FEMA Needs to Improve 

Management of Its 

Flood Mapping Programs 

September 27, 2017 

OIG-17-110 
 

 

 

 

 

 

DHS OIG HIGHLIGHTS
 

FEMA Needs to Improve Management of Its

Flood Mapping Programs 

September 27, 2017 

Why We Did 

This Audit 

Flood hazard identification 

and mapping is an integral 

part of the National Flood 

Insurance Program (NFIP) as it 

creates the foundation for 

floodplain management, flood 

insurance, and mitigation. We 

sought to determine whether 

the Federal Emergency 

Management Agency’s (FEMA) 

Risk Mapping, Assessment 

and Planning Program (Risk 

MAP) resulted in the 

production of timely and 

accurate flood maps in 

accordance with NFIP 

requirements. 

What We 

Recommend 

We made four 

recommendations designed to 

improve FEMA’s management 

and oversight of its flood 

mapping programs. 

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 

FEMA is unable to assess flood hazard miles to meet its 

program goal and is not ensuring mapping partner quality 

reviews are completed in accordance with applicable 

guidance. FEMA needs to improve its management and 

oversight of flood mapping projects to achieve or reassess 

its program goals and ensure the production of accurate 

and timely flood maps. Specifically, FEMA – 

x needs to improve its financial management of flood 

map projects to achieve or to reassess its 

program goal of 80 percent New, Valid, or Updated 

Engineering program miles; 

x has not updated its Risk MAP life cycle cost estimate 

to inform critical decision making; 

x lacks uniform, centralized policies and procedures 

for projects placed on hold; and 

x is not performing adequate oversight to ensure 

mapping partner quality reviews comply with 

requirements set forth in applicable guidance. 

Without accurate floodplain identification and mapping 

processes, management, and oversight, FEMA cannot 

provide members of the public with a reliable rendering of 

their true flood vulnerability or ensure that NFIP rates 

reflect the real risk of flooding. 

FEMA’s Response 

FEMA noted that it has made significant progress 

developing and implementing several flood-related policy 

and program changes since the Office of Inspector General 

began this audit. FEMA remains strongly committed to 

providing credible risk information to communities so that 

they can make informed flood risk management decisions. 

The report contained four recommendations with which 

FEMA concurs. 

www.oig.dhs.gov OIG-17-110 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

September 27, 2017 

MEMORANDUM FOR: 	 Angela Gladwell 

Risk Management Deputy Assistant Administrator 

Federal Insurance and Mitigation Administration 

Federal Emergency Management Agency 

FROM: 	 John V. Kelly _..., 

Deputy Inspector General 

SUBJECT: 	 FEMA Needs to Improve Management ofits Flood 

Mapping Programs 

Attached for your action is our final report, FEMA Needs to Improve 

Management ofits Flood Mapping Programs. We incorporated the formal 

comments provided by your office. 

The report contains four recommendations aimed at improving FEMA's 

management and oversight of its flood mapping programs. Your office 

concurred with all four recommendations. Based on the 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 a formal closeout letter to us within 30 days 

so that we may close the recommendations. The memorandum should be 

accompanied by evidence of completion of agreed upon corrective actions and 

the disposition of monetary amounts. We consider recommendations 3 and 4 

open and unresolved. As prescribed by the Department of Homeland Security 

Directive 077-01, Follow-Up and Resolutions for the Office ofInspector General 

Report Recommendations, within 90 days of the date of this memorandum, 

please provide our office with a written response that includes your target 

completion date for each recommendation. Please send your response or 

closure request to OIGAuditsFollowup@oig.dhs.gov. 

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

provide copies of our report to appropriate congressional committees with 

oversight and appropriation responsibility over the Department of Homeland 

Security. We will post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Maureen Duddy, 

Deputy Assistant Inspector General for Audits, at (617) 565-8723. 

