gov

DHS OIG HIGHLIGHTS

FEMA Did Not Provide Sufficient Oversightof Project Airbridge
February 7, 2023

Why We Did
This Audit
In response to COVID-19,
FEMA initiated Project
Airbridge to mitigate
shortfalls in medical supply
distributors’ PPE andfacilitate the delivery ofcritical PPE to locations
where it was most needed.
The objective of this audit
was to determine the extent
to which FEMA provided
oversight of Project
Airbridge and ensured its
commercial partners
distributed medical
supplies to prioritized
healthcare facilities indesignated locations.

What We FoundThe Federal Emergency Management Agency (FEMA) did
not provide sufficient oversight of Project Airbridge, a
COVID-19 initiative. Under unprecedented pressure to
mitigate disruptions in global medical supply chains,
FEMA established Project Airbridge. The project was
intended as a temporary measure to address perceived
shortfalls in distributors’ personal protective equipment(PPE) inventories of gloves, gowns, and masks. However,the project actually supplemented the distributors’ alreadylarge domestic inventories. We attribute Project Airbridge’s
unnecessary air shipment of PPE to the pressure FEMA
faced to get medical supplies distributed quickly. With alimited understanding of commercial supply and demand,
FEMA did not sufficiently assess whether medical supply
distributors needed Project Airbridge to stabilize their
supply chains.

In addition, FEMA did not ensure the distributors delivered
PPE to healthcare facilities as agreed. We could only
confirm distributors delivered 35 percent of Airbridge PPE
to designated healthcare facilities in prioritized locations
instead of the 50 percent minimum required by FEMA.
Because FEMA did not properly define the project’s
requirements, it did not have sufficient controls to hold the
distributors accountable. As a result, FEMA paid totransport PPE that may not have been necessary to meet
distributors’ needs and was not always delivered tolocations most in need. Accordingly, the project’s $238
million may have been better spent on other COVID-19
We made tworecommendations to improve initiatives. FEMA should leverage lessons learned fromthis audit when contemplating and undertaking future
FEMA’s management andprivate-government partnerships.
oversight of future
public/private partnerships.

What We
Recommend

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

www.oig.dhs.gov

FEMA Response

FEMA concurred with our two recommendations. We
consider both open and resolved.

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Background
The U.S. Department of Health & Human Services (HHS) determined that anationwide public health emergency existed starting on January 27, 2020,
due to COVID-19. In March 2020, the World Health Organization
characterized the COVID-19 outbreak as a pandemic1 and President Trumpdeclared a nationwide emergency.2 The Federal Emergency Management
Agency (FEMA) initially supported HHS in combating the COVID-19 pandemic,
but soon transitioned to leading the Federal response.
In 2020, the FEMA Administrator and HHS Assistant Secretary for
Preparedness and Response co-led the Unified Coordination Group3 andassembled task forces to address top priorities for the pandemic response,
including supply chain disruption. For example, FEMA and HHS created aSupply Chain Stabilization Task Force (Task Force), one of eight COVID-19focused task forces under the National Response Coordination Center. The
Task Force used a whole-of-America approach to increase the flow of medical
supplies and equipment to healthcare workers on the front line. It dealt withpersonal protective equipment (PPE) supply shortages at different levels, suchas:(1) supply shortages for healthcare workers on the front line, and(2) supply shortages in medical distributors’ PPE supply base.
The National Resource Prioritization Cell, led by the Task Force, developed
data-driven recommendations to the Unified Coordination Group to ensure
distribution of the right resources to the right places at the right time. The
cell issued bulletins that identified priority places of care and specificgeographic locations that needed PPE the most.
In March 2020, FEMA initiated Project Airbridge to serve as a temporary
solution designed to address perceived shortages in medical supply
distributors’ inventories of PPE. FEMA covered the flight costs of shipping PPEfrom overseas factories in several countries (such as Malaysia, China, andVietnam) to U.S. medical supply distributors. By using air freight instead ofsea shipments, Project Airbridge reduced shipment times from around 36 days
to about 4 days. In exchange for expedited flights at FEMA’s expense, themedical supply distributors agreed to distribute at least 50 percent of thetransported PPE to distributors’ customers at a reasonable price in specificareas prioritized by FEMA and HHS. The distributors would disseminate the
1 WHO Director-General's opening remarks at the media briefing on COVID-19, March 11, 2020.
2 Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease(COVID-19) Outbreak, March 13, 2020.
3 On March 20, 2022, FEMA and HHS established a Unified Coordination Group to makecritical prioritization decisions in response to COVID-19. The group provided national-level
decision points to the White House Coronavirus Task Force.
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remainder of the shipments into the broader U.S. supply chain as part of theirregular course of business.
FEMA signed memorandums of agreement (MOAs) outlining the terms of its
public-private partnership with six medical supply distributors4 to transportand distribute PPE.
On March 29, 2020, the first Project Airbridge flightlanded at New York’s John F. Kennedy International
Airport; the last flight landed on June 30, 2020, at
Ohio’s Rickenbacker International Airport. In total,
FEMA spent $237.6 million to transport to theUnited States approximately 1.1 billion PPE items,
primarily consisting of gloves, masks, and gowns.
Table 1 identifies the type and amount of PPEtransported by Project Airbridge.5

