FEMA Should Recover 

$1.8 Million of $5.5 

Million in Public 

Assistance Grant Funds 

Awarded to Columbia 

County, Florida, for 

Tropical Storm Debby 

Damages 

November 2, 2016 

OIG-17-06-D 
 

 

 

DHS OIG HIGHLIGHTS
 

FEMA Should Recover $1.8 Million of 

$5.5 Million in Public Assistance Grant Funds 

Awarded to Columbia County, Florida, for

Tropical Storm Debby Damages
 

November 2, 2016 

Why We 

Did This Audit 

Columbia County, Florida 

(County) received a $5.5 

million net grant award from 

the Florida Division of 

Emergency Management 

(Florida), a Federal Emergency 

Management Agency (FEMA) 

grantee, for damages resulting 

from Tropical Storm Debby in 

June 2012. We audited 12 

projects for emergency and 

permanent work totaling $3.9 

million, or 71 percent of the 

$5.5 million awarded. 

What We 

Recommend 

FEMA should disallow 

$1,771,894 of ineligible costs 

and direct Florida to monitor 

the County’s performance for 

compliance with Federal grant 

requirements on open projects. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

What We Found 

The County generally accounted for FEMA funds 

on a project-by-project basis as required, but did 

not always follow Federal regulations and FEMA 

guidelines in spending the funds. We identified 

$1,771,894 (Federal share $1,328,921) of project 

costs that FEMA should disallow, which 

represents about 45 percent of the $3.9 million we 

reviewed. These costs consisted of the following 

amounts: 

x $1,563,780 of improper contract costs, of 

which $1,495,007 the County also did not 

adequately support; 

x $182,648 of unreasonable equipment costs; 

x $16,349 for small projects not completed; 

x $4,794 in ineligible labor costs; and 

x $4,323 of duplicate project costs. 

The findings we discuss in this report occurred 

primarily because the County was not fully aware 

of FEMA’s Public Assistance guidelines and grant 

administrative requirements. However, the grantee 

(Florida) is responsible for monitoring subgrant 

activities and ensuring that its subgrantee (the 

County) is aware of and complies with grant 

requirements. 

FEMA Response

FEMA officials concurred with our findings and 

recommendations. Appendix C includes FEMA’s 

written response in its entirety. 

www.oig.dhs.gvo OIG 17-06-D -
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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


November 2, 2016 


MEMORANDUM FOR: Gracia Szczech 

Regional Administrator, Region IV 

Federal Emergency Management Agency 

~1Vf.~ 

FROM: Thomas M. Salmon 

Assistant Inspector General 

Office of Emergency Management Oversight 

SUBJECT: FEMA Should Recover $1.8 Million of$5.5 Million in 

Public Assistance Grant Funds Awarded to Columbia 

County, Florida, for Tropical Storm Debby Damages 

Audit Report Number OIG-17-06-D 

We audited Public Assistance grant funds awarded to Columbia County, 

Florida (County). The Florida Division of Emergency Management (Florida), a 

Federal Emergency Management Agency (FEMA) grantee, awarded the County 

$5.5 million (net of insurance and other credits) for damages resulting from 

Tropical Storm Debby that occurred in late June 2012. The award provided 

75 percent FEMA funding for debris removal, emergency protective measures, 

and permanent restoration of damaged roads and facilities. We audited seven 

large and five small projects totaling $3.9 million (see appendix B, table 3).1 At 

the time of our audit, the County had completed work on all projects in our 

audit scope and submitted final claims to Florida for all project expenditures. 

Results of Audit 

The County generally accounted for FEMA funds on a project-by-project basis 

as required, but did not always follow Federal regulations and FEMA guidelines 

in spending the funds. We identified $1,771,894 (Federal share $1,328,921) of 

project costs that FEMA should disallow, which represents about 45 percent of 

the $3.9 million we reviewed. These costs consisted of the following amounts: 

1 Federal regulations in effect at the time of Tropical Storm Debby set the large project 

threshold at $66,400 [Notice of Adjustment of Disaster Grant Amounts, 76 Fed. Reg. 63933 

(Oct. 14, 2011)]. 

