FEMA Needs to Improve 

Its Oversight of the 

Sheltering and Temporary 

Essential Power Pilot 

Program 

February 10, 2017 

OIG-17-38-D 
 

 

 

DHS OIG HIGHLIGHTS 

FEMA Needs to Improve Its Oversight of the 

Sheltering and Temporary Essential Power Pilot Program
 

February 10, 2017 

Why We 

Did This Audit 

Following Hurricane Sandy, the New 

York City, Department of Environmental 

Protection (New York City) received 

$537.94 million in Federal Emergency 

Management Agency (FEMA) Public 

Assistance grant funds for temporary 

power, heat, and hot water so residents 

could shelter-in-place. 

In January 2013, FEMA estimated New 

York City would spend $14.33 million of 

this essential assistance on repairs to 

multifamily structures, including 

properties with commercial owners or 

operators. 

Our objective was to determine the 

extent FEMA identified and received 

reimbursement due from New York City 

for Federal funds it spent on repairs to 

commercial residential properties. 

What We 

Recommend 

FEMA should review and improve, as 

necessary, policies and procedures that 

protect government resources used to 

support disaster response and recovery 

activities. 

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 

Although more than 3 years have passed 

since the completion of the work, FEMA has 

not identified and recovered Federal funds 

New York City spent on repairs to 

commercial residential properties. These 

repairs included short-term measures such 

as temporary boilers and power generators. 

This occurred because FEMA’s records were 

incomplete and the New York State Division 

of Homeland Security and Emergency 

Services (New York State) has not provided 

FEMA with a final accounting of costs for the 

work. Furthermore, FEMA has no 

procedures to independently identify 

commercial residential properties New York 

City had assisted with Federal funds. 

FEMA recognizes that commercial landlords 

may have received an incidental benefit from 

the Federal assistance provided to New York 

City and used for repairs to multifamily 

dwellings to ensure tenants could shelter in 

their homes. However, it is the responsibility 

of New York State (the grantee) to ensure 

that the money that FEMA provides is spent 

in accordance with Federal laws and 

regulations. Under FEMA rules, for-profit 

organizations are ineligible for Public 

Assistance grant funds. 

FEMA Response 

FEMA concurred with all three of our 

recommendations. 

www.oig.dhs.gov OIG-17-38-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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


February 10, 2017 


MEMORANDUM FOR: Corey Gruber 

Acting Associate Administrator, Response and Recovery 

Federal Emergency Management Agency 

Michael Byrne 

Acting Regional Administrator, Region II 

Federal Emergency Management Agency 

~?vt·~ 

FROM: 	 Thomas M. Salmon 

Assistant Inspector General 

Office of Emergency Management Oversight 

SUBJECT: 	 FEMA Needs to Improve Its Oversight ofthe Sheltering 

and Temporary Essential Power Pilot Program 

Audit Report number OIG-17-38-D 

We audited FEMA efforts to identify and obtain reimbursement due from the 

New York City, Department of Environmental Protection (New York City) for 

Public Assistance grant funds it spent on repairs to commercial residential 

properties such as multifamily buildings that were owned by commercial 

entities.1 The New York State Division of Homeland Security and Emergency 

Services2 (New York State), a FEMA grantee, awarded New York City 

$537.94 million3 for emergency protective measures such as temporary power, 

heat, and hot water so residents could shelter-in-place following Hurricane 

Sandy. FEMA made this assistance available to both single family and 

multifamily dwellings. As of July 7, 2016, the end of our audit, FEMA did not 

have a final accounting for the work or procedures in place to independently 

identify properties where New York City assisted with Federal funds. 