Table 1. PPE Transported into
the United States by Project
Airbridge

PPE
Type

Total Airbridge PPEGloves936.9M

Gowns

66.6M

Masks

122.4M

Other

23.2M

Total

1.1B

Source: Department of Homeland
Security Office of Inspector General
analysis of FEMA Project Airbridge
Tracker

The objective of this audit was to determine theextent to which FEMA provided oversight of Project
Airbridge and ensured its commercial partners
distributed medical supplies to prioritized healthcare facilities in designatedlocations.

Results of Audit
Although Project Airbridge was a potential solution to address concerns about
insufficient PPE during an unprecedented pandemic, FEMA did not provide
sufficient oversight of Project Airbridge, which expended approximately $238
million to transport about 1.1 billion PPE items to the United States.
Specifically, FEMA did not assess medical supply distributors’ inventories of
PPE. This occurred because FEMA went from concept to implementation of
Project Airbridge in about 1 week, without assessing the capacity of the
distributors’ commercial supply chains. According to FEMA, although it
gathered demand signals based on PPE resource requests from states,
localities, tribes, and territories, as it does in traditional disasters, it operated
with a limited understanding of commercial supply and demand. As a result,the project did not address shortfalls in the inventory of PPE. Rather, theproject supplemented the distributors’ already large domestic inventories ofgloves, gowns, and masks, which grew about one-third between March andJune 2020. Consequently, FEMA paid to transport PPE that may not have
4 The six distributors represented approximately 90 percent of the market share of thedomestic medical supply industry before the pandemic.
5 The PPE type “Masks” includes surgical and procedure masks but does not include N95 or
K95 respirators; the PPE type “Other” includes items such as N95 respirators, face shields,
thermometers, and other supplies transported through Airbridge in smaller amounts.
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been necessary to meet the distributors’ needs, meaning, the project’s $238
million may have been better spent on other COVID-19 initiatives.
In addition, FEMA did not ensure the distributors delivered PPE to healthcare
facilities as agreed. Specifically, we could only confirm distributors delivered
35 percent of the Airbridge PPE to designated healthcare facilities in prioritizedlocations instead of the 50 percent minimum requirement. This occurredbecause MOAs with the distributors, which were quickly signed andimplemented, contained ambiguous terms that made enforcing themchallenging. Because FEMA did not properly define the project’s requirements,
it did not have the controls necessary to hold the distributors accountable. As
a result, PPE was not always delivered to locations most in need. FEMA should
leverage lessons learned from this audit when contemplating future privategovernment partnerships.
Project Airbridge was Not Needed to Stabilize Domestic Supply Chains
In March 2020, one of FEMA’s goals was to ensure it met the medical supply
and equipment needs of healthcare providers quickly through various
initiatives, including Project Airbridge. FEMA was charged with assessing the
medical supply chain to identify gaps and shortfalls. In response to anticipatedsupply chain disruptions and an unprecedented surge in demand for critical
PPE in healthcare facilities, Project Airbridge was designed to mitigate medical
supply distributors’ immediate perceived PPE shortages in domestic medical
supply chains. In other words, the project was meant to temporarily stabilize
domestic medical supply chains so distributors could satisfy anticipated surges
in PPE demands.
Although it was not FEMA’s intent, Project Airbridge added to large quantities
of existing PPE items in distributors’ supply chains and inventories in the
United States. As set forth in Table 1, from March through June 2020, FEMAtransported into the United States approximately 1.1 billion PPE items for the
medical distributors. During that same period, PPE Monthly Distributor Volume
reports6 showed distributors already had 7.5 billion gloves, and imported about
25 billion of the same PPE items from their existing supply chains. Thisoccurred because, despite the pandemic and supply chain issues, the medical
distributors continued to use their own commercial supply chains to import
PPE throughout the duration of Project Airbridge. For perspective, Project
Airbridge PPE shipments represented just under 5 percent of total PPE
shipments received by distributors from March through June 2020.
Moreover, the distributors already had sufficient domestic inventories to
distribute PPE to their customers without Project Airbridge. For example,
6 Prepared by the Supply Chain Stabilization Task Force, PPE Monthly Distributor Volume