1 www.oig.dhs.gov OIG-17-06-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x $1,563,780 of improper contract costs, of which $1,495,007 the County 

also did not adequately support; 

x $182,648 of unreasonable equipment costs; 

x $16,349 for small projects not completed; 

x $4,794 in ineligible labor costs; and 

x $4,323 of duplicate project costs. 

The findings we discuss in this report occurred primarily because the County 

was not fully aware of FEMA’s Public Assistance guidelines and grant 

administrative requirements. However, the grantee (Florida) is responsible for 

monitoring subgrant activities and ensuring that its subgrantee (the County) is 

aware of and complies with grant requirements. 

Finding A: Improper and Unsupported Contract Costs 

The County did not comply with Federal procurement standards in awarding 

$1.6 million for five contracts for non-exigent work — four contracts for road 

repairs and one contract for debris removal activities.2 As a result, full and 

open competition did not always occur, which decreased opportunities for 

disadvantaged firms (small and minority firms, women’s business enterprises, 

and labor surplus area firms) to compete for federally funded work, and may 

have increased the risk of fraud, waste, and abuse. Finally, the County did not 

have adequate support for $1,495,007 of costs it claimed under the four road 

repair contracts. As a result, we could not validate the accuracy and eligibility 

of the road repair costs. We question all of the non-exigent contract costs 

totaling $1,563,780 as ineligible. We did not question $52,255 (see table 1) that 

the County claimed for exigent contract work because lives and property were 

at risk. 

Federal procurement standards at 44 Code of Federal Regulations (CFR) 13.36, 

in part, require that subgrantees — 

1. conduct procurement transactions in a manner providing full and open 

competition (44 CFR 13.36(c)); 

2. maintain a contract administration system that ensures contractors 

perform in accordance with the terms, conditions, and specifications of 

their contracts or purchase orders (44 CFR 13.36(b)(2)); 

2 The Uniform Administrative Requirements for Grants and Cooperative Agreements to State and 

Local Governments at 44 CFR 13 includes applicable Federal procurement standards. 

2 www.oig.dhs.gov OIG-17-06-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

3. take all necessary affirmative steps to assure the use of small and 

minority firms, women’s business enterprises, and labor surplus area 

firms, when possible (44 CFR 13.36(e)); 

4. include required provisions in all their contracts (44 CFR 13.36(i)); and 

5. use time-and-material type contracts only after determining that no 

other contract is suitable, and only if the contract includes a ceiling price 

(44 CFR 13.36(b)(10)). 

Table 1: Violations of Procurement Standards for Five Contracts 

Project(s) 

Contract 

Scope of 

Work 

Number 

of 

Contracts 

Contract 

Award 

Amount in 

Scope 

Exigent 

Work Not 

Questioned 

NonExigent 

Work 

Questioned 

Violation of 

Procurement 

Standards Listed 

Above 

1 2 3 4 5 

935, 1044 

& 1057 

Road 

Repairs 3 $1,151,088 $ 0 $1,151,088 X X X X 

935, 1044 

& 1057 

Road 

Repairs 1 343,919 0 343,919 X X X 

999 

Debris 

Removal 1 121,028 52,255 68,773 X X X 

Totals 5 $1,616,035 $52,255 $1,563,780 

Source: County procurement records and Office of Inspector General (OIG) analysis 

Inadequate Competition Ɇ The County awarded three of the five contracts 

without full and open competition. These three contracts were for road repair 

work totaling $1,151,088 (see table 1). The County solicited bids for road 

repairs from several contractors with whom it had pre-established 

relationships. However, the County should have advertised contract 

solicitations publicly, thus allowing all interested qualified contractors to 

compete for the federally funded work. Without full and open competition, 

FEMA has little assurance that the County obtained the best price for the 

contract work. Full and open competition also helps discourage and prevent 

favoritism, collusion, fraud, waste, and abuse. Further, adequate competition 

requires proper consideration of small businesses, minority firms, and women’s 

business enterprises. 