Background 

When Hurricane Sandy made landfall on October 29, 2012, the high winds and 

storm surge caused extensive coastal flooding and power outages across New 

York City including the boroughs of the Bronx, Brooklyn, Manhattan, Queens, 

and Staten Island. A substantial number of single family and multifamily 

1 This includes short-term measures such as temporary boilers and power generators. 

2 FEMA records identify the entity as the New York Office of Emergency Management. 

3 Rounded down from $537,940,357.85 (90% Federal share of project costs totaling 

$597,711,508.72) 

www.oig.dhs.gov 1 	 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

structures sustained damage to electrical, heating, and hot water systems. This 

included both private and commercial residential properties. As noted in the 

timeline (figure 1), the President issued a major disaster declaration on 

October 30, 2012, and authorized Federal Emergency Management Agency 

(FEMA) assistance for the affected areas. FEMA provided $537.94 million to 

help New York City implement two large “shelter-in-place” projects that enabled 

disaster survivors to stay in their own homes by providing emergency protective 

measures such as temporary repairs to affected electrical, heating, and hot 

water systems. 

In the wake of Hurricane Sandy, FEMA, working with New York State and New 

York City, decided to make these repair services (Rapid Repairs) available to 

multifamily structures like apartment buildings, which house a significant 

number of New York City residents. Additionally, FEMA expanded the repair 

services to include short-term measures such as temporary boilers and power 

generators. FEMA made these decisions so that temporary repairs could be 

made and residents could safely shelter-in-place ahead of the imminent winter 

season. As a condition of this assistance, New York City (applicant) agreed to – 

Make reasonable efforts when appropriate and allowed for under 

state and local laws to compel commercial building 

owners/operators to make permanent repairs to health and safety 

hazards and other housing code violations addressed by FEMAfunded emergency protective measures under this initiative, and to 

recover from commercial owners any Federal funds expended on 

emergency protective measures for facilities they own or 

operate...should the applicant obtain reimbursement from the 

building owner for costs associated with the emergency work 

performed, the applicant must reimburse FEMA the federal share 

of costs associated with the work. 

In January 2013, FEMA estimated that New York City’s total spending on 

emergency protective measures for multifamily structures at $14.33 million.4 

By April 2013, all Rapid Repairs work ended. In September 2013, at New York 

City’s request, FEMA and New York State agreed to consolidate the two large 

“shelter-in-place” projects into one project.5 The stated goal of the consolidation 

was to maximize project administration efficiencies and minimize complicated, 

cross-project accounting since the same contractors had worked on both. 

According to FEMA records, reasons include “the fact that overhead program 

costs would be too difficult to separate by two PWs” (i.e., the two projects). 

4 Rounded up from $14,325,860 

5 Two large projects that were subsequently combined: PA-02-NY-4085-PW-00012 (FEMA 

Sheltering and Temporary Essential Power Pilot program assistance) and PA-02-NY-4085-PW00013 (Section 403 Emergency Protective Measures for Multifamily Dwellings). 

www.oig.dhs.gov 2 OIG-17-38-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1: Timeline of New York City’s Large “Shelter-in-Place” Projects 

