United States Government Accountability Office

GAO Testimony 

Before the Committee on Homeland 

Security and Governmental Affairs, 

U.S. Senate

HURRICANES KATRINA 

AND RITA DISASTER 

RELIEF 

Continued Findings of 

Fraud, Waste, and Abuse 

Statement of Greg Kutz, Managing Director 

Forensic Audits and Special Investigations 

John J. Ryan, Assistant Director 

Forensic Audits and Special Investigations 

For Release on Delivery

Expected at 10:00 a.m. EST 

Wednesday, December 6, 2006

 

GAO-07-252T 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

December 6, 2006

HURRICANES KATRINA AND RITA 

DISASTER RELIEF 

Continued Findings of Fraud, Waste, and 

Abuse 

Highlights of GAO-07-252T, a testimony to 

the Committee on Homeland Security and 

Governmental Affairs, U.S. Senate 

Hurricanes Katrina and Rita

destroyed homes and displaced

millions of individuals. While the

Federal Emergency Management 

Agency (FEMA) continues to 

respond to this disaster, GAO’s 

previous work identified significant 

control weaknesses—specifically

in FEMA’s Individuals and 

Households Program (IHP) and in 

the Department of Homeland 

Security’s (DHS) purchase card

program—resulting in significant 

fraud, waste, and abuse. 

Today’s testimony will address 

whether FEMA provided improper

and potentially fraudulent 

(1) rental assistance payments to 

registrants at the same time it was

providing free housing via trailers 

and apartments; (2) duplicate 

assistance payments to individuals

who claimed damages to the same

property for both hurricanes 

Katrina and Rita; and (3) IHP 

payments to non-U.S. residents 

who did not qualify for IHP. This 

testimony will also discuss (1) the

importance of fraud identification

and prevention, and (2) the results 

of our investigation into property 

FEMA bought using DHS purchase

cards. 

To address these objectives, GAO 

data mined and analyzed FEMA

records and interviewed city 

officials, university officials, and 

foreign students. GAO also traveled

to Louisiana and Texas to inspect 

selected property items and to

investigate improper housing 

payments to individuals living in

FEMA-provided housing. 

FEMA continued to lose tens of millions of dollars through potentially 

improper and/or fraudulent payments from both hurricanes Katrina and Rita. 

These payments include $17 million in rental assistance paid to individuals 

to whom FEMA had already provided free housing through trailers or 

apartments. In one case, FEMA provided free housing to 10 individuals in 

apartments in Plano, Texas, while at the same time it sent these individuals

$46,000 to cover out-of-pocket housing expenses. In addition, several of 

these individuals certified to FEMA that they needed rental assistance. 

FEMA made nearly $20 million in duplicate payments to thousands of 

individuals who claimed damages to the same property from both hurricanes 

Katrina and Rita. FEMA also made millions in potentially improper and/or 

fraudulent payments to nonqualified aliens who were not eligible for IHP. 

For example, FEMA paid at least $3 million to more than 500 ineligible

foreign students at four universities in the affected areas. This amount likely 

understates the total payments to ineligible foreign students because it does 

not cover all colleges and universities in the area. FEMA also provided 

potentially improper and/or fraudulent IHP assistance to other ineligible 

non-U.S. residents, despite having documentation indicating their 

ineligibility. 

Finally, FEMA’s difficulties in identifying and collecting improper payments 

further emphasized the importance of implementing an effective fraud, 

waste, and abuse prevention system. For example, GAO previously 

estimated improper and potentially fraudulent payments related to the IHP 

application process to be $1 billion through February 2006. As of November 

2006, FEMA identified about $290 million in improper payments and 

collected about $7 million. 