County officials agreed with this finding, but said that they believed the 

contract costs were reasonable. They also said only one local contractor in the 

area had the resources sufficient to handle a large disaster. Further, County 

officials said they determined in their subsequent research that there was only 

one contractor with a small business designation and there were no women- or 

minority-owned businesses in the county that were registered to do the 

contracted work. Despite the County’s assertions, we maintain that the County 

should have conducted a full and open competitive process to provide all 

3 www.oig.dhs.gov OIG-17-06-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

interested firms, local or otherwise, an opportunity to bid and participate in the 

disaster recovery work. 

Contract Administration System Ɇ The County did not have a sufficient 

contract review process to ensure that it properly executed contracts. As a 

result, three of the road repair contracts under Projects 935, 1044, and 1057 

contained the following deficiencies: 

x no contract execution date; 

x no documentation of agreed upon billing rates; 

x no description of the specific scope of services; and 

x incomplete terms of agreement section. 

Without appropriately executed contracts, the County did not have adequate 

means to enforce the terms of each agreement and did not have sufficient legal 

recourse in the event of a contractor dispute. 

County officials agreed with this finding, but said that they were not aware of 

either any issues with enforcing contract terms or legal disputes related to the 

contracts. 

Affirmative Steps Ɇ The County did not take the required affirmative steps to 

assure the use of disadvantaged firms when possible when soliciting bids for all 

five contracts in question. The required steps include using the services and 

assistance of the Small Business Administration and the Minority Business 

Development Agency of the Department of Commerce to solicit and use these 

firms. 

County officials agreed with this finding. Nevertheless, they said they 

determined in their subsequent research that there was only one contractor 

with a small business designation and there were no women- or minorityowned businesses in the county that were registered to do the contracted work 

performed. Despite the County’s assertions, we maintain our position that the 

County should have taken the required affirmative action steps to provide 

interested disadvantaged firms, local or otherwise, the opportunity to bid for 

the disaster recovery work. 

Required Contract Provisions Ɇ The County did not include all federally 

required provisions in all five contracts in question. These provisions ensure 

that contractors comply with applicable Federal requirements, policies, and 

mandates pertaining to employment, labor laws, the environment, and energy 

efficiency. These provisions also document the rights and responsibilities of the 

parties and minimize the risk of misinterpretations and disputes. 

4 www.oig.dhs.gov OIG-17-06-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

County officials agreed with this finding. 

Time-and-Material Type Contracts Ɇ The County competitively awarded one 

debris removal contract totaling $121,028 under Project 999 that did not 

comply with Federal contracting requirements regarding the use of time-andmaterial contracts. The contract did not include a ceiling price; and we found 

no evidence that the County considered using firm fixed-price or fixed-unitprice contracts, which FEMA considers more suitable for debris removal work. 

Furthermore, FEMA policy states that “time and materials contracts should be 

avoided, but may be allowed for work that is necessary immediately after the 

disaster has occurred when a clear scope of work cannot be developed and the 

work will not exceed 70 hours”.3 

This finding occurred because the County did not consider Federal 

requirements with respect to time-and-material contracting. We determined 

that the first 70 hours of work claimed under the contract were eligible based 

on FEMA’s guidelines for a reasonable exigency period. Thus, we did not 

question $52,255 of contract costs the County claimed for the first 70 hours of 

work. However, we question the remaining $68,773 as ineligible because the 

County should have negotiated a unit-price rate with the contractor after the 

first 70 hours of work to ensure reasonable project costs. 

County officials agreed with this finding, but said they believed the contract 

costs were reasonable. 

Inadequate Supporting Documentation Ɇ The County did not have adequate 

support for $1,495,007 of costs it claimed under the four road repair contracts. 

As a result, we could not determine whether the costs were valid and eligible. 