reports contained monthly PPE data on distributors’ domestic inventories, shipments frommanufacturers, and distributions to customers.
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FEMA transported approximately 937 million gloves during the project.
Concurrently, the six distributors imported 23 billion gloves through existing
channels and maintained an average PPE ending inventory of 8.5 billion acrossall distributors. Figure 1 illustrates glove inventories compared to distributions
and Airbridge shipments.
Figure 1. Glove Inventory Capacity vs. Distributed Inventory (in billions),
March – June 2020

Source: DHS OIG analysis of Supply Chain Stabilization Task Force PPE Monthly Distributor
Volume reports

Instead of acting as a temporary measure to address supply chain shortages,
Project Airbridge created unnecessary increases to already large domestic
inventories of gloves, gowns, and masks. During the project, the PPE inventory
increased by about 2.6 billion items (32 percent). Although never intended toaugment growing commercial inventories, Project Airbridge contributed to 5
percent of the overall 32 percent inventory growth. The most significant growthoccurred in surgical mask inventories, which grew by about 568 million (almost
180 percent). Project Airbridge contributed to 8 percent of the mask inventory
growth. Table 2 provides information about PPE imported and present ininventories during Project Airbridge.

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Table 2. PPE in the United States Brought in and Present during Project
Airbridge by the Six Distributors, March to June 2020
PPE
Type

Beginning
Inventory
March
2020

Total PPE
Brought in byDistributors

EndingInventory
June
2020

AverageInventory

Numberof PPE
Items
Project
Airbridge
Brought
to theUnitedStatesMarch 29
- June30, 2020

Percent
Growth inInventories

Gloves
Gowns
Masks
Total

7.5B
244.7M
320.9M
8.1B

23.0B
473.7M
1.5B
24.9B

9.6B
248.1M889.0M
10.7B

8.5B
186.1M
510.8M
9.2B

936.9M
66.6M
122.4M
1.1B

27%
1%
177%
32%

Source: DHS OIG analysis of Supply Chain Stabilization Task Force PPE Monthly Distributor
Volume reports