GAO Improper Payment Estimate and FEMA Reported Overpayments and Collections 

GAO’s previous work on the DHS purchase cards also showed significant 

problems with property accountability. Of 246 items we investigated that 

FEMA purchased for hurricane relief efforts using DHS’s purchase cards, 85 

items—or 34 percent—are still missing and presumed lost or stolen.

www.gao.gov/cgi-bin/getrpt?GAO-07-252T.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Gregory Kutz at 

(202) 512-7455 or kutzg@gao.gov. 
Chairman and Members of the Committee: 

Thank you for the opportunity to discuss our forensic audit and related 

investigations into the Federal Emergency Management Agency’s (FEMA) 

response to hurricanes Katrina and Rita. In several prior hearings, we 

testified that significant control weaknesses in FEMA’s Individuals and 

Households Program (IHP) and in the Department of Homeland Security’s 

(DHS) purchase card program have left the government vulnerable to 

significant fraud, waste, and abuse. In February 2006,1

 we testified before 

this Committee that specific control weaknesses in the IHP program 

resulted in improper expedited assistance payments and nonexistent 

controls left the government vulnerable to substantial fraud and abuse 

related to IHP. Several months later, in June 2006,2

 we testified on 

additional work performed whereby we projected that the weak or 

nonexistent controls resulted in an estimated $1 billion dollars in 

potentially fraudulent and improper IHP payments.3

 Most recently, in July 

2006,

4

 we testified before this Committee that control weaknesses in DHS’s 

purchase card program had resulted in fraud, waste, and abuse, including 

activity by FEMA related to hurricanes Katrina and Rita. Our purchase 

card work also showed that poor controls over property acquired 

primarily for hurricanes Katrina and Rita operations, including laptops, 

printers, global positioning system (GPS) units, and flat-bottom boats, 

resulted in lost, missing, or stolen assets. We have issued companion 

 1

GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s

Control Weaknesses Exposed the Government to Significant Fraud and Abuse, 

GAO-06-403T (Washington, D.C.: Feb. 13, 2006). 

2

GAO, Hurricanes Katrina and Rita Disaster Relief: Improper and Potentially

Fraudulent Individual Assistance Payments Estimated to Be Between $600 Million and 

$1.4 Billion, GAO-06-844T (Washington, D.C.: June 14, 2006). 

3

 To reach this estimate we followed a probability procedure based on random selections. 

Therefore, our sample is only one of a large number of samples that we might have drawn.

Since each sample could have provided different estimates, we expressed our confidence

in the precision of our particular sample’s results as a 95 percent confidence interval. The 

95 percent confidence interval surrounding the estimate of $1 billion ranges from $600 

million to $1.4 billion.

4

GAO, Purchase Cards: Control Weaknesses Leave DHS Highly Vulnerable to Fraudulent,

Improper, and Abusive Activity, GAO-06-957T (Washington, D.C.: July 19, 2006). This 

work was performed jointly with the DHS Office of Inspector General. 

Page 1 GAO-07-252T 
reports5

 following each of these testimonies that included numerous 

recommendations on how to address the weaknesses identified by our 

audit and investigative work. 

As we previously reported, the Robert T. Stafford Disaster Relief and

Emergency Assistance Act (Stafford Act)6

 provides the basis for IHP. IHP 

is a major component of the federal disaster response efforts designed to 

provide financial assistance to individuals and households that, as a direct

result of a major disaster, have necessary expenses and serious needs that 

cannot be met through other means. The Stafford Act allowed registrants 

to receive financial assistance up to a cap of $26,200 for disasters 

occurring in 2005. In early October 2006, FEMA reported to Congress that 

it had delivered approximately $7 billion in IHP aid for hurricanes Katrina 

and Rita. This IHP amount included expedited assistance, temporary 

housing assistance, repair and replacement of real and personal property, 

and other miscellaneous categories. 

Today’s testimony reflects new findings related to additional work we 

have performed since June 2006. The testimony will address whether 

FEMA provided potentially improper and/or fraudulent (1) rental 

assistance payments to registrants at the same time it was providing free 

housing via trailers and apartments; (2) duplicate assistance payments to 

individuals who claimed damages to the same property for both 

hurricanes Katrina and Rita; and (3) IHP payments to nonqualified aliens 

who did not qualify for IHP. This testimony will also discuss (1) the 

importance of fraud prevention, and (2) the results of our investigation 

into property bought by FEMA using DHS purchase cards, which was 

subsequently lost or stolen. For purposes of this testimony, potentially 

improper and/or fraudulent payments refers to payments made by FEMA 

based on potentially improper and/or fraudulent registration data 

submitted by IHP registrants. 