Federal cost principles (Cost Principles for State, Local, and Indian Tribal 

Governments) at 2 CFR 225, Appendix A, section (C)(1)(j), require costs to be 

adequately documented to be allowable under a Federal award. 

We reviewed the $1,495,007 of costs the County claimed for repairs on over 

350 roads (work sites). As support for its claim, the County provided (1) a 

separate spreadsheet for costs claimed for each project that listed costs by 

work sites; (2) contractor invoices that contained various charges for multiple 

projects; and (3) contractor payment records. However, the County did not 

provide a reconciliation or a cross-indexing of the work sites listed on the 

spreadsheet to specific invoices. County officials told us that a FEMA employee 

prepared the spreadsheets to allocate contractor costs to specific projects but 

3 FEMA 321, Public Assistance Policy Digest, January 2008, p. 23 

5 www.oig.dhs.gov OIG-17-06-D 
 

x

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

that he did not provide the County with any other type of documentation. As a 

result, we could not trace the costs listed on the spreadsheet to specific 

invoices to validate the accuracy and eligibility of the costs. Therefore, FEMA 

should disallow the $1,495,007 of unsupported costs unless the County 

provides sufficient documentation to support its claim. To avoid questioning 

the same costs twice, we included the $1,495,007 of unsupported costs in the 

amount we questioned for improper contracting. However, if FEMA allows the 

improper contracting costs, it should still disallow the unsupported costs 

unless the County provides additional documentation sufficient to support the 

costs. 

County officials agreed with this finding, but said they believed the contract 

costs were reasonable. County officials also said that the County has sufficient 

documentation to support the claimed costs and that they are in the process of 

organizing the support necessary to adequately document the work performed. 

Finding B: Unreasonable Equipment Costs 

The County’s claim of $200,435 under Project 812 for vehicles that its sheriff’s 

office used to perform emergency protective measures included $182,648 of 

unreasonable costs. According to Federal cost principles (Cost Principles for 

State, Local, and Indian Tribal Governments, OMB Circular A-87) at 2 CFR 225, 

Appendix A, section C.1.a., costs must be reasonable to be allowable under a 

Federal award. Section C.2 of the cost principles defines a reasonable cost as 

one that, in nature and amount, does not exceed that which a prudent person 

would incur under the circumstances prevailing at the time. We question the 

$182,648 of unreasonable equipment charges, as follows: 

The County claimed a total of $179,091 for the use of 63 police vehicles. 

The claim covered sheriff’s office activities for the period June 26, 2012, 

to July 19, 2012. The County calculated its claim using the FEMA 

Schedule of Equipment Rates and claimed each vehicle’s use at $16.25 

per hour based on the number of eligible daily work hours the officer 

worked on a given day. According to the FEMA Schedule of Equipment 

Rates, FEMA reimburses police vehicles used in patrolling activities at 

$0.60 per mile or at $16.25 per hour if used as barricades (stationary 

with engine running). In this case, regardless of the activity (patrolling or 

stationary), the County calculated the cost at the $16.25 hourly rate, 

which resulted in excessive or unreasonable costs. 

According to County officials, the sheriff’s office did not record vehicle 

mileage data or have vehicle activity logs that logged the County’s actual 

use of the vehicles (patrolling or barricades). They said that they did not 

6 www.oig.dhs.gov OIG-17-06-D 
x

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

keep such records because they relied on guidance from FEMA officials, 

who told them that FEMA would reimburse all vehicle use at an hourly 

rate. As a result, we could not estimate reasonable costs for the County’s 

actual use of the vehicles. Therefore, we question the $179,091. 

County officials disagreed that FEMA should disallow its entire claim for 

use of its police vehicles. They asserted that the officers drove their 

assigned vehicles at least 50 miles during each hour of their work shift, 

which would equate to $30 per hour using the FEMA mileage rate of 

$0.60 per mile. They said that this calculation would have resulted in a 

higher claim to FEMA than the actual claim of $16.25 per hour. 