 Hurricane Sandy Makes Landfall - October 29, 2012 

 Major Disaster Declaration - October 30, 2012 

 Rapid Repairs Announced - November 9, 2012 

 FEMA Issues Guidance on its Sheltering and Temporary Essential 

Power (STEP) Pilot Program - November 16, 2012 

 DHS OIG Issues a Letter Report on the FEMA STEP Pilot Program 

(OIG-13-15) - December 7, 2012 

 FEMA Issues Additional Guidance on STEP Pilot Program - 

December 13, 2012 

 Approximately 818 Multifamily Structures Needed Repairs as a

Result of Hurricane Sandy - December 20, 2012 

 FEMA Issues Guidance on Emergency Protective Measures for 

Multifamily Dwellings - December 27, 2012 

 FEMA Estimates $14.33 million in Emergency Protective Measures

for Multifamily Structures - January 30, 2013 

 Federal Coordinating Officer Opposes Consolidation of Two Large 

"Shelter-in-Place" Projects - February 28, 2013 

 Rapid Repairs Work Ends - March 31, 2013 

 Agreement to Consolidate Two Large "Shelter-in-Place" Projects 

into One Project - September 26, 2013 

 FEMA Disbursed more than $537.94 million in Federal Funds for 

the Consolidated "Shelter-in-Place" Projects - April 4, 2016 

Source: Office of Inspector General (OIG) analysis of FEMA records 

www.oig.dhs.gov 3 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

Less than a month after Hurricane Sandy devastated communities on the 

Atlantic coast, FEMA quickly implemented the STEP Pilot Program. This 

urgently needed program provided the emergency assistance necessary to save 

lives, protect public health and safety, and protect property. Nevertheless, 

FEMA should improve its management oversight to more effectively protect 

against the vulnerabilities associated with implementing pilot programs. 

Specifically, FEMA has not identified and recovered Federal funds New York 

City spent more than 3 years ago on emergency protective measures, 

incidentally benefiting commercial residential properties. This occurred 

because FEMA’s records were incomplete and the New York State Division of 

Homeland Security and Emergency Services (New York State) has not provided 

FEMA with a final accounting of costs for the work. Furthermore, FEMA has no 

procedures to independently identify commercial residential properties New 

York City had assisted with Federally-funded emergency protective measures 

such as temporary repairs to affected electrical, heating, and hot water systems 

or short-term measures such as temporary boilers and power generators. 

FEMA Has Not Initiated Action to Identify or Collect Money 

Although all Rapid Repairs work ended on March 31, 2013, and 

$537.94 million was disbursed to New York State for the work, FEMA has not 

received a final accounting and certification of costs for the work. This occurred 

because project closeout has not started.6 However, New York City has made 

no payments to any Rapid Repairs contractors since October 15, 2014. 

FEMA officials told us that their expectations for receiving a final accounting 

and certification of costs vary based upon circumstances affecting the event 

and the specific projects. They noted that in an event the size and complexity of 

Hurricane Sandy, the timeframe is longer. They also cited factors such as New 

York City’s building types and sheer number of eligible residents added to the 

timeline for reporting. The officials further stated that, given the high level of 

devastation caused by Hurricane Sandy, their focus was on recovery efforts 

such as the restoration of basic infrastructure. 

6 During project closeout, FEMA conducts a final review for compliance with the terms and 

conditions of assistance provided. This includes ensuring that New York City made “reasonable 

efforts when appropriate and allowed for under state and local laws to compel commercial 

building owners/operators to make permanent repairs to health and safety hazards and other 

housing code violations addressed by FEMA-funded emergency protective measures under this 

initiative, and to recover from commercial owners any Federal funds expended on emergency 

protective measures for facilities they own or operate.” 

www.oig.dhs.gov 4 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Nevertheless, because more than 3 years have passed since the completion of 

the work, FEMA is at an increased risk of not being able to recover these funds. 

We are concerned FEMA officials are not displaying a sense of urgency in 

accounting for and recovering Federal taxpayer funds invested in the effort 

given that: 

x	 Commercial property owners change or exit the business. 

x	 Federal funds may have been spent on unauthorized repairs. 

x	 Expenditures of Federal funds for emergency protective measures may 

not be adequately supported. 

We identified at least six residential properties that received more than 

$520,000 worth of Rapid Repairs work as having changed ownership following 

Hurricane Sandy: 

x	 Two limited liability companies (LLC) benefiting from more than 

$129,681 in Rapid Repairs work transferred their repaired properties to 

other LLCs. 

x	 One for-profit corporation benefiting from $33,146 in Rapid Repairs work 

transferred its repaired property to an LLC. 

x	 A Florida-based LLC benefiting from $3,165 in Rapid Repairs work 

transferred its repaired property to an individual and subsequently 

exited the business. 

x	 An individual benefiting from more than $56,206 in Rapid Repairs work 

transferred the repaired property to a non-profit corporation. 

x	 One individual receiving more than $300,000 in Rapid Repairs work, 

including electrical conduit and wiring repairs totaling $70,650, 

transferred the repaired property to an LLC. 