FEMA Did Not Assess Medical Supply Distributors’ Supply Chains
We attribute Project Airbridge’s unnecessary air shipment of PPE items to thepressure FEMA faced to get medical supplies distributed quickly. As a result,
FEMA did not sufficiently assess whether medical supply distributors needed
Project Airbridge to stabilize their supply chains. FEMA initiated Project
Airbridge in about a week without first considering the distributors’ existing
domestic supply chains, including inventory levels, scheduled sea shipments,
and actual customer deliveries. According to FEMA, despite early engagementwith private sector partners, neither FEMA nor the partners were able to assess
PPE capacity given the uncertainty about supply chains and the urgency ofrising demand. FEMA further explained that, given its reliance on Resource
Request Forms from states, localities, tribes, and territories to determine
demand, it operated with the belief that demand would rapidly deplete
available supply because domestic PPE consumption was far greater thanusual. Although FEMA eventually obtained some private sector supply data, it
still did not have a comprehensive overview of the distributors’ inventories
during the project. According to FEMA, without a comprehensive
understanding of the evolving national supply and demand, it could not fully
evaluate the cost and operational effectiveness of the project.
FEMA did not conduct a cost-benefit analysis until mid-April 2020. FEMA
justified continuation of the project based on high PPE demand signals andreduced shipping times from an average of 36 to 4 days, emphasizing air
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freight delivery speed over larger sea shipment volumes. Although air freight isquicker, one air shipment can only transport about 1/1,100 of the volume of
one container vessel and at a much higher cost. Thus, high demand signals
and reduced shipping times are not sufficient justification given that, during
Project Airbridge, the distributors continued to import high volumes of PPE attheir own expense to increase existing large inventories.
FEMA also did not establish procedures for determining when to sunset Project
Airbridge and did not define guidelines for assessing the distributors’ ability tosustain supplies delivered by sea. Instead, FEMA based decisions on ad hoc
discussions with distributors about PPE needs. FEMA expressed concerns thatswitching to sea shipments too early in the project might result in a lack of PPE
importation into the United States for an extended period. To mitigate thisrisk, the Unified Coordination Group, at FEMA’s recommendation, decided togradually transition from air to sea shipments in May 2020, with only gowns
flown through Project Airbridge during June 2020. By that time, 82 percent of
the Project Airbridge shipped gloves, masks, and gowns had already arrived in
the United States and been delivered to the distributors. Because FEMA did
not assess supply needs at the outset of Project Airbridge, FEMA paid totransport PPE that may not have been necessary to meet immediate distributor
needs. Accordingly, the project’s $238 million may have been better spent onother COVID-19 initiatives.
FEMA Did Not Ensure Medical Supply Distributors Delivered PPE to
Healthcare Facilities in Designated Locations
According to the MOAs signed in March 2020, in exchange for transportation at
FEMA’s expense, medical supply distributors agreed to distribute at least 50
percent of the transported PPE to FEMA and HHS-designated locations.
Designated locations included hospitals, nursing homes, long-term carefacilities, and state and local governments in geographic locations with thegreatest needs. Distributors also agreed to sell the PPE to existing customers
at a reasonable price. On April 8, 2020, at the direction of the FEMA
Administrator, the National Resource Prioritization Cell issued Resource
Prioritization Bulletin #2, which identified recommended priority sites of care,such as hospitals and nursing homes, as well as priority county locations. In
accordance with MOA requirements, FEMA provided the distributors withspreadsheets that identified, by county, priority locations with the greatest needfor PPE. FEMA updated the spreadsheets weekly or biweekly.
We were only able to confirm that the six medical supply distributors delivered
35 percent (395 million PPE items) of total Project Airbridge shipments tohealthcare facilities in designated locations instead of a minimum of 50 percent
required by the Project Airbridge MOAs. Although the distributors delivered 35
percent of Project Airbridge PPE to healthcare facilities in prioritized locations,
we could not determine the extent to which they prioritized hospitals andwww.oig.dhs.gov

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nursing homes over other medical customers. The MOAs clearly identified
targeted recipients, but they did not limit distribution to them. This ambiguity
allowed distributors to continue with their normal distribution processes totheir customers, including medical professionals who provide non-critical,
elective medical services, such as chiropractors, plastic surgeons, dentists, andophthalmologists — many of whose practices were closed during the project’s
timeframe — and retail, wholesale, and home improvement stores.
The distributors made non-compliant distributions, meaning PPE was notdelivered to healthcare facilities in the designated locations for the minimum
50 percent requirement or the final delivery location of PPE could not be
determined from FEMA’s records. Specifically, although distributors delivered
696 million gloves, gowns, masks, and N95 respirators, 301 million of these
items were non-compliant distributions. Almost 36 percent (107 million) of
non-compliant distributions went to customers in non-priority locations.
About 61 percent (184 million) of non-compliant distributions went to other
distributors instead of healthcare facilities in designated locations. Five of thesix distributors had sales to other distributors, ranging from 2 percent to 65
percent of their total distributions. Although the MOAs did not strictly prohibit
distributor-to-distributor sales, distributors are not final consumers.
Therefore, for distributor-to-distributor sales, we could not determine thegeographic location of final recipients for compliance reporting purposes,
making these distributions non-compliant. The final 4 percent of noncompliant distributions went to non-medical customers, such as hair salons,veterinarians, or other retail establishments. Figure 2 sets forth information
regarding compliant and non-compliant distributions. Appendix B summarizes
the distribution locations of the 696 million Project Airbridge PPE.