However, County officials did not provide evidence to support their 

assertion. Therefore, our position remains unchanged. 

The County claimed $21,345 for use of four 11⁄2 ton pick-up trucks. 

However, the County mistakenly used the incorrect FEMA equipment 

rate to calculate its claim. According to the FEMA Schedule of Equipment 

Rates, FEMA reimburses 11⁄2 ton pick-up trucks at a rate of $25 per 

hour. Yet, the County claimed the pick-up trucks at $30 per hour. Using 

the correct rate of $25 per hour, the County should have claimed 

$17,788 (711.5 hours of use times $25), or $3,557 less than the amount 

it claimed 

County officials agreed with this finding. 

Finding C: Small Projects Not Completed 

The County’s claim included $16,349 for hazard mitigation work that it did 

not perform under three small projects. According to 44 CFR 206.205(a), 

failure to complete work under a small project may require the grant recipient 

to refund the Federal payment received for the work. In addition, according to 

FEMA’s Public Assistance Guide (FEMA 322, June 2007, pp.138-139), a grant 

recipient has 18 months from the disaster declaration date to complete work 

under permanent repair projects. Florida, as grantee, has the authority to 

grant extensions for an additional 30 months under extenuating 

circumstances, and FEMA may grant extensions beyond the grantee’s 

authority appropriate to the situation. 

The County received $16,349 of FEMA funding under three small projects to 

complete hazard mitigation work (pouring reinforced concrete and headwalls) 

to prevent future washout of roads the disaster damaged. However, as of June 

2016, or 3 years and 11 months after the disaster, the County could not 

provide evidence that it completed the $16,349 of hazard mitigation work, or 

7 www.oig.dhs.gov OIG-17-06-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

that Florida or FEMA granted the County time extensions to complete the 

work. Therefore, we question the $16,349 as shown in table 2. 

Table 2: Small Projects Not Completed 

Project 

Number 

Activities 

Not Implemented 

Amount 

Awarded/Received 

Amount 

Questioned 

997 Drew Road (reinforced concrete at 

headwall locations) $53,791 $5,328 

1050 Needmore Road (reinforced concrete at 

headwall locations) 43,737 7,824 

1064 Tommy Lites Road (reinforced concrete 

at headwall locations) 44,141 3,197 

Total $141,669 $16,349 

Source: FEMA project worksheets, County records, and OIG analyses 

County officials agreed with this finding. 

Finding D: Excessive Labor Costs 

The County’s labor claim of $126,681 for County personnel who performed 

work under Project 812 included $4,794 of excessive labor costs. According to 

44 CFR 13.20(b)(2) and (6), subgrantees must maintain accounting records 

that adequately identify the source and application of Federal funds and 

maintain source documentation to support those accounting records. In our 

analysis of payroll records that supported the County’s labor claim, we 

identified $4,794 of overtime costs that the County claimed but did not pay to 

employees. Therefore, we question the $4,794 that the County did not incur 

but claimed to the FEMA project. 

County officials agreed with this finding. County officials said that the FEMA 

project officer who wrote the project worksheet mistakenly changed the 

overtime hours that the County submitted for its claim. 

Finding E: Duplicate Project Costs 

The County’s claim included $4,323 of material costs the County mistakenly 

claimed more than once. The County claimed $54,620 of material costs under 

Project 937 for various emergency supplies such as sand bags, nails, and waste 

baskets that County employees used during the period June 26, 2012, to 

September 18, 2012. However, we identified purchases totaling $4,323 that the 

County inadvertently included in its claim multiple times. Therefore, we 

question the $4,323 as ineligible duplicate project costs. 

8 www.oig.dhs.gov OIG-17-06-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

County officials agreed with this finding. 