Attachment 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

Background .................................................................................................... 1 

Results of Audit .............................................................................................. 3 

Management of Flood Mapping Projects Needs Improvement .................. 3 

FEMA Should Enhance Its Oversight of 

Mapping Partner Quality Reviews .......................................................... 7 

Conclusion .......................................................................................... 10 

Recommendations ......................................................................................... 11 

Appendixes 

Appendix A: Objective, Scope, and Methodology ................................. 14 

Appendix B: FEMA Comments to the Draft Report ............................... 17 

Appendix C:Report Distribution .......................................................... 21 

Abbreviations 

ECD estimated completion date 

FEMA Federal Emergency Management Agency 

FIRM or flood map Flood Insurance Rate Map 

LCCE life cycle cost estimate 

MIP Mapping Information Platform 

Needs Database Coordinated Needs Management Strategy 

Database 

NFIP National Flood Insurance Program 

NVUE New, Valid, or Updated Engineering 

OIG Office of Inspector General 

QR quality review 

Risk MAP Risk Mapping, Assessment and Planning Program 

RMD Risk Management Directorate 

verification check Database Verification Tool 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

Flooding has been, and continues to be, a serious risk in the United States. To 

reduce this risk, Congress established the National Flood Insurance Program 

(NFIP) with the passage of the National Flood Insurance Act of 1968. Although 

originally intended to be funded with policyholder premiums, NFIP, in part due 

to natural disasters in 2005 and 2012, has proven to be actuarially unsound. 

For example, as of March 2016, the Federal Emergency Management Agency 

(FEMA) owed the U.S. Treasury $23 billion, up from $20 billion in November 

2012, to pay flood claims. 

FEMA administers NFIP through the Federal Insurance and Mitigation 

Administration. NFIP’s three-fold mission is to – 

x make federally backed flood insurance available to home and business 

owners and renters; 

x minimize the economic impact of flood events through floodplain 

management, which incorporates mitigation efforts and communityadopted floodplain ordinances; and 

x identify and map community areas subject to flooding. 

Flood hazard identification and mapping is an integral part of NFIP as it creates 

the foundation for floodplain management, flood insurance, and mitigation. A 

Flood Insurance Rate Map (FIRM or flood map) includes statistical information 

such as data for river flow, storm tides, hydrologic and hydraulic analyses, and 

rainfall and topographic surveys. 

Flood maps provide risk information and enable communities to make 

informed decisions, e.g., to adopt and enforce minimum floodplain 

management regulations that reduce the loss of life and property. 

Flood studies are conducted to assess the following conditions: 

x riverine flooding of rivers, streams, or other waterways; 

x flooding of lakes and ponds; 

x coastal flooding caused by hurricanes or severe storms; and 

x shallow flooding, ponding, and sheet flow. 

FEMA manages its mapping needs through the Coordinated Needs 

Management Strategy Database (Needs Database), a resource that includes 

processes and data for tracking flood hazard studies. FEMA uses the Needs 

Database assessment process to report the percentage of updated and valid 

flood maps. FEMA expresses this metric as the New, Valid, or Updated 

Engineering (NVUE) percent attained. 

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OFFICE OF INSPECTOR GENERAL 

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The NVUE percent attained is a ratio of all NVUE study miles divided by the 

total miles in FEMA’s mapped inventory. NVUE metrics distinguish between 

engineering studies that adequately identify the level of flood risk (known as 

Valid) from those that are in need of restudy (known as Unverified). Changes in 

topography, hydrology, and/or land development are evaluated as part of this 

validation process. When a floodplain needs to be studied or is being studied, it 

is labeled as Unverified in the Need Database. Unverified miles can only 

become NVUE compliant through a new flood study. 

According to the National Flood Insurance Reform Act of 1994, FEMA must 

assess the need to revise and update all floodplain areas and flood risk zones 

identified once during each 5-year period. Thus, valid miles will expire every 

five years if not assessed. Failure to assess an NVUE compliant mile within the 

5-year window will result in the mile being re-categorized as “Unknown” in the 

Needs Database. Unknown miles have not been subjected to the validation 

process to determine whether they reflect the current flood risk or are in need 

of restudy. In 2009, FEMA set a goal to attain 80 percent NVUE by the end of 

fiscal year 2014. 

FEMA Headquarters and regions select flood mapping projects based on the 

highest risk, need, and available funding. FEMA relies on mapping partners 

such as production and technical services contractors, which are private 

engineering firms, as well as state and local governments or regional agencies 

participating in FEMA’s Cooperating Technical Partners program for riverine, 

levee, and coastal flood studies. 

FEMA uses the Mapping Information Platform (MIP) as the system of record to 

manage the production of flood maps. MIP integrates program and project 

management, data storage and retrieval, standardized quality control reviews, 

and tracking of flood map production into one web-based application. 

