Additional Controls Needed 

to Better Manage 

FEMA’s Transitional 

Sheltering Assistance Program 

March 29, 2019 

OIG-19-37 
 

 

DHS OIG HIGHLIGHTS
 

Additional Controls Needed to Better Manage 

FEMA’s Transitional Sheltering Assistance Program 

March 29, 2019 

Why We Did 

This Audit 

This interim report is part 

of an ongoing audit to 

determine the extent FEMA 

is meeting disaster 

survivors’ transitional 

shelter needs after the 

California wildfires and 

Hurricanes Harvey, Irma, 

and Maria in 2017. 

What We 

Recommend 

This report contains no 

recommendations. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

During our ongoing audit of the Federal Emergency 

Management Agency (FEMA) Transitional Sheltering 

Assistance (TSA) program, we determined that FEMA does 

not require disaster survivors to notify the agency when 

they vacate hotels participating in the TSA program, thus 

allowing the hotels to continue to bill FEMA for 

unoccupied rooms. Because FEMA is unaware when 

disaster survivors vacate the hotels, the agency does not 

know the magnitude of unnecessary hotel charges. 

Consequently, FEMA could not account for associated 

TSA payments it may have paid since August 2017, 

related to the 2017 hurricane season and California 

wildfires. 

Additionally, FEMA does not include its Office of the Chief 

Security Officer Tip Line information on the TSA Terms 

and Conditions form used by hotels and disaster 

survivors; nor does it require hotels to provide disaster 

survivors with copies of the completed forms. 

Unless FEMA requires notification of hotel departures, it 

increases its risks of paying for unoccupied hotel rooms. 

These issues may affect FEMA’s ability to detect potential 

fraud, waste, and abuse of TSA program funds, as well as 

survivors’ ability to comply with TSA requirements. 

FEMA Response 

FEMA agreed with our initial findings and has initiated 

actions to improve the TSA program. 

www.oig.dhs.gov OIG-19-37 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Washington, DC 20528 / www.oig.dhs.gov 

March 29, 2019 

MEMORANDUM FOR: Keith Turi 

Assistant Administrator, Recovery 

Federal Emergency Management Agency 

FROM: Sondra F. McCauley 

Assistant Inspector General for Audits 

SUBJECT: Additional Controls Needed to Better Manage FEMA’s 

Transitional Sheltering Assistance Program 

For your action is our interim report, Additional Controls Needed to Better 

Manage FEMA’s Transitional Sheltering Assistance Program. Because our full 

audit remains ongoing, we are not making recommendations in this interim 

report, but we identify actions the Federal Emergency Management Agency 

(FEMA) can take to strengthen internal controls to prevent and better detect 

potential fraud, waste, and abuse. We considered FEMA’s technical comments 

and incorporated the formal comments in this final interim report. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our interim report to congressional committees with oversight 

and appropriation responsibility over the Department of Homeland Security. 

We will post this final interim report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Katherine Trimble, 

Deputy Assistant Inspector General for Audits, at (202) 981-6000. 

www.oig.dhs.gov 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

Under the Transitional Shelter Assistance (TSA) program, the Federal 

Emergency Management Agency (FEMA) provides transitional sheltering in 

hotels for individuals displaced by emergencies or major disasters. Providing 

hotel lodging reduces the number of disaster survivors housed in congregate 

shelters.1 Once FEMA notifies disaster survivors of their eligibility for the TSA 

program, the survivors are responsible for locating available rooms at 

participating hotels. 

To verify applicant eligibility, FEMA requires hotel personnel and disaster 

survivors to complete TSA Terms and Conditions forms with the survivors’ 

information, FEMA registration number, check-in date, signature, and date 

acknowledging acceptance of TSA program requirements. Appendix B contains 

an example of a TSA Terms and Conditions form. 

After Hurricanes Harvey, Irma, Maria, and the California wildfires in 2017, 

FEMA activated TSA programs in Texas, Florida, Puerto Rico, and California. 