Finding F: Grant Management 

The findings we discuss in this report occurred primarily because the County 

was not fully aware of FEMA’s Public Assistance guidelines and grant 

administrative requirements. Nevertheless, the grantee (Florida) is responsible 

for monitoring subgrant activities and ensuring that its subgrantee (the 

County) is aware of and complies with grant requirements.4 Therefore, Florida 

should carefully review the $1.6 million the County claimed for projects outside 

the scope of our audit to ensure the costs are eligible and adequately 

supported. Florida should also provide technical assistance to the County to 

ensure it is aware of Federal grant requirements to prevent future 

noncompliance. 

Florida officials said they believed that their current oversight process provides 

adequate guidance to all applicants. They said their guidance includes the 

applicant briefing as well as training classes in Public Assistance, 

procurement, preliminary damage assessments, debris removal, environmental 

considerations, and insurance. Further, they said that Florida’s website 

(www.FloridaPA.org) includes detailed information on the Public Assistance 

program and that the funding agreement that the County signed also provided 

the County with detailed procurement information. However, we maintain that 

had Florida adequately monitored the County’s activities, it could have advised 

the County early on in the disaster that some of its methodologies (i.e., for 

procurement, contract cost support, and police vehicle use) were not in 

compliance with FEMA guidelines and Federal regulations. 

Recommendations 

We recommend that the Regional Administrator, FEMA Region IV: 

Recommendation 1: Disallow $1,563,780 (Federal share $1,172,835) of 

ineligible contract costs, unless FEMA grants an exception for all or part of the 

costs as 44 CFR 13.6(c) allows and determines the costs are eligible and 

reasonable. However, if FEMA allows the ineligible contract costs, it should 

disallow $1,495,007 of the costs as unsupported unless the County provides 

FEMA with adequate support for these costs (finding A). 

4 44 CFR 13.37(a)(2) and 44 CFR 13.40(a) 

9 www.oig.dhs.gov OIG-17-06-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation 2: Disallow as ineligible $182,648 (Federal share 

$136,986) in unreasonable equipment costs the County claimed unless FEMA 

determines that some or all of the costs we question are eligible and reasonable 

(finding B). 

Recommendation 3: Disallow as ineligible $16,349 (Federal share 

$12,262) of costs for small project work that the County did not complete 

unless the County provides additional evidence that it completed the work 

(finding C). 

Recommendation 4: Disallow as ineligible $4,794 (Federal share $3,596) 

of labor costs unless the County provides appropriate evidence that the costs 

are eligible (finding D). 

Recommendation 5: Disallow as ineligible $4,323 (Federal share $3,243) 

of duplicate project costs (finding E). 

Recommendation 6: Direct Florida to review carefully the $1.6 million the 

County claimed for projects outside the scope of our audit to ensure the costs 

are eligible and adequately supported (finding F). 

Recommendation 7: Direct Florida to provide technical assistance to the 

County to ensure it is aware of Federal grant requirements to prevent future 

noncompliance (finding F). 

Discussion with Management and Audit Follow-up 

We discussed the results of our audit with the County, Florida, and FEMA 

officials during our audit. We also provided a draft report in advance to these 

officials and discussed it at the exit conference held on September 15, 2016. 

We included the County’s comments, as appropriate, in the body of this report. 

FEMA Region IV provided a written response on October 13, 2016, agreeing 

with all seven recommendations contained in this report (see appendix C). The 

response indicated that FEMA expects to implement its proposed corrective 

actions to address all recommendations by December 9, 2016. Therefore, we 

consider all seven recommendations to be resolved, but open. We will evaluate 

for closure upon documentation that FEMA has implemented its proposed 

corrective actions. Please email closeout documentation and request to 

Carl.Kimble@oig.dhs.gov. 

10 www.oig.dhs.gov OIG-17-06-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The Office of Emergency Management Oversight major contributors to this 

report are David Kimble, Director; Adrianne Bryant, Audit Manager; 

Kim Lemon, Auditor-in-Charge; and John Schmidt, Program Analyst. 

Please call me with any questions at (202) 254-4100, or your staff may contact 

David Kimble, Director, Eastern Regional Office – South at (404) 832-6702. 