This review focuses on riverine flooding, which occurs in waterways subject to 

overbank flooding, flash floods, and urban drainage system flooding. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

FEMA is unable to assess flood hazard miles to meet its program goal and is 

not ensuring mapping partner quality reviews are completed in accordance 

with applicable guidance. FEMA needs to improve its management and 

oversight of flood mapping projects to achieve or reassess its program goals 

and ensure the production of timely and accurate flood maps. Specifically, 

FEMA – 

x	 needs to improve its financial management of flood map projects to 

achieve or to reassess its program goal of 80 percent NVUE program 

miles; 

x	 has not updated its Risk Mapping, Assessment and Planning Program 

(Risk MAP) life cycle cost estimate (LCCE) to inform critical decision 

making; 

x lacks uniform, centralized policies and procedures for projects placed on 

hold; and 

x lacks oversight to ensure mapping partner quality reviews (QR) comply 

with requirements set forth in FEMA’s quality review guidance. 

Without accurate floodplain identification and mapping processes, 

management, and oversight, FEMA cannot provide members of the public with 

a reliable rendering of their true flood vulnerability or ensure that NFIP rates 

reflect the real risk of flooding. 

Management of Flood Mapping Projects Needs Improvement 

FEMA is not meeting its program goal to ensure flood hazards are current with 

NVUE miles. In 2009, FEMA set a performance goal to attain 80 percent NVUE 

by the end of FY 2014. However, in February 2014, FEMA notified the 

Department of its anticipated breach of that goal and set an approved revised 

baseline of 64 percent NVUE. Despite adjusting its performance goal, FEMA 

only attained 49 percent NVUE at the end of FY 2014 (see figure 1). As of 

December 2016, FEMA’s NVUE was at 42 percent, meaning more than half of 

the Needs Database inventory of miles either required a re-study or have not 

yet been assessed through the validation process. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1: National NVUE Attained through FY17 Quarter 1 % NVUE Attained 

60.0% 

40.0% 

20.0% 

0.0% 

40.2% 41.8% 45.0% 45.7% 46.7% 48.0% 49.2% 49.3% 

42.0% 40.9% 42.4% 42.4% 

32.5% 

 Source: FEMA 

This was caused in part because FEMA (1) does not have an appropriate 

system for tracking obligations and expenditures for regions at the task order 

level; (2) has not updated its Risk MAP life cycle cost estimate to inform critical 

decision making; and (3) did not always effectively oversee the progress and 

completion of flood map projects. FEMA needs to improve its management of 

flood map projects to achieve or to reassess its 80 percent NVUE program miles 

goal. 

Financial Management Oversight to Achieve Program Goal 

FEMA needs to improve its financial management of flood map projects to 

achieve or to reassess its program goal of 80 percent NVUE. FEMA attributed 

the reduction in NVUE compliance to a decrease in program funding. FEMA’s 

funding for FYs 2010 to 2014 was expected to total $1.47 billion, but FEMA 

received just $1.23 billion during this period. We identified $194 million 

unexpended funds from FYs 2010 to 2014 that could have been used for 

additional projects. 

FEMA officials stated that they were unable to spend the $194 million due to 

mapping projects lasting long periods or projects that were not closed. 

Although we identified two regions with an in-house mechanism to track and 

trace commitments, we were unable to reconcile these unexpended funds to 

mapping studies because FEMA does not have a financial system that enables 

them to track obligations and expenditures for regions at the task order level. 

Tracking obligations and expenditures would enable FEMA to better manage its 

resources and give them a means for monitoring and assessing the validity of 

its program goal. 

The Risk MAP Life Cycle Cost Estimate 

FEMA has not updated its Risk MAP life cycle cost estimate (LCCE) to inform 

critical decision making. FEMA created the original Risk MAP LCCE in 2010 

and updated it in 2012 to project costs through 2014. Following NVUE 

performance goal breach and the award of two major production and technical 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

service contracts in 2014, FEMA drafted an LCCE to estimate the total cost of 

Risk MAP over the life of the program (FY2010 through FY2020). This 

document was in draft form at the conclusion of our review. According to one 

FEMA Program Specialist, the LCCE remains in draft because of their 

impending new governance structure and uncertainty regarding future 

congressional appropriations. 