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Figure 2. Airbridge PPE Distribution Compliance with MOA Requirements7

Source: DHS OIG analysis of medical distributors’ Airbridge Compliance Reports

The distributors’ compliance rates varied significantly. Individual compliance
rates for the six distributors ranged from 6 percent to 58 percent, with only one
distributor exceeding the minimum 50 percent requirement. One distributordelivered about 19 million PPE items to its priority customers out of 322
million PPE items shipped to it through Project Airbridge. Another exceeded its
overall required distribution to priority locations by more than 3 million PPE
items, but it distributed just 13 percent of the 1.2 million N95 respirators it
received. Table 3 shows the six distributors’ compliance with MOA
requirements.

7 Airbridge Compliance Reports did not include all Project Airbridge distributions, only what

was distributed in relationship to the minimum 50 percent compliance requirement of total
shipments. The PPE amount labeled as “Non Subject to MOA Compliance” in Figure 2 does not
represent distributions but instead the portion of Project Airbridge PPE that distributors could
sell through their regular distribution networks into the broader U.S. supply chain.
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Table 3. Airbridge PPE Distribution Compliance with MOA Requirements

MedicalSupplyDistributors

Project
Airbridge
Shipments

DistributortoDistributor

NonPriority
Locations

NonMedical
Customers

Distributor 1
42M
5M
472K
Distributor 2
11M
2K
76K
Distributor 3
67M
1M
5M
Distributor 4
430M
6M
45M
Distributor 5
250M
21M
583K
Distributor 6
322M
150M
56M
Grand Total
1.1B
184M
107M
PPE Items in: Billions (B); Millions (M); Thousands (K)

2M
97K
132K
839K
3M
5M
10M

CompliantDistributions

CompliantDistribution
as aPercentage
of Project
Airbridge
Shipments

24M
5M
25M
200M
122M
19M
395M

58%
43%
37%
46%
49%
6%
35%

Source: DHS OIG analysis of medical distributors’ Airbridge Compliance Reports

FEMA Did Not Implement Controls to Enforce Compliance with MOAs
FEMA did not establish a process to enforce compliance with the MOAs before
coordinating flights to deliver PPE. Specifically, FEMA began coordinating
Project Airbridge flights prior to finalizing the MOAs, with most signed the dayof the first flight. FEMA did not implement sufficient controls because it
advanced from concept to implementation of MOAs in less than 1 week.
According to one FEMA official, FEMA established processes throughout the
project’s life. The FEMA official described it as building the plane while it was
flying. Because FEMA did not properly define the project’s requirements, suchas priority facilities and reporting requirements, in the MOAs, it did not havethe controls necessary to hold the distributors accountable, which madeassessing and enforcing Project Airbridge requirements even more challenging.
FEMA also experienced problems with distributors’ reporting because of issues
with timeliness, completion, and accuracy. The reports for the six distributors
were missing facility types, delivery dates, and pricing information. Five of thesix distributors delayed reporting for various reasons described by FEMA
including reluctance to share data, internal reporting difficulties, and an
inability to determine where they delivered PPE. Due to the omission of basic
program metrics, FEMA could not determine if the project helped the
distributors accelerate PPE distribution to prioritized healthcare facilities atreasonable prices.

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Conclusion
COVID-19 became the first national pandemic response led by FEMA since its
inception. After the President declared a nationwide emergency on March 13,
2020, FEMA needed to develop novel approaches to address potential PPE
supply shortages at healthcare facilities throughout the United States.
We understand the need to mitigate supply chain disruptions. However, FEMA
still had a responsibility to spend funds on verified needs. Although airlift
initiatives move items quickly, they are not justified when inventory growth
exceeds distribution rates. During Project Airbridge, the distributors’ supply
chains were functioning, they had significant PPE inventories, and they
imported more PPE than Project Airbridge. FEMA should have implemented
better controls to assess and adjust operations based on distributors’
inventories and supply lines, but it did not. Additionally, Project Airbridge
appears to have had little impact in reducing critical PPE shortages forhealthcare workers who needed supplies most. Only one of the six distributors
satisfied the MOA minimum 50 percent compliance requirement of total
shipments. Thus, the project’s $238 million may have been better spent onother COVID-19 initiatives. FEMA should leverage lessons learned from thisaudit when contemplating and undertaking future private-government
partnerships.