 5

GAO, Expedited Assistance for Victims of Hurricanes Katrina and Rita: FEMA’s

Control Weaknesses Exposed the Government to Significant Fraud and Abuse, 

GAO-06-655 (Washington, D.C.: June 16, 2006); GAO, Hurricanes Katrina and Rita: 

Unprecedented Challenges Exposed the Individuals and Households Program to Fraud

and Abuse; Actions Needed to Reduce Such Problems in Future, GAO-06-1013 

(Washington, D.C.: Sept. 27, 2006); and GAO and DHS Inspector General, Purchase Cards:

Control Weaknesses Leave DHS Highly Vulnerable to Fraudulent, Improper, and Abusive 

Activity, GAO-06-1117 (Washington, D.C.: Sept. 28, 2006). 

6

42 U.S.C. §5121-§5206. 

Page 2 GAO-07-252T 
To address these objectives, we compared information included in FEMA 

databases; performed data mining on FEMA databases; and interviewed 

officials in selected cities and universities, and foreign students. We also 

traveled to Louisiana and Texas to physically inspect selected items FEMA 

purchased for hurricane relief efforts. For details on our scope and 

methodology, see appendix I. We conducted our audit and investigations 

from June 2006 through November 2006. We conducted our audit work in 

accordance with generally accepted government auditing standards and 

conducted our investigative work in accordance with the standards 

prescribed by the President’s Council on Integrity and Efficiency. 

Our audit and investigative work on controls over FEMA disaster relief 

payments associated with hurricanes Katrina and Rita identified additional

potentially improper and/or fraudulent payments, including the following: 

Summary 

• Nearly $17 million in potentially improper and/or fraudulent rental 

assistance payments to individuals while they were living in trailers 

also paid for by FEMA. For example, after FEMA provided a trailer to a 

household—in January 2006—FEMA provided rental assistance 

payments to the same household in late January, February, and April of 

2006 totaling approximately $5,500. 

• FEMA provided potentially improper and/or fraudulent rental 

assistance payments to individuals living in FEMA-paid apartments. 

For example, FEMA made nearly $46,000 in rental assistance payments 

to at least 10 individuals living in apartments at the same time that the 

apartments were being paid for by FEMA through the city of Plano, 

Texas. Seven of 10 in this group self-certified to FEMA that they 

needed rental assistance, despite the fact that they were living in rentfree housing. Because of limitations in FEMA data, we were not able to 

identify the full extent of potentially improper rental assistance 

payments made to individuals in FEMA-paid apartments. 

• Nearly $20 million in potentially improper and/or fraudulent payments 

went to individuals who registered for both hurricanes Katrina and Rita 

assistance using the same property. With few exceptions, FEMA 

officials explained that victims of both disasters are entitled to only 

one set of IHP payments for the same damaged property. However, 

FEMA officials told us that they turned off the system edits that should 

have identified these types of duplicate payments to increase the speed 

with which FEMA could distribute disaster assistance. Consequently, 

FEMA paid over 7,000 individuals IHP assistance twice for the same 

property—once for Hurricane Katrina and once for Hurricane Rita. 

Page 3 GAO-07-252T 
These individuals received double payments for expedited assistance, 

rental assistance, and/or housing replacement. For example, FEMA 

records showed that one registrant received two housing replacement 

payments of $10,500 each, despite the fact that he had only one 

property to replace. 

• Millions of dollars of improper and potentially fraudulent payments 

went to nonqualified aliens, including foreign students and temporary 

workers. For example, FEMA improperly paid at least $3 million in IHP 

assistance to more than 500 ineligible foreign students at four 

universities. Further, FEMA provided IHP payments that included 

expedited assistance and personal property totaling more than 

$156,000 to 25 individuals who claimed to be foreign workers on 

temporary visas. FEMA made these payments despite having copies of 

the work visas for several individuals, which should have alerted FEMA 

that the temporary workers were not eligible for financial assistance. 

Because we did not obtain information from all universities in the Gulf 

region and because of unavailability of detailed data on other 

nonqualified legal aliens, we were not able to determine the magnitude 

of potentially improper and/or fraudulent payments in this area. 

• The small amount of money that FEMA has been able to collect from 

improper payments further demonstrates the need to have adequate

preventive controls. We previously reported that inadequate preventive

controls related to the IHP application process resulted in an estimated 

$1 billion of potentially improper and/or fraudulent payments through 

February 2006. In contrast, as of November 2006, FEMA had detected 

through its own processes about $290 million in overpayments. This 

overpayment amount, which FEMA refers to as recoupments, 

represents the improper payments that FEMA had detected and had 

issued letters requesting repayments. However, through November 

FEMA had only collected nearly $7 million of the about $290 million 

identified for recoupment. Collection of only $7 million of an estimated 

$1 billion of fraudulent and improper payments clearly supports the 

basic point we have previously made7

 that fraud prevention is far more 

efficient and effective than detection and collection. 