We believe that finalizing the Risk MAP LCCE would help FEMA estimate the 

likely cost of flood hazard studies and contribute to establishing a baseline for 

NVUE compliance over the next 5 years. 

Projects Placed on Hold 

FEMA did not always effectively oversee the progress and completion of flood 

map projects. A FEMA region may place a flood map project on hold to 

temporarily suspend its assessment of schedule and cost performance (earned 

value calculation) when it cannot progress due to uncontrollable 

circumstances. Schedule and cost performance is calculated by earned value at 

the project level. Earned value calculations of time, budget, and performance 

better enable FEMA to manage and assess the health of a flood map project.

FEMA may place a project on hold pending the receipt of data from an external 

source or when progress cannot be made until critical information such as new 

levee guidance has been received. 

Although the intent of placing projects on hold is supposed to be temporary to 

suspend earned value calculations, FEMA lacks centralized policies and 

procedures for expediting removal of projects from on hold status. Specifically, 

65 of the 88 projects we tested were on hold for more than a year. When flood 

map projects are placed on hold for long periods, FEMA cannot provide 

members of the public with a timely understanding of their true flood 

vulnerability or ensure that NFIP rates reflect the real risk of flooding. 

We identified 240 of 1,947 (12 percent) active flood map projects that were on 

hold during of our review. We focused our review on 88 of the 240 on hold 

projects that were riverine flood map projects. Of the 88 riverine projects 

tested: 

x 28 (or 32 percent) were on hold for an average of 2.9 years because they 

were impacted by new levee accreditation guidance; 

x 21 (or 24 percent) were on hold for an average of 2.6 years because their 

period of performance for the mapping contract expired. These projects 

could remain on hold indefinitely as FEMA may or may not fund to 

continue the project in the subsequent years; and 

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x

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

13 (or 15 percent) were on hold for an average of 2.9 years because the 

project was in the post or revised preliminary mapping process. When a 

project needs significant modification, it may be necessary to issue a 

revised set of preliminary maps. The revised preliminary process usually 

requires a contract modification in order to change the project scope, 

period of performance, and funding. 

See figure 2 for the range of reasons FEMA placed 88 projects on hold. 

Figure 2: Duration and Reason Risk MAP Projects Placed on Hold 

for Regions Combined 

Reason # 1 2 3 4 

Levee Analysis and Mapping Procedures 28 

Expired Period of Performance 21 

Revised Preliminary Phase 11 

Completed; Future Work Anticipated 9 

Awaiting Completion of Countywide Project 3 

No Additional Funding 3 

Awaiting LiDAR Data 2 

Post Preliminary Phase 2 

Change Request 1 

Other* 8 

88 

2.4 

1.9 

2.9 

0.8 

3.4 

1.3 

Duration in Years (Average) 

2.9 

2.6 

2.8 

1.1 

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

*Other: Projects that have been combined with other flood mapping projects or are placeholders in the 

MIP. 

The Regional Project Management Lead or the Regional Project Manager is 

responsible for tracking the status of projects and placing them on hold with 

FEMA Headquarters approval. FEMA region officials reported that they would 

like more input or guidance from Headquarters on how they should complete 

or prioritize on hold projects. For example, while one FEMA region prioritizes 

the funding of on hold projects during their annual planning phase, another 

region pools projects regardless of their status. Also, while one FEMA region 

plans and sets aside funding to cover expenses associated with community 

appeals, another does not. 

Because FEMA allows its 10 regions to independently manage and oversee 

their flood mapping projects, at a minimum, FEMA should set a standard or 

benchmark for the completion of on hold projects and improve communication 

and coordination among Regional Project Managers to develop and share best 

practices. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA Should Improve Its Oversight of Mapping Partner Quality 

Reviews 

FEMA lacks oversight to ensure that mapping partner QRs comply with 

applicable guidance. Specifically, FEMA did not ensure that mapping partners 

completed and uploaded required checklists and self-certifications into MIP. 

FEMA also did not always verify that flood map project data passed all required 

Database Verification Tool checks (verification check) prior to issuing a map or 

ensure that documentation was kept on file to support bypassing failed 

verification checks. 