Table 1 shows the number of households served through TSA programs by 

state or territory and associated costs. 

Table 1. TSA Households and Total Expenditures from August 2017 

to September 2018 

State (Disaster Declaration Number) Households 

Total Estimated 

Expenditures 

California (4344) 646 $3,667,865 

Florida (4337) 27,332 $119,058,404 

Puerto Rico (4336 & 4339) 7,024 $105,586,586 

Texas (4332) 54,640 $414,181,611 

Total 89,642 $642,494,466 

Source: FEMA TSA Expense Summary Sheets for listed disasters 

FEMA Paid TSA Hotels for Unoccupied Rooms 

Since August 2017, FEMA has paid hotels in the TSA program for an unknown 

number of unoccupied rooms. Internal controls over financial reporting should 

help safeguard assets from waste, loss, unauthorized use, or misappropriation, 

as well as ensure compliance with laws and regulations pertaining to financial 

1 FEMA defines congregate shelters as any private or public facility that provides contingency 

congregate refuge to evacuees, but which day‐to‐day serves a non‐refuge function, such as 

schools, stadiums, and churches (or church‐sponsored residences or facilities). 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

reporting.2 Although FEMA requires disaster survivors to sign and date TSA 

Terms and Conditions forms upon check-in, it does not require them to 

document or notify FEMA or hotel personnel when they check out of their 

rooms. Consequently, FEMA officials indicated it is difficult to know when 

disaster survivors leave the hotels and which dates of occupancy are billable. 

FEMA provided five examples of disaster survivors leaving the TSA program 

since August 2017 without notifying hotel personnel or FEMA. Although the 

disaster survivors were no longer at the hotels, the hotels continued to bill 

FEMA for the rooms in all five cases. Our analysis showed that FEMA paid 

about $4,700 to TSA hotels for these unoccupied rooms for a total of 41 nights. 

FEMA is uncertain about the magnitude of unnecessary payments related to 

the 2017 hurricane season and across all disasters since August 2017. 

FEMA Does Not Provide Tip Line Information on Its TSA Terms and 

Conditions Form 

Our review of FEMA’s TSA Terms and Conditions form revealed that FEMA did 

not provide disaster survivors and TSA hotels with the Office of the Chief 

Security Officer Tip Line3 information for reporting allegations of fraud, waste, 

and abuse. According to one TSA hotel manager in Kansas, local police used a 

warrant to execute a search of a disaster survivor’s hotel room and uncovered 

evidence of fraud against FEMA and the TSA program. However, the hotel 

manager did not report the incident to FEMA because he was not aware of the 

requirement or of the existence of the Office of the Chief Security Officer Tip 

Line. Further, FEMA does not require hotel personnel to provide disaster 

survivors with copies of their completed TSA Terms and Conditions forms, 

which may affect survivors’ ability to comply with TSA requirements or timely 

report fraud, waste, and abuse. 

According to the Government Accountability Office’s Fraud Framework, 

reporting mechanisms such as hotlines can help managers detect instances of 

potential fraud and deter individuals from engaging in fraudulent behavior. 

FEMA’s Office of the Chief Security Officer Tip Line is the primary mechanism 

for directly reporting allegations of fraud, waste, and abuse related to FEMA 

programs. DHS Management Directive 810.1 requires FEMA to promptly advise 

DHS OIG of allegations of misconduct. 

2 OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and 

Internal Control (2016) – Reporting on Internal Controls, VI at 41 (Definition of Material 

Weakness). 

3 FEMA officials sometimes refer to the Office of the Chief Security Officer Tip Line as the FEMA 

Disaster Fraud Hotline. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Until FEMA ensures disaster survivors receive copies of the TSA Terms and 

Conditions form with the FEMA information, disaster survivors may lack 

awareness on how to report potential fraud in FEMA programs. Unreported 

fraud can limit FEMA’s and the OIG’s ability to prevent, detect, and deter 

fraud, waste, and abuse of Federal programs and funds. 