• Regarding the DHS purchase card program, we found overall problems 

with property items bought for hurricanes Katrina and Rita relief 

efforts using government purchase cards. For example, FEMA is still 

 7

GAO, Individual Disaster Assistance Programs: Framework for Fraud Prevention,

Detection, and Prosecution, GAO-06-954T (Washington, D.C.: July 12, 2006).

Page 4 GAO-07-252T 
unable to locate 48 of the143 missing items (e.g., laptop and printers) 

identified in our July 2006 testimony. Moreover, 37 items were missing 

from an additional 103 items that we investigated. Thus, over a year 

after being purchased, FEMA could not locate 85 of the 246 items (34 

percent) that we investigated, and are presumed lost or stolen. 

• Our investigation also revealed that although FEMA was in possession 

of 18 of the 20 flat-bottom boats it had purchased for hurricane relief 

efforts, FEMA had not received the title to any of these boats. Further, 

FEMA could not provide any information about the location of the 

remaining two boats, although local law enforcement officials informed 

us that they found one of the boats in a shed at the house of its 

previous owner. 

We found that FEMA provided nearly $17 million in potentially improper 

and/or fraudulent rental assistance payments to individuals already 

housed in other accommodations that FEMA provided through other 

disaster assistance programs. The Stafford Act prohibits FEMA from 

providing rental assistance payments under IHP to an applicant if 

temporary housing has been provided by any other source.8

 Despite this 

prohibition, FEMA did not have an effective process in place to compare 

IHP registrant data with data on individuals already housed in FEMApurchased trailers and FEMA-provided apartments. FEMA also failed to 

adequately advise victims that they were prohibited from receiving rental

assistance for the same period they occupied rent-free housing. 

Consequently, FEMA improperly paid nearly $17 million to over 8,600 

registrants after they had already moved into FEMA trailers. While the 

quality of FEMA data did not allow us to make similar calculations for the 

amount and number of individuals receiving rental assistance payments 

after they had been housed in FEMA-provided apartments, the amount 

could be substantial. 

Potentially Improper 

and/or Fraudulent 

Housing Assistance 

Payments Related to 

Trailers and 

Apartments 

In the aftermath of hurricanes Katrina and Rita, FEMA used various 

programs to house displaced victims, including financial assistance for 

rent and rent-free housing. Rent-free housing included trailers that FEMA 

purchased and apartments that FEMA either paid for directly or 

reimbursed state and local governments for after they paid landlords on 

behalf of the disaster victims. According to a FEMA official, to expedite

 8

42 U.S.C. §5155, C.F.R. §206.101. 

Page 5 GAO-07-252T 
apartment rental assistance, FEMA provided payments to over 100 

different state and local governments for the provision of rent-free 

apartments. 

By comparing information in two of FEMA’s databases—the FEMA 

Response and Recovery Applicant Tracking System (FRRATS) and the 

National Emergency Management Information System (NEMIS)—we 

calculated that FEMA improperly made rental assistance payments—

intended to cover out-of-pocket rental expenses—totaling nearly $17 

million to over 8,600 individuals after they had moved into FEMA-provided 

trailers.9

 Some received multiple rental assistance payments even after 

they moved into free FEMA-provided housing. In some instances, the 

payments were made based on potentially fraudulent claims because 

recipients typically have to certify to FEMA that they continued to need 

IHP rental assistance. 

Limitations in FEMA apartment data did not allow us to determine the 

magnitude of potentially duplicate rental assistance payment to 

individuals housed in rent-free apartments. In contrast to trailer data, 

which FEMA maintains in the FRRATS database, we could not validate 

accuracy or completeness of apartment data. According to FEMA officials, 

the accuracy of apartment data was questionable because it came from the 

over 100 state and local authorities who assisted in delivering housing aid 

for FEMA. The completeness of data was also at issue because FEMA did 

not ask states to collect registration data from individuals in rent-free 

apartments until well after the aid was provided, and therefore individuals

who may have left the rent-free apartments were not included in the data. 