11 www.oig.dhs.gov OIG-17-06-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

We audited Public Assistance grant funds awarded to the County, FIPS Code 

023-99023-00. Our audit objective was to determine whether the County 

accounted for and expended Federal Emergency Management Agency (FEMA) 

funds according to Federal regulations and FEMA guidelines for Disaster 

Number 4068-DR-FL. The County received a Public Assistance grant award of 

$5.5 million (net of insurance and other adjustments) from the Florida, a FEMA 

grantee, for damages resulting from Tropical Storm Debby that occurred in 

June 2012. The award provided 75 percent FEMA funding for debris removal, 

emergency protective measures, and permanent repairs to roads and other 

facilities. The award consisted of 12 large projects and 13 small projects. 

We audited seven large projects and five small projects with net awards totaling 

$3.9 million (see appendix B, table 3). The audit covered the period June 23, 

2012, to August 16, 2016, during which the County claimed $3.9 million under 

the 12 projects in our audit scope. At the time of our audit, the County had 

completed work on the 12 projects, but had not submitted a final claim to 

Florida for all project expenditures. 

We interviewed County, Florida, and FEMA personnel; gained an 

understanding of the County’s method of accounting for disaster-related costs 

and its procurement policies and procedures; judgmentally selected and 

reviewed (generally based on dollar amounts) project costs and procurement 

transactions for the projects in our audit scope; reviewed applicable Federal 

regulations and FEMA guidelines; and performed other procedures considered 

necessary to accomplish our audit objective. 

As part of our standard audit procedures, we also notified our Office of 

Information Technology Audits of contracts the County awarded under the 

grant that we reviewed to determine whether the contractors were debarred or 

whether there were any indications of other issues related to those contractors 

that would indicate fraud, waste, or abuse. As of the date of this report, the 

Office of Information Technology Audits’ analysis of contracts was ongoing. 

When it is complete, we will review the results and determine whether 

additional action is necessary. We did not perform a detailed assessment of the 

County’s internal controls applicable to its grant activities because it was not 

necessary to accomplish our audit objective. 

12 www.oig.dhs.gov OIG-17-06-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A (continued) 

We conducted this performance audit between January and September 2016 

pursuant to the Inspector General Act of 1978, as amended, and according to 

generally accepted government auditing standards. Those standards require 

that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based upon our 

audit objective. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objective. To 

conduct this audit, we applied the statutes, regulations, and FEMA policies and 

guidelines in effect at the time of the disaster. 

13 www.oig.dhs.gov OIG-17-06-D 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Potential Monetary Benefits 

Table 3: Projects Audited and Questioned Costs 

Project 

Number 

FEMA 

Category 

of Work 5 

Type of 

Project 

Amount 

Awarded 

Amount 

Questioned 

75 Percent 

Federal 

Share Finding 

812 B Large $ 327,248 $ 187,442 $ 140,581 B, D 

935 C Large 801,381 643,657 482,743 A 

937 B Large 153,834 4,323 3,242 E 

999 A Large 264,510 68,773 51,580 A 

1044 C Large 511,920 437,305 327,979 A 

1057 C Large 557,012 414,045 310,534 A 

1062 B Large 1,041,912 0 0 

997 C Small 53,791 5,328 3,996 C 

1004 C Small 63,713 0 0 

1005 B Small 38,808 0 0 

1050 C Small 43,737 7,824 5,868 C 

1064 

 Totals 

C Small 44,141 

$3,902,007 

3,197 

$1,771,894 

2,398 

$1,328,921 

C 

Source: FEMA Project Worksheets, County records, and OIG analyses 

Table 4: Summary of Potential Monetary Benefits 

Type of Potential Monetary Benefit Amount Federal Share 

Questioned Costs – Ineligible $ 1,771,894 $ 1,328,921 

Questioned Costs – Unsupported 0 0 

Funds Put to Better Use 

Totals 

0 

$1,771,894 

0 

$1,328,921 

Source: OIG analysis of findings in this report 

5 FEMA classifies disaster-related work by type: debris removal (Category A), emergency 

protective measures (Category B), and permanent work (Categories C through G). 