In 2013, FEMA revised its QR requirements that mapping partners must 

comply with during the course of developing flood maps. FEMA’s guidance 

requires that mapping partners use FEMA’s three mandatory standardized 

checklists during the course of developing a flood map. These checklists 

document whether project data complies with FEMA’s standards. Once the 

mapping partner makes any necessary corrections and completes the checklist, 

the mapping partner uploads them into MIP and self-certifies the flood map’s 

compliance with FEMA’s standards. 

Additionally, data used to develop a flood map must pass automated 

verification checks in order for the project to advance to the next step in the 

development of the flood map. Verification checks determine whether project 

data used in developing a flood map complies with FEMA’s Flood Map 

Database standards. Mapping partners upload data into MIP and use the 

verification checks to test the quality of draft, preliminary, and final flood map 

database submittals. If the MIP verification check fails, the data is returned to 

the mapping partner for correction. In some instances, the mapping partner 

can request a verification check bypass and explain the reason. All quality 

compliance check issues noted during the QR process must be fully addressed, 

documented, resolved, and included in MIP. 

However, FEMA’s guidance does not assign responsibilities to FEMA personnel 

to ensure that mapping partners – 

x complete and upload the required checklists and self-certifications into 

MIP; 

x validate that flood map project data passes all verification check prior to 

issuance of a flood map; and 

x upload documentation of verification check bypasses in the MIP. 

FEMA regions reported a general lack of understanding as to who should 

oversee QRs performed by mapping partners. According to one FEMA Program 

Specialist, FEMA has not provided any training to Regional Program Managers 

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OFFICE OF INSPECTOR GENERAL 

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regarding the QR process. Additionally, this specialist was unaware of any 

FEMA region that confirms the uploading of required checklists into MIP. We 

held discussions with five Regional Program Managers and they offered the 

following feedback about oversight uncertainty. Different managers indicated 

that they – 

x did not know who was responsible for overseeing the quality review 

process; 

x were not required to upload quality review checklists to the MIP prior to 

2015; 

x did not have access to all MIP files; 

x believed the QR process was not mandatory; 

x stated the regions and Headquarters shared responsibility for overseeing 

QRs; 

x did not always know whether mapping partners completed and uploaded 

QR checklists to MIP (based on the manager’s tendency not to use MIP); 

and 

x did not know where QRs are housed in MIP. 

During the course of our review, we also learned that a Regional Program 

Manager may be responsible for up to 50 ongoing flood mapping projects in 

addition to first responder duties for disaster-related events. 

We judgmentally selected nine flood map projects completed between May 2014 

and July 2016 to substantiate the lack of internal controls identified during the 

course of our review. None of nine flood map projects selected for our review 

complied with FEMA’s QR guidance. Specifically, all nine projects either did not 

have FEMA’s mandatory checklists or the required self-certification uploaded in 

MIP.1 Eight of the nine projects had a failed verification check for a draft, 

preliminary, final, or test after final flood map submittal. The results of our 

analysis follow. 

Quality Review Checks 

FEMA is not supervising contractor performance to ensure that required QR 

checklists and self-certifications are completed and uploaded into MIP. All nine 

projects selected for our review either did not have FEMA’s mandatory QR 

checklists or the required self-certification uploaded in MIP. Specifically, 19 out 

of 27 QR checklists (70 percent) and 8 out of 9 self-certifications (89 percent) 

were not in MIP at the time of our review. See table 1 for the results of our 

review by region. 

 1 We selected one project from each of FEMA’s 10 Regions except Region 8, where we could not 

find any flood map projects completed during our test period. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1: Total Number of Quality Review Checklists and Self -

Certifications Missing in the MIP by Region 

Region Case # 

Required Quality Review Checklists in MIP? Self – 

certifications 

Quality in MIP? 

Review 3 

Quality 

Review 7 

Quality 

Review 8 

1 11-01-0889S Yes Yes Yes No 

2 13-02-0708S No No Yes No 

3 10-03-0355S No No No No 

4 09-04-8601S No No Yes No 

5 11-05-1556S No No No No 

6 10-06-1115S No No No No 

7 11-07-2747S No No No No 

9 11-09-0920S No No Yes No 

10 10-10-0993S Yes No Yes Yes 

 Total 

7 of 9 8 of 9 4 of 9 

8 of 9

19 of 27 

 Source: OIG Analysis of MIP data 

For QR checklists not included in MIP, we contacted FEMA to verify whether 

mapping partners had in fact completed them. FEMA subsequently received 

from mapping partners 9 of the 19 missing checklists and 3 of the 8 missing 

self-certifications. 