Table 1 provides illustrative examples of duplicate rental assistance 

payments to registrants in FEMA trailers and rent-free apartments. 

 9

FEMA officials stated that they did not believe that the initial rental assistance payment,

provided to cover the first few months of rental housing, should be considered a 

duplication of benefits if it was provided to trailer residents. FEMA officials argued that 

this amount is designed to assist disaster victims in moving from temporary emergency

housing into a normal apartment or home lease situation. The United States District Court 

for the Eastern District of Louisiana expressed approval when FEMA permitted claimants 

to reapply for three months of IHP rental assistance even though they had already received

IHP rental assistance for that period where the claimants certified that the first IHP rental 

assistance was used for essential needs other than lodging and/or that they had not been 

notified the money could only be used for lodging. McWaters v. FEMA, Civ. Action. No. 05-

5488 (Order and Reasons dated 12/12/05 and 6/16/06). The court also permitted short term

lodging program participants to remain in their rent free lodging two weeks after receiving 

their rental assistance or the disapproval of their claim. Id. 

Page 6 GAO-07-252T 
Table 1: Examples of Duplicate and Potentially Improper and/or Fraudulent Housing Assistance Payments Related to FEMA 

Trailers and Apartments 

Case 

Amount of duplicate

and improper

payment 

Type/ location of 

FEMA-provided 

unit Details 

1 $46,000 Apartment/ Plano,

TX 

• 10 residents of an apartment complex applied and received rental assistance.

• At the same time, FEMA provided rent-free housing at the apartment in 

Plano, Texas. 

• FEMA records indicated that seven registrants certified to FEMA that they 

needed rental assistance, despite the fact that they lived in rent-free 

apartments. 

2 3,600 Apartment/ Austin,

TX 

• Registrant received free housing in September 2005 when the registrant 

moved into an apartment the city of Austin paid for on behalf of FEMA. 

• FEMA made rental assistance payments in September 2005, February 2006, 

and May 2006 totaling more than $3,600 at the same time that it paid $705

per month for the apartment. 

3 1,700 Apartment/

Houston, TX

• Registrant received assistance in February and a smaller payment in May 

2006 covering rent from February through May 2006. 

• Registrant received a rent-free apartment for the months of February, April, 

and May 2006. We were unable to confirm whether the registrant received

rent-free housing in March 2006 due to incomplete data. 

4 5,400 Trailer/ Slidell, LA • Registrant received trailer in mid-March 2006. 

• Registrant received two rental assistance payments totaling more than 

$5,400 in April and May 2006 for the time the registrant lived in the trailer. 

5 5,500 Trailer/ Lacombe,

LA 

• Five members of the same household registered and received IHP assistance 

using the same damaged address. 

• FEMA delivered a trailer to the damaged property in January 2006, but 

continued to provide rental assistance to four members of the same family in

January, February, and April 2006. 

• One interviewee informed us that the rental receipt that a family member 

provided to FEMA was fictitious. 

• In addition to the $5,500 in improper duplicative payments for trailer and 

rental assistance, the family also received over $6,000 in potentially improper 

and/or fraudulent payments by submitting multiple registrations. 

Source: GAO analysis of FEMA’s IHP trailer, data and apartment data from selected cities.

• Case 1 relates to a series of potentially improper and/or fraudulent IHP 

rental assistance payments totaling $46,000 made to 10 registrants 

already housed in rent-free housing. In this case, FEMA paid nearly 

$46,000 in rental assistance to 10 residents of an apartment complex in 

Plano, Texas, from September 2005 through June 2006. However, at 

about the same time period (October 2005 through March 2006), the 

city of Plano made payments totaling more than $74,000 directly to the 

apartment, for which it received reimbursements from FEMA. Of the 

total amount paid, $46,000 was duplicative and therefore potentially 

improper and/or fraudulent. Our review of FEMA records indicated 

Page 7 GAO-07-252T 
that 7 of the 10 individuals certified to FEMA that they were in need of 

rental assistance, even after they had been provided with free housing. 

Further, FEMA records showed that 7 provided rental receipts and/or 

leases that clearly indicated that the rent was paid by the city of Plano. 