Recommendations
Recommendation 1: We recommend the FEMA Administrator develop andimplement assessment criteria for public/private partnerships with
distributors in response to life-threatening circumstances or events. At aminimum, assessment criteria should include:
x a justification memorandum explaining why each partnership isnecessary, including a clear definition of the problem and why thepartnership is an effective solution with consideration of needs, costs,
and alternatives;
x an assessment of alternatives;x a cost/benefit analysis; andx information regarding the partners’ existing supply chain, including
existing inventories, supply replenishment shipments and customer
orders and deliveries to support public/private partnerships.
Recommendation 2: We recommend the FEMA Administrator develop andimplement policies and procedures for the use of memorandums of agreement
when establishing public/private partnerships in response to life-threatening
circumstances or events. The policies and procedures should ensure FEMA
can enforce and assess compliance with the memorandums of agreement
requirements and address, at a minimum:x the review and approval process;www.oig.dhs.gov

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x
x
x
x
x

statutory authorities;
roles and responsibilities;
evaluation and reporting requirements;
targeted end-use, users, and locations; andindustry information necessary to monitor compliance.

Management Comments and OIG Analysis
The Acting Associate Administrator Office of Policy and Program Analysis
provided written comments on a draft of this report, which are included in their
entirety in Appendix A. FEMA concurred with our two recommendations. Prior
to drafting our report, FEMA provided technical comments in response topotential findings and recommendations. We made revisions whereappropriate to the findings. Following the issuance of our draft report, FEMA
did not provide additional technical comments. We consider both
recommendations open and resolved.
In its response to our draft report, FEMA stated the OIG concluded there wasno shortage of PPE in the early days of COVID-19, and therefore, FEMA did notneed to accelerate PPE delivery. FEMA disagreed with that conclusion andcited reports of PPE supply chain disruptions, rising PPE demand signals, andshortages of PPE among hospital staff. However, our findings do not question
whether PPE supply chain disruptions existed or whether PPE shortages
existed among healthcare workers, but rather whether Project Airbridge was aneffective and efficient solution as implemented. We found that Project Airbridge
supplemented large and growing PPE inventories of participating medical
supply distributors, and FEMA did not ensure those distributors delivered PPE
to healthcare facilities as agreed. Therefore, Project Airbridge appeared to have
had little impact in reducing critical PPE shortages for healthcare workers whoneeded supplies most.
FEMA’s Response to Recommendation 1: FEMA officials concurred and willdevelop assessment criteria that apply when a public/private partnership isnecessary to effectuate the delivery of emergency protective measure assistanceunder the Stafford Act. FEMA’s estimated completion date is December 31,
2024.
OIG Analysis: FEMA’s proposed actions are responsive to thisrecommendation, which we consider open and resolved. It will remain open
until we receive evidence of FEMA’s implementation of public/private
partnership assessment criteria.
FEMA’s Response to Recommendation 2: FEMA officials concurred and willdevelop policies and procedures to establish memoranda of agreement or other
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appropriate agreements that apply when a public/private partnership isnecessary to effectuate emergency protective measures assistance under theStafford Act. FEMA’s estimated completion date is December 31, 2024.
OIG Analysis: FEMA’s proposed actions are responsive to thisrecommendation, which we consider open and resolved. It will remain open
until we receive evidence of FEMA’s implementation of the applicable policies
and procedures.