Database Verification Tool Checks 

FEMA is not supervising contractor performance to ensure flood map project 

data passed all required verification checks. Additionally, FEMA did not ensure 

documentation was kept on file to support bypassing failed verification checks. 

Eight of the nine projects selected for our review had a failed verification check 

for either a draft, preliminary, final, or test after final flood map submittal. 

Specifically, 14 of 27 (55 percent) required verification checks failed and were 

bypassed, but there was no evidence of a bypass explanation in MIP. See table 

2 for the results of our review by Region. 

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Table 2: Number of Database Verification Tool Bypasses Not on MIP 

Region Case # 

Number of Database 

Verification Tool Bypasses 

Not on MIP 

Type of Submittal 

1 11-01-0889S 1 Final 

2 13-02-0708S 1 Final* 

3 10-03-0355S 2 Draft* and Preliminary* 

4 09-04-8601S 2 Draft and Final 

5 11-05-1556S 0 

6 10-06-1115S 2 Draft and Preliminary 

7 11-07-2747S 2 Draft and Preliminary 

9 11-09-0920S 3 Draft, Preliminary, and Final 

10 10-10-0993S 1 Final 

Total 14 

Source: OIG analysis of MIP data

 *Provided by mapping partner
 

To determine whether mapping partners completed bypass explanations, we 

contacted FEMA personnel who coordinated with mapping partners for bypass 

documentation. Mapping partners could not provide documentation for 11 of 

the 14 bypasses. 

We also found four instances where a verification check failed but the project 

advanced to the next phase without a bypass request and the map was issued. 

A FEMA official was unable to explain the reason FEMA advanced three of the 

four projects, and did not provide documentation to support map issuance. 

Without adequate oversight to ensure that mapping partner QRs comply with 

applicable guidance, FEMA cannot provide the public with a reliable rendering 

of their true flood vulnerability or ensure that NFIP rates reflect the real risk of 

flooding. 

Conclusion 

FEMA needs to improve its management and oversight of flood mapping 

projects to achieve program goals and ensure the production of accurate and 

timely flood maps. Flood hazard identification and mapping is an integral part 

of NFIP. It creates the foundation for floodplain management, flood insurance, 

and mitigation. Flood maps provide risk information and enable communities 

to make informed decisions such as adopting and enforcing minimum 

floodplain management regulations that reduce the loss of life and property. 

FEMA lacks uniform, centralized policies and procedures for projects placed on 

hold and is not adequately overseeing mapping partner quality reviews. 

Without accurate floodplain identification and mapping processes, 

management, and oversight, FEMA cannot provide members of the public with 

a reliable rendering of their true flood vulnerability or ensure that NFIP rates 

reflect the real risk of flooding. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

We recommend that the Federal Insurance and Mitigation Administration, Risk 

Management Deputy Assistant Administrator, Federal Emergency Management 

Agency: 

Recommendation 1: Implement a system of tracking regional cost allocations 

for flood map projects including studies and other investments, as well as the 

status of funds (expended and unexpended) and where they are in their 

lifecycle. 

Recommendation 2: Coordinate with the FEMA Chief Acquisition Executive 

Office to finalize and approve the Risk MAP LCCE. 

Recommendation 3: Develop an effective oversight strategy and 

implementation plan including necessary policies and procedures to enable 

mapping projects to move forward on a timely and consistent basis. 

Recommendation 4: Revise policies and procedures to require Regional 

Project Managers to – 

x ensure QR checklists and self-certifications are completed and uploaded 

into MIP; 

x verify project data passes all Data Verification Tool checks prior to 

issuance of a flood map; and 

x ensure documentation of all Data Verification Tool bypasses is uploaded 

in MIP. 

FEMA Comments and OIG Analysis 

FEMA concurs with all of the recommendations. In its comments, FEMA noted 

that it has made significant progress developing and implementing several 

flood-related policy and program changes since OIG began this audit. These 

changes include: (1) development and finalization of a Risk Mapping 

Assessment and Planning (Risk MAP) Program Lifecycle Cost Estimate (LCCE); 

(2) development and implementation of the Risk Management Directorate 

(RMD) Centric Budget Matrix Tool; and (3) updating the Risk MAP Quality 

Assurance Management Plan. 