14 www.oig.dhs.gov OIG-17-06-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

FEMA Management Response 

D o.bcr ll, 2016 

Stl B:JEGT: Marragemcn: RcipOMl.l o Dmll Re:,ll<lti 

w	FE!M ~lm1ifd Jhica...u $I fl iflllla qfSU Hllllon ·11 

PJ,ibllc .fi1'Cli.l'.tann NJ , mtb. A •artled la ColumbJa 

Ca,r.1r:rn F'larJdu, for Trop~ Sf!N'TI• Dtb&2 Dumagμ, " 

FEMA Dfml~ 4W!i-.DR·FL 

Drnft ;\u.dil lb:J~llt NUlnber. 010-l fi..XX-D 

Than&. you fQI" Uoie opportunitv In revil!W llI1d mrnmcot nn this dni.ft: rupmt Th~ U Depi!mnent 

Qrfo!cr.n~l11nd 91et:url.I:)'' Fcdetal Jiim:lfl!L".Ht}' M~m:!il\Agency (DR.S-FEMAJ eppn:i::iatc» ti]&: 

of'lhi: Offie.e of '1~ lm" Genensi (0 a} in p~tmnhig and airtdllicttn!! ~'lfe'\11 and UIJlng

ml& repc!rL 

Th-= DHs-FEMA 5llletlglhcning i~o;r,ith implementing • Pubf!A: A~e 

P(O!lfllm ln urde~ lo prom111!:: cuailit~y i!nd tramparnri~ i:n [!!g ~en!' mm i:rifi~ 

d!ab~El~ affederiil fvnds.. Dfls-FEMA ill cammined lo lllCCll:SBfull; . ptemenIDig me 

Puhtk A!!:!il:!tllm:i= program la 1155t!.I c;nPJmi.mitie!I in rti:OYl!Jil1g fina:i the i,ki\•llS!Sling elf«l5 of 

dl~b)" pmt; lifn11, 11Sri~ ru 1111 ~mcli::nt. e!Tectfvc. CO~l llDd 11!1.oner-frl~IW 

JmlDDl:r wh& lllmlrlng !:he 1!ppropri1111!.*Wll(d:ilr'ip a rfM.P&)ICr i;foll11~ 

DH '•FEMA toneun with eoch oflh dmft n:pDll·.i ~ven reeommmda:liom.. PlCUe RC th~ 

auaclred.Ior O\lI" deudli:d l"i=i;!pCll!SC to each 1HDilllJlendalillll 

Ai;ain; we dwn.k yau fbrtheoppo:Qlln:~ ID n::v1cwM!d i:ommcm 011 di!. drafl "'JlOfL lc!:hnical 

t!nlluMlllll were pn?Yioual)· proYi!.'.!a:I unde( !l~mVtt. Pl- fi!i:l fitre lll a1111l!lat m~ if mJ. 

fl~lll'IY Q~tlllll- WI! look t1J "Md Q l;lfO \mg wlb ypu again in tbe futuru. 

15 www.oig.dhs.gov 	 OIG-17-06-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

 Appendix C (continued)
 

16 www.oig.dhs.gov OIG-17-06-D
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C (continued)
 

17 www.oig.dhs.gov OIG-17-06-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Chief of Staff 

Chief Financial Officer 

Under Secretary for Management 

Chief Privacy Officer 

Audit Liaison, DHS 

Federal Emergency Management Agency 

Administrator 

Chief of Staff 

Chief Financial Officer 

Chief Counsel 

Chief Procurement Officer 

Director, Risk Management and Compliance 

Audit Liaison, FEMA Region IV 

Audit Liaison, FEMA (Job Code G-16-017) 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

External 

Executive Director, Florida Division of Emergency Management 

State Auditor, Florida 

Emergency Management Director, Columbia County 

County Manager, Columbia County 

18 www.oig.dhs.gov OIG-17-06-D 
 

 

 

 

 

 

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