Conclusion 

FEMA could benefit by requiring, as a condition of the TSA program, that 

disaster survivors and hotel personnel immediately document or notify FEMA 

when disaster survivors vacate hotels. Inclusion of FEMA’s Office of the Chief 

Security Officer Tip Line information on the TSA Terms and Conditions form 

could also ensure disaster survivors and hotels have the information needed to 

report allegations of waste, fraud, and abuse in the TSA program. Additionally, 

hotels should provide copies of their completed TSA Terms and Conditions 

forms to disaster survivors. 

We are continuing our audit work in this area. We will include formal 

recommendations on these issues in our full audit report. 

Management Comments and OIG Analysis 

FEMA provided written comments to our draft report. We included a copy of 

FEMA’s management comments in their entirety in appendix A. We also 

received technical comments and revised our report as appropriate. 

FEMA Management Comment: FEMA management noted that it has initiated 

changes to improve FEMA’s ability to detect potential fraud, waste, and abuse 

of TSA funds. The changes include adding a fraud hotline number to the TSA 

Terms and Conditions form and working with its contractor to encourage 

lodging providers to give a copy of the form to disaster survivors at check in. 

Additionally, FEMA acknowledged that while it currently has no requirement 

for disaster survivors to notify FEMA when they vacate lodging, it monitors 

hotel check-in and check-out data provided by the lodging contractor. 

OIG Response: We commend FEMA for adding a fraud hotline number to the 

TSA Terms and Conditions form to address one issue we identified in this 

report. We also appreciate FEMA’s efforts to monitor survivors’ hotel check-in 

and check-out data provided by the lodging contractor to ensure they fall 

within TSA eligibility timeframes. However, monitoring the data alone will not 

suffice to alert FEMA of instances where survivors leave their rooms 

unoccupied before their eligibility periods expire, without checking out with the 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

hotels. As noted in our report, requiring survivors to notify FEMA of their 

departures may help ensure FEMA does not continue to pay hotels 

unnecessarily for unoccupied rooms. We will address in our full audit report 

FEMA’s corrective actions in response to this interim report. 

Objective, Scope, and Methodology 

We are issuing this interim report as part of an ongoing audit to determine the 

extent FEMA is meeting transitional sheltering needs of disaster survivors of 

Hurricanes Harvey, Irma, and Maria and the California wildfires in 2017. To 

report on FEMA’s TSA program, we interviewed officials from FEMA’s Fraud 

Prevention and Investigations Branch, Individual Assistance Division, Finance 

Center, and Program Support Branch. We interviewed executives from the TSA 

contract vendor. We reviewed and analyzed key internal FEMA documentation, 

including Individuals and Households Program Unified Guidance (September 

2016), Fraud Prevention & Investigations Branch’s Draft 2016 TSA Program 

Review, FEMA’s operational draft Transitional Sheltering Assistance 

Playbook/SOP (2017), and FEMA’s TSA Terms and Conditions forms used 

during 2017 for the TSA program. 

The DHS Office of Inspector General (OIG) was established by the Homeland 

Security Act of 2002 (Public Law 107−296) by amendment to the Inspector 

General Act of 1978. We performed this audit work in accordance with OIG 

policies and procedures and under the authority of the Inspector General Act of 

1978. This report does not contain recommendations. 

Office of Audits major contributors to this interim report are Yesi Starinsky, 

Director; Andrew Smith, Audit Manager; James Lloyd, Auditor-in-Charge; 

Lauren Bullis, Auditor; Stefanie Holloway, Auditor; Corinn King, Auditor; 

Jessica Makowski, Program Analyst; James Townsend, Program Analyst; 

Deborah Mouton-Miller, Communications Analyst; and John Skrmetti, 

Independent Referencer. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

FEMA Comments to the Interim Report 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

FEMA Terms and Conditions Form Example 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

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 

www.oig.dhs.gov 9 OIG-19-37 
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 click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, 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