Federal regulations7 require that an accounting 

of costs for the work be submitted “as soon as 

practicable” after a large project has been 

completed and payment requested. This 

includes a certification that reported costs were 

incurred in the performance of eligible work; the 

approved work was completed; the project is in 

FEMA standard operating 

procedures set a target 

date for submitting an 

accounting of costs 

90 days after a large 

project is complete. 

7 44 Code of Federal Regulations (CFR) 206.205(b)(1) 

www.oig.dhs.gov 5	 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

compliance with the provisions of the FEMA-State Agreement; and payments 

for the project have been made in accordance with 44 CFR 13.21. 

At the end of our audit engagement, New York State had not submitted a final 

accounting and certification of costs for the work to FEMA. Once FEMA 

receives the final accounting of cost and closeout of the project begins, FEMA 

should be able to identify the amount it needs to collect from New York State 

and New York City. In accordance with standard Federal regulations and the 

FEMA-New York State Disaster Assistance Grant Agreement, it is New York’s— 

not FEMA’s—responsibility to monitor and oversee the expenditure of disaster 

assistance funds.8 

FEMA Has Not Performed Adequate Monitoring and Oversight 

FEMA officials reported that they did not know whether New York State or New 

York City had collected any money from the owners of the assisted properties. 

This occurred because other than the final compliance review at project 

closeout, FEMA does not have procedures in place for the timely identification 

and recovery of Federal funds incidentally benefiting commercial landlords. 

Additionally, FEMA records for properties receiving Rapid Repairs work are 

incomplete. When we ended our audit engagement on July 7, 2016, we found 

no information in FEMA records regarding any amount of money owed by 

commercial property owners or any related collection efforts. FEMA anticipates 

receiving the necessary records from New York State and New York City when 

the closeout process commences. 

FEMA records and New York City records in FEMA’s possession only accounted 

for 5,641 single family and multifamily dwellings that received an estimated 

$195.12 million in assistance through Rapid Repairs. Our review of these 

records disclosed that 157 of the properties were registered in New York City as 

multiple dwellings with 3 or more residential units or private dwellings with 

1 or 2 residential units where neither the owner nor the owner's immediate 

family resided.9 New York City provided these 157 properties with at least 

$7.34 million in temporary electrical, heating, and hot water system repairs. 

According to FEMA, it expects that New York State will submit complete 

documentation for final accounting and project closeout. 

FEMA Records Did Not Separate Private and Commercial Residential Properties 

FEMA did not maintain records separating private and commercial residential 

properties assisted through Rapid Repairs. As a result, FEMA cannot easily 

determine the amount New York City spent on commercial residential 

properties and owes FEMA. 

8 44 CFR 13.20(a) and 44 CFR 13.40(a)
 9 As of August 27, 2015, excluding housing co-operatives and condominiums
 

www.oig.dhs.gov 6 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

According to the Federal Coordinating Officer, 

while the types of work provided for single 

family and multifamily dwellings through 

Rapid Repairs were similar in nature, they 

were provided under separate program 

guidelines and the “logical option” was to 

document each project’s costs accordingly. 

For-profit organizations such as commercial landlords are ineligible for Public 

Assistance grant funds. However, New York City (through New York State) was 

eligible to receive Federal disaster assistance to perform emergency protective 

measures allowing residents to shelter-in-place. FEMA, New York State, and 

New York City proactively enabled renters such as apartment building tenants 

to shelter-in-place by providing temporary repairs, including short-term 

measures such as temporary boilers and power generators. To avoid 

subsidizing repairs that are the responsibility of commercial residential 

property owners and their insurance companies, FEMA required New York City 

to make reasonable efforts to recover the Federal share of repair costs from the 

owners and to return the funds to FEMA. 