Objective, Scope, and Methodology
The Department of Homeland Security Office of Inspector General wasestablished by the Homeland Security Act of 2002 (Public Law 107−296) byamendment to the Inspector General Act of 1978.
Our audit objective was to determine the extent to which FEMA provided
oversight of Project Airbridge and ensured its commercial partners distributed
medical supplies to prioritized healthcare facilities in designated locations. Our
audit scope covered all Project Airbridge flights from March 2020 through June
2020 and distributions made by medical distributors from March 2020 throughAugust 2020.
We assessed internal controls related to FEMA’s oversight of Project Airbridge.
Because our review was limited to addressing our audit objective it may nothave disclosed all internal control deficiencies that may have existed at thetime of the audit. As discussed in the body of this report, we identified
weaknesses related to FEMA’s establishment and administration of the project.
To gain an understanding of Project Airbridge, we met with Supply Chain
Stabilization Task Force leadership, counsel, and staff and with the FEMA
Logistics Management Directorate to discuss the intent of the project and theprocess used to develop its requirements. We reviewed meeting minutes,
planning documents, congressional testimony, reports, and MOAs between
FEMA and Project Airbridge distributors to understand Project Airbridge
requirements and how it was managed and overseen.
To determine the quantity and type of supplies FEMA imported through Project
Airbridge, we reviewed FEMA’s Project Airbridge Tracker. We assessed thereliability of the tracker by validating the flight numbers, dates, distributor
names, quantity, and type of PPE on each flight through reviews of cargo
Airway bills, U.S Customs and Border Protection entry forms, distributor
inventory controls sheets, packing slips, and transportation provider shipping
reports. We also interviewed individuals responsible for maintaining the
tracker. We believe the data is sufficiently reliable for our reporting purposes.
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To determine the amount of PPE distributed by the distributors, we reconciled
FEMA’s Project Airbridge Tracker to the six medical distributors’ distribution
reports by flight date, flight number, and PPE type. Once reconciled, we
compared the distributor reports with FEMA’s prioritization bulletins andidentified shipments sent to prioritized areas using a combination of state andcounty codes and/or ZIP Codes. We determined the compliance rate bycomparing the amount of PPE distributed to FEMA designated locations to thetotal amount of Project Airbridge shipments on an individual flight and overall
distributor level. We compared our results to FEMA’s compliance reports andnoted any major discrepancies. Although we did not directly test the accuracyof the distribution reports to supporting documentation, we believe they are
sufficiently reliable for reporting purposes because we were able to reconcile
them to the Project Airbridge Tracker.
To determine the type of customer that received Project Airbridge supplies, we
reviewed and sorted distribution reports by the quantity of PPE distributed andselected the top 50 customers that received the most PPE from each of the
distributors. For each of the distributor’s top 50 customers, we usedcustomers’ names, addresses, and open-source research to identify customer
type. We continued customer type testing for all other reported distributions,to identify non-compliant distributions to other distributors and to non-medical
customers. We did this by searching known distributor names and nonmedical customers, such as non-medical retailers, corporations, salons, spas,
veterinary services, and other similar entities.
To determine the extent to which FEMA’s Project Airbridge shipments alleviateddisruptions in the distributor PPE supply chains, we analyzed Monthly
Distributor Volume reports prepared by the Supply Chain Control Tower.
These reports included distributor furnished data on their PPE inventory levels,
imports, and domestic distributions from March through July 2020. We wereable to partially validate Supply Chain Control Tower information. Specifically,
we determined the import amounts to be reasonable when compared tocorresponding PPE import reporting by the U.S. International Trade
Commission. Additionally, we contacted distributors and discussed the reports
to ensure information was accurate. Based on our analytical reviews, we
determined the data to be sufficiently reliable for our audit. We limited ourreview to gloves, masks, and gowns supply types because they consisted of 98
percent of supplies imported through Project Airbridge.
We conducted this performance audit between July 2020 and September 2022
pursuant to the Inspector General Act of 1978, as amended, and according to
generally accepted government auditing standards. Those standards requirethat we plan and perform the audit to obtain sufficient, appropriate evidence toprovide a reasonable basis for our findings and conclusions based upon our
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audit objectives. We believe that the evidence obtained provides a reasonablebasis for our findings and conclusions based upon our audit objectives.
The Office of Audits major contributors to this report are Ruth Blevins, Audit
Director; Armando Lastra, Audit Manager; Matthew Noll, Auditor-in-Charge;
Henry Kim, Auditor; Dennisse Lecaro, Program Analyst; Rolando Chavez,
Independent Reference Reviewer.

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Appendix A
FEMA Comments to the Draft Reportwww.oig.dhs.gov

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Appendix B
Map of Airbridge PPE Distributions

Source: DHS OIG Analysis of Medical Distributors’ Airbridge Compliance Reports

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Appendix C
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, Government Accountability Office/OIG Liaison Office
Under Secretary, Office of Strategy, Policy, and Plans
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
FEMA, Audit Liaison
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees

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Additional Information and Copies
To view this and any of our other reports, please visit our website at:www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General
Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov.
Follow us on Twitter at: @dhsoig.

OIG Hotline
To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and clickon the red "Hotline" ER[. If you cannot access our website, call our hotline at(800)323-8603, or write to us at:
Department of Homeland Security
Office of Inspector General, Mail Stop 0305
Attention: Hotline
245 Murray Drive, SW
Washington, DC 20528-0305