• Case 5 relates to a family of five, all of whom registered for IHP using 

the same damaged address. Four registrations were duplicative and 

therefore payments on those registrations are potentially improper 

and/or fraudulent. Further, despite the fact that FEMA had installed a 

trailer on the damaged property in January 2006, FEMA continued to 

send rental assistance payments in late January, February, and April 

2006 totaling approximately $5,500. Further, a family member informed 

us that the family had moved back into the damaged home prior to the 

trailer being delivered. Consequently, when the trailer was delivered, it 

simply increased the living space for the household, and it was used by 

a family member who lived in the house prior to the hurricane. Further,

evidence we gathered during the course of the investigation indicated 

that a rental receipt provided to FEMA to justify continued need for 

rental assistance was fictitious, and that the family member who 

submitted the receipt had never paid rent to the supposed landlord. In 

addition to the $5,500 in improper duplicative rental assistance 

payments, we found that the family members also received at least 

$6,000 in other potentially improper and/or fraudulent IHP payments 

arising from the duplicate registrations. 

In the course of apartment-related audit and investigative work, we also 

identified 14 individuals who improperly received more than $75,000 in

disaster assistance using one apartment building as their hurricanedamaged address, even though the building had minimal damage and 

residents were not forced to evacuate. We provide further details in 

appendix II.

FEMA made nearly $20 million in duplicate payments to thousands of 

individuals who submitted claims for damages to the same primary 

residences from both hurricanes Katrina and Rita. With few exceptions, 

FEMA officials explained that victims of both disasters should not receive 

duplicate benefits for the same necessities and/or damages to the same 

property. However, in order to process disaster claims more quickly,

FEMA disabled a system edit check in NEMIS that could have alerted 

FEMA officials when the same individual applied for both disasters using 

the same identifying information. This system change resulted in nearly 

$20 million in duplicate payments being made based on duplicate 

registrations for hurricanes Katrina and Rita. 

Potentially Improper 

and/or Fraudulent 

IHP Assistance 

Payments to 

Individuals Claiming 

Damages from Both 

Hurricanes 

Page 8 GAO-07-252T 
In October 2005, FEMA officials informed us that the small amount of time 

between the impact of hurricanes Katrina and Rita had necessitated the 

issuance of new policy to prevent duplicate claims for the same damaged 

property for both hurricanes. FEMA officials said that, with few 

exceptions, the new policy specified that registrants were entitled to one 

payment for the same damage and/or need. FEMA explained to us that this

was necessary because most individuals did not have an opportunity to 

replace and/or repair damages they incurred from Hurricane Katrina 

before Hurricane Rita struck, and because their displacement was likely 

caused by both hurricanes. At the time, FEMA officials informed us that 

they had available a system edit check in NEMIS intended to alert FEMA 

system administrators when the same individual applies for assistance for 

both disasters, so that FEMA personnel could perform a manual review 

prior to payments being made. 

Despite having a control available, we identified through our review of 

FEMA’s NEMIS that FEMA made payments to about 7,600 individuals who 

used the same social security number (SSN) and hurricane-damaged 

addresses for their Hurricane Katrina registration that they used for their 

Hurricane Rita registration. Subsequently, FEMA officials informed us that 

these duplicate payments occurred because FEMA disabled the system 

edit check feature. FEMA stated that they deactivated the system edit 

check in order to process disaster claims more quickly, because the 

manual review process that they had intended for these duplicate 

registrations would have held up many eligible payments. Because of this, 

FEMA paid nearly $20 million in duplicate payments to individuals who 

submitted duplicate registrations using the same SSNs and damaged 

addresses. The nearly $20 million includes duplicate payments for all areas 

of IHP assistance, including expedited assistance, rental assistance, 

housing replacement payments, or a combination of these. In five of the 

six cases where we performed investigative work, the same individual 

received duplicate payments to replace the same damaged property. The

individuals also failed to provide FEMA with evidence that they had

replaced the items or conducted repair work after Hurricane Katrina, only 

to have those items or that work destroyed again by Hurricane Rita. In all 

cases, FEMA performed its first physical inspection of the damaged 

property after the passing of both hurricanes. 