FEMA Does Not Have Records to Independently Verify Information 

FEMA officials were unable to locate 26 of 45 work orders for properties 

identified as having received temporary electrical, heating, and hot water 

system repairs. The total invoiced costs associated with the missing work 

orders was more than $2.05 million. According to FEMA officials, their efforts 

to respond to our data requests were “more difficult than anticipated as the 

format and details associated with various source documents varied.”10 

Because FEMA does not have the records to independently verify amounts 

provided for repairs to commercial residential properties, it must rely on 

records kept by New York State and New York City. 

This occurred although the Federal Coordinating Officer had emphasized the 

importance of closely monitoring and documenting all of the costs associated 

with the Rapid Repairs work. OIG cautioned FEMA in December 2012 about 

the need to (1) maintain strong internal controls given the number of 

individuals affected by Hurricane Sandy; and (2) address vulnerabilities 

associated with implementing pilot programs such as STEP.11 However, at the 

end of our audit engagement, FEMA still did not have adequate policies and 

procedures for protecting government resources used to support disaster 

response and recovery activities that did not fit standard grant conditions. 

10 Included in FEMA’s response, dated February 12, 2016, to our written data requests of 

October 21, 2015, and December 8, 2015 

11 FEMA’s Sheltering and Temporary Essential Power Pilot Program, OIG-13-15, December 2012 

www.oig.dhs.gov 7 OIG-17-38-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Consistent with standard grant management closeout processes, FEMA plans 

to verify the records provided by New York State and New York City as part of 

the project’s closeout. 

According to the Government Accountability Office’s Standards for Internal 

Control in the Federal Government, the accurate and timely recording of 

transactions and events is a key internal control activity. The prompt recording 

of a transaction, through its entire life cycle, is critical in maintaining its 

relevance and value to management in controlling operations. This includes 

clearly documenting all transactions and ensuring that the documentation is 

readily available for examination. This was not the case with Federal funds New 

York City spent on repairs to commercial residential properties. Without 

adequate internal controls, FEMA is at risk of not being able to recover all the 

Federal taxpayer funds New York City spent on repairs to commercial 

residential properties. FEMA recognizes that commercial landlords may have 

received an incidental benefit from the Federal assistance provided to New York 

City and used for repairs to multifamily dwellings to ensure tenants could 

shelter in their homes. 

FEMA’s $14.33 Million Cost Estimate Was Inaccurate 

FEMA based its $14.33 million cost estimate on 37 high-rise apartment 

buildings receiving temporary power, heat, and hot water for 90 days, less than 

5 percent of the 818 multifamily structures needing repairs as a result of 

Hurricane Sandy.12 FEMA’s estimate did not include temporary repairs or 

emergency protective measures for other types of multiple dwellings.13 Under 

New York State law and New York City building code, a multiple dwelling is 

defined as “a dwelling which is either rented, leased, let or hired out, to be 

occupied, or is occupied as the residence or home of three or more families 

living independently of each other.” 

On December 27, 2012, the Federal Coordinating Officer issued guidance 

applicable to multifamily dwellings “that rely upon common utilities, which 

serve multiple individual dwelling units within a larger structure.” Eligible 

assistance included minimal repairs to the existing building systems necessary 

to provide essential power, heat, and hot water for the building’s residents. 

However, more permanent methods of repairs were also eligible if either cost 

neutral or more cost effective. FEMA’s estimate did not address these 

additional costs. 

12 As of December 20, 2012 

13 On February 25, 2015, without adjusting its cost estimate, FEMA updated the project’s 

scope of work to read 3,225 multifamily units. We were unable to locate detailed supporting 

documentation (e.g., work order or address listings) in FEMA’s records for this change. 

www.oig.dhs.gov 8 OIG-17-38-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Conclusion 

FEMA should improve its management oversight to more effectively protect 

against the vulnerabilities associated with implementing pilot programs. 