We have included a copy of the management comments in their entirety in 

appendix B. A summary of FEMA’s response and our analysis follows. 

Response to Recommendation #1: Concur. FEMA’s RMD is developing 

budget tracking procedures with action steps for regional program components 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

and staff. These steps include: (1) aligning cost tracking to production 

milestones, 2) working with regional staff to develop cost tracking guidance, 

and 3) implementing a review of the cost tracking procedures as part of the 

quarterly occurring joint performance reviews with the Regions to assess 

operations during FY 2018. Estimated completion date (ECD): September 30, 

2018. 

OIG Analysis: FEMA’s corrective action is responsive to the recommendation. 

The recommendation will remain open and resolved until FEMA provides 

evidence to support that corrective actions are completed. 

Response to Recommendation #2: Concur. FEMA’s RMD initiated an update 

of the Risk MAP LCCE, led by the Risk MAP Program Manager, during the audit 

period. The LCCE is now in final routing for approval by FEMA Office of the 

Chief Financial Officer, Office of the Chief Information Officer, and the Chief 

Acquisition Executive. ECD: October 31, 2017. 

OIG Analysis: FEMA’s corrective action is responsive to the recommendation. 

The recommendation will remain open and resolved until FEMA provides 

evidence of the final approved version of the LCCE. 

Response to Recommendation #3: Concur. FEMA is developing a strategy to 

monitor the status of projects currently on hold. The strategy will include 

quarterly joint performance review meetings that will introduce performance 

metrics to ensure regions continue to maintain progress in moving projects 

forward to completion. Monthly cost and schedule performance reports will be 

reviewed during these meetings and corrective action will be provided as 

needed. FEMA will also develop a national implementation plan to categorize all 

on hold projects and will provide regions with guidance to move these projects 

forward in a consistent manner. ECD: to be determined. 

OIG Analysis: FEMA’s corrective action is responsive to the recommendation 

but will remain open and unresolved pending receipt of ECD and evidence of its 

strategy and implementation plan to ensure mapping projects currently placed 

on hold move forward in a timely manner. 

Response to Recommendation #4: Concur. FEMA‘s Quality Working Group 

finalized the Quality Assurance Management Plan requiring regions verify their 

project data passes all Data Verification Tool checks prior to issuance of a 

flood map. FEMA also update the Mapping Information Platform system to 

include quality review (QR) tasks and validation tasks. The QR task will be the 

repository for the upload of the QR checklists, Production and Technical 

Services self-certification documentation, and Data Verification Tool check 

information, to include results and bypasses, should they exist. The validations 

tasks will allow the Regions to validate that correct information is uploaded for 

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the QR tasks and the project has met the quality requirements. A report of the 

data validation tasks and documentation checks will be developed and 

provided to all study managers on a quarterly basis to provide an additional 

level of visibility on the process and data collection. ECD: to be determined. 

OIG Analysis: FEMA’s corrective action is responsive to the recommendation 

but will remain open and unresolved pending receipt of ECD and until we have 

reviewed FEMA’s Quality Assurance Management Plan. 

www.oig.dhs.gov 13 OIG-17-110 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and 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. 

We conducted this audit to determine whether Federal Emergency Management 

Agency’s (FEMA) Risk Mapping, Assessment and Planning Program (Risk MAP) 

assessed and updated flood maps timely and accurately in accordance with 

National Flood Insurance Program (NFIP) requirements. Specifically, we 

reviewed whether FEMA is meeting its program goal to ensure that 80 percent 

of flood hazard miles are current with New, Valid, or Updated Engineering 

(NVUE); oversaw the progress and completion of riverine flood map projects 

placed on hold; and ensured mapping partner quality reviews comply with 

requirements set forth in FEMA’s quality review guidance. 

To accomplish our objective, we obtained and reviewed pertinent Federal and 

FEMA specific regulations, policies, procedures, and guidance relevant to flood 

mapping. We interviewed FEMA officials and staff responsible for the 

management and oversight of flood mapping projects. 