Because more than 3 years have passed since the completion of the work, 

FEMA is at an increased risk of not being able to recover Federal funds New 

York City spent on emergency protective measures incidentally benefitting 

commercial residential properties. We are concerned FEMA officials are not 

displaying a sense of urgency in accounting for and recovering Federal taxpayer 

funds invested in the effort given that: 

x Commercial property owners change or exit the business. 

x Federal funds may have been spent on unauthorized repairs. 

x Expenditures of Federal funds for emergency protective measures may 

not be adequately supported. 

In December 2012, OIG cautioned FEMA about the need to (1) maintain strong 

internal controls given the number of individuals affected by Hurricane Sandy; 

and (2) address vulnerabilities associated with implementing pilot programs 

such as STEP. At the end of our audit engagement, FEMA still did not have 

adequate policies and procedures for protecting government resources used to 

support disaster response and recovery activities that did not fit standard grant 

conditions. 

Recommendations 

We recommend that the Associate Administrator of Response and Recovery and 

Regional Administrator, FEMA Region II: 

Recommendation 1: Review and improve, as necessary, policies and 

procedures that protect government resources used to support disaster 

response and recovery activities. Research the viability, appropriateness and 

legality of placing a lien or Notice of Federal Interest on commercial residential 

properties receiving Federally-funded emergency protective measures such as 

temporary repairs or short-term measures such as temporary boilers and 

power generators. 

We recommend that the Regional Administrator, FEMA Region II: 

Recommendation 2: Work with New York State and New York City to close out 

the project. This includes ensuring that the final cost reconciliation accurately 

separates the costs for commercial residential properties. 

www.oig.dhs.gov 9 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation 3: Ensure New York City made reasonable efforts when 

appropriate and allowed for under State and local laws to compel commercial 

building owners/operators to make permanent repairs to health and safety 

hazards and other housing code violations addressed by FEMA-funded 

emergency protective measures under this initiative, and to recover from 

commercial owners any Federal funds expended on emergency protective 

measures for facilities they own or operate. 

Discussion with Management and Audit Follow-up 

We discussed the results of our audit with FEMA officials during our audit. We 

also provided a discussion draft and discussed it with FEMA, New York State, 

and New York City officials on June 14, 2016. FEMA officials provided 

technical comments on July 7, 2016, and November 23, 2016. We discussed 

those comments with FEMA officials on December 8, 2016. We incorporated 

those comments, as appropriate, in this report. 

FEMA provided a written response on January 23, 2017, agreeing with all three 

recommendations contained in this report (see appendix B). The response 

indicated that FEMA expects to implement its proposed corrective actions to 

address all recommendations by December 29, 2017. Therefore, we consider all 

three 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 OIGEMOFollowup@oig.dhs.gov. 

The Office of Emergency Management Oversight major contributors to this 

report are Paul Wood, Acting Deputy Assistant Inspector General; 

John McPhail, Supervisory Program Analyst; John Woo, Auditor-in-Charge; 

and Christine Alvarez, Independent Referencer. 

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

Paul Wood, Acting Deputy Assistant Inspector General, Office of Emergency 

Management Oversight, at (202) 254-4283. 

www.oig.dhs.gov 10 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, Methodology 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) 

was established by the Homeland Security Act of 2002 (Public Law 107ï296) by 

amendment to the Inspector General Act of 1978. 

The objective of our audit was to determine the extent FEMA identified and 

received reimbursement due from New York City for Federal funds it spent on 

repairs to commercial residential properties.14 Accordingly, we audited FEMA’s 

efforts to identify and obtain reimbursement due from New York City (Public 

Assistance Identification Number 081-51000-26) for Public Assistance grant 

funds it spent on repairs to multifamily buildings that may have been owned by 

commercial entities. While we did receive some information and feedback from 

New York State and New York City, the focus of our audit was not designed to 

audit New York State or New York City’s efforts. 

New York City received a Public Assistance grant award of $537.94 million 

(90% Federal share of project costs totaling $597,711,508.72) from New York 

State for damages resulting from Hurricane Sandy occurring in October 2012. 

The award provided Federal funding to help New York City implement two large 

projects so disaster survivors could shelter-in-place in their own homes. These 

emergency protective measures were available for both single family and 

multifamily dwellings and consisted of temporary power, heat, and hot water 

system repairs and short-term measures such as temporary boilers and 

emergency power generators. 

The scope of our audit covered the period October 30, 2012, to July 7, 2016; 

and included analyses of two large projects15 that were subsequently 

combined: PA-02-NY-4085-PW-00012 (FEMA Sheltering and Temporary 

Essential Power Pilot program assistance) and PA-02-NY-4085-PW-00013 

(Section 403 Emergency Protective Measures for Multifamily Dwellings). Based 

on an agreement with New York State and New York City, FEMA merged PA-02-

NY-4085-PW-00013 into PA-02-NY-4085-PW-00012. We did not review the 

terms and conditions of the agreement for reasonableness or determine 

whether the agreement was in conformance with Federal regulations. 

To accomplish our objective, we reviewed the major disaster declaration, 

FEMA-State Agreement, and related amendments; examined prior audit reports 

and the Hurricane Sandy FEMA After-Action Report; interviewed FEMA 

14 This includes short-term measures such as temporary boilers and power generators. 

15 Federal regulations in effect at the time of Hurricane Sandy set the large project threshold 

at $67,500. 

www.oig.dhs.gov 11 OIG-17-38-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

officials; and gained an understanding of the projects, including the addendum 

combining them. We inspected FEMA and New York City project records in 

FEMA’s possession, including email correspondence; and judgmentally selected 

and reviewed (generally based on dollar values) project invoices and supporting 

work orders. 

We also reviewed applicable Federal regulations and FEMA guidelines; obtained 

written comments from FEMA and New York State officials on preliminary 

findings and recommendations; and performed other procedures considered 

necessary under the circumstances to accomplish our audit objective. In 

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

and guidelines in effect at the time of the disaster. We did not assess the 

adequacy of the agency’s internal controls applicable to information systems 

and the financial processing of the projects because it was not necessary to 

accomplish our audit objective. 

While the focus of our audit was not designed to audit New York State or New 

York City’s efforts, we did receive comments directly from New York State 

officials on July 7, 2016. Those comments included information that had not 

previously been made available to FEMA. Since we did not did not review the 

accuracy or validity of New York State’s assertions, we did not include those 

assertions in the body of this report. 

We conducted this performance audit between October 2015 and July 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 objectives. We believe that the evidence obtained provides a reasonable 

basis for our findings and conclusions based upon our audit objectives. 

. 

www.oig.dhs.gov 12 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

FEMA Response 

www.oig.dhs.gov 13 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B (continued) 

www.oig.dhs.gov 14 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B (continued) 

www.oig.dhs.gov 15 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B (continued) 

www.oig.dhs.gov 16 OIG-17-38-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B (continued) 

www.oig.dhs.gov 17 OIG-17-38-D 
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 

Under Secretary for Management 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Assistant Secretary for Office of Partnership and Engagement 

Chief Privacy Officer 

Director, GAO/OIG Liaison Office 

Federal Emergency Management Agency 

Administrator 

Chief of Staff 

Chief Financial Officer 

Chief Counsel 

Associate Administrator for Policy, Program Analysis, and International Affairs 

Director, Risk Management and Compliance 

Director, Office of External Affairs 

Audit Liaison, FEMA Region II (Job Code 15-133-EMO-FEMA) 

Audit Liaison, FEMA (Job Code 15-133-EMO-FEMA) 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

External 

Commissioner, New York State Division of Homeland Security and 

Emergency Services 

Director, New York City Office of Management and Budget 

www.oig.dhs.gov 18 OIG-17-38-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