To determine whether FEMA met its program goal of 80 percent NVUE miles, 

we obtained FEMA’s report titled Overview of Risk MAP Coordination Needs 

Management Strategy and NVUE Status issued to Congress on September 18, 

2015. We compared the data in this report to reports from FEMA’s 

Coordination Needs Management Strategy to verify accuracy. We obtained 

additional fiscal year data from the Coordination Needs Management Strategy 

system to present the current year NVUE attained percentage presented in 

figure 2 of this report. For the purpose of this report we determined that the 

data was sufficiently reliable. 

To identify unexpended obligations, we obtained a listing of financial 

transactions from FEMA’s Integrated Financial Management Information 

System (IFMIS) for fiscal years 2009 through 2016. We subtracted the total 

expenditures and adjustments from total obligations included in the listing of 

IFMIS transactions. We were unable to test the data reliability of unexpended 

funds because FEMA does not track obligations and expenditures at the task 

order level for legacy contracts. 

To assess the process of assuring the timely production of flood maps, we 

identified the number of all active and on hold projects between April and 

November 2016 (1,947 projects) from FEMA’s Mapping Information Platform 

(MIP) and FEMA regions. We limited the scope of our review to riverine mapping 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

projects that were categorized as “on-hold” in MIP as riverine projects are the 

largest program cost within Risk MAP. In total we identified 240 “on-hold” 

projects with expenditures totaling $41 million. 

We developed and sent out a questionnaire to seven FEMA regions to 

understand how each manages, tracks, and processes on-hold projects. Based 

on responses received, we conducted interviews with seven regional officials 

who manage flood map projects. We judgmentally selected these regions based 

on criteria such as the number of on-hold projects at the time of our review 

and type of responses given to our questionnaire to obtain a broad range of 

view on how projects are managed. 

To assess the reliability of the on-hold data, we compared the data generated 

from MIP to each region’s responses and discussed the on-hold project data 

with regional officials. We also “spot checked” for completeness and accuracy 

by reviewing the information provided by the regions to MIP. We found 

inconsistencies in some of the projects status during our interview with one 

region and also found some data was missing because the case numbers were 

not added to MIP. However, for the purpose of this report we determined that 

the data was sufficiently reliable. 

To determine whether quality reviews were conducted in accordance with 

FEMA’s guidance, we verified whether (1) mandatory QR checklists and selfcertifications were completed and uploaded in MIP; (2) there was 

documentation of a bypass request in MIP when project data failed a Data 

Verification Tool check; and (3) projects passed all required Data Verification 

Tool checks prior to FEMA issuing a flood map. 

We judgmentally selected 9 of 1,894 coastal and riverine projects from FEMA’s 

Risk MAP Progress website on July 7, 2016, that were prepared by production 

and technical services mapping partners and completed between May 2014 and 

July 2016. Production and technical services contractors and Cooperative 

Technical Partners (CTP) completed a total of 1,894 projects. However, our 

scope does not include projects completed by CTPs. The focus of our review 

was on riverine flooding; however, we included one coastal project in our 

sample as it was reviewed while developing our understanding of FEMA’s 

quality review process during our survey phaseǤ We selected one project for 

each of FEMA’s 10 regions except for Region 8, as we were unable to find in 

that region a production and technical services project that was completed 

during our test period. Additionally, we relied on the data provided in the 

FEMA’s Risk MAP Progress website and did not conduct further reliability tests 

of the information. We did not select more than nine projects because FEMA 

personnel stated that they were not overseeing the quality review process 

conducted by mapping partners. 

www.oig.dhs.gov 15 OIG-17-110 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We conducted this performance audit between March and December 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. 

The Office of Audits major contributors to this report are: Maureen Duddy, 

Deputy Assistant Inspector General for Audits; Carolyn Hicks, Director; Paul 

Exarchos, Audit Manager; Andrew Smith, Audit Manager; Jeff Mun, co-Auditor 

in-charge; Roger Thoet, co-Auditor in-charge, Corneliu Buzesan, Program 

Analyst; Steffanie Moore, Program Analyst; Aneet Marwaha, Program Analyst; 

Ellen Gallagher, Communications Analyst; and Juan Santana, Independent 

Referencer. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

FEMA Comments to the Draft Report 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 18 OIG-17-110 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 19 OIG-17-110 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 20 OIG-17-110 
 

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 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 21 OIG-17-110 
 

 

 

 

 

 

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