In addition to other IHP payment types, all six individuals we investigated

also received IHP personal property payments to compensate them for lost 

or destroyed household items, twice—once for Hurricane Katrina and 

again for Hurricane Rita. In one case, an individual received multiple 

payments for more than $27,000—over the $26,200 cap—for personal 

Page 9 GAO-07-252T 
property replacement alone. In total, this individual received more than 

$51,800 in IHP assistance, of which at least $25,000 is potentially improper 

and/or fraudulent. According to FEMA records, another registrant 

received two housing replacement payments of $10,500 each, despite the 

fact that the individual had only one property to replace. 

FEMA made at least $3 million dollars of improper and potentially 

fraudulent payments to nonqualified aliens who were not eligible for IHP 

financial assistance. U.S. law specifically prohibits nonqualified aliens, 

such as foreign students and workers on temporary visas, from receiving 

financial assistance in case of disaster.10 However, FEMA did not have 

implementing controls in place, such as an agreement in place with other 

government agencies, such as the Social Security Administration (SSA), to 

identify nonqualified aliens and prevent them from receiving such 

assistance. Consequently, FEMA paid at least $3 million to foreign 

students from four selected universities. FEMA also made payments to 

other nonqualified aliens, such as workers on temporary visas. However, 

because of a lack of data on other nonqualified aliens, we were unable

determine the magnitude of any such improper payments. FEMA made 

such payments even in cases in which FEMA received information 

indicating that the alien applying for assistance was not qualified to 

receive financial disaster assistance. 

Potentially Improper 

and/or Fraudulent 

Payments to 

Nonqualified Aliens 

IHP Payments to Ineligible 

International Students 

The destruction caused by hurricanes Katrina and Rita affected thousands 

of college students in the fall of 2005. As with other U.S. citizens and 

qualified aliens, college students who were able to demonstrate losses 

were eligible to receive IHP payments to assist them in recovering from 

the disaster. However, U.S. law11 and FEMA policy specifically prohibits 

students in the United States on student visas from receiving IHP 

assistance. By comparing data provided by four universities in Louisiana 

and Texas against registrant information in NEMIS, we determined that 

FEMA improperly provided at least $3 million in financial assistance, in 

the form of IHP payments, to more than 500 students in the United States 

on student visas. This amount could understate the total payments to 

 108 U.S.C. §1611 allows the U.S. government to provide nonfinancial, in kind emergency 

disaster relief, including short term shelter to temporary legal aliens (nonqualified aliens) 

after a disaster, but prohibits them from receiving financial assistance. 

118 U.S.C. §1611. 

Page 10 GAO-07-252T 
ineligible foreign students because we requested information on 

international students from only four of the colleges and universities in the 

areas affected by hurricanes Katrina and Rita. 

Our interviews of school officials and several of the ineligible students 

stated that they received misleading information from FEMA personnel. 

Specifically, officials at several universities informed us that FEMA 

personnel actively encouraged all students—including international 

students—to register for IHP assistance. Despite being ineligible for 

financial disaster assistance, many international students with whom we 

spoke stated that FEMA officials told them they were eligible to receive 

IHP payments and should apply for aid. 

We found that FEMA made these payments despite evidence provided to 

FEMA by students—specifically their student visas—that indicated that 

they were not eligible for cash assistance. Further, consistent with a 

finding we reported on previously, FEMA could have identified these 

students if it had validated their identities with SSA prior to issuing IHP 

payments. In fact, more than 400 of the students reported as foreign by the 

four universities were also identified by SSA as non-U.S. citizens. Table 2 

displays some examples of ineligible students and payments they received. 

Page 11 GAO-07-252T 
Table 2: Improper Payments Made to Ineligible International Students 

Case Location

Number of 

payments/ 

amount Type of payments

1 Louisiana 6/$25,500 Expedited assistance, rental assistance, 

transportation assistance, and personal property 

replacement 

2 Louisiana 6/$22,500 Expedited assistance, rental assistance, housing 

repair, and personal property replacement 

3 Louisiana 3/$17,700 Rental assistance and personal property 

replacement 

4 Louisiana 4/$16,400 Expedited assistance, rental assistance, and 

housing repair

5 Louisiana 3/$17,000 Rental assistance and personal property 

replacement 

6 Louisiana 4/$10,900 Expedited assistance, rental assistance, and 

transportation replacement 

7 Texas 3/$7,700 Expedited assistance, rental assistance, and 

personal property replacement

8 Louisiana 3/$6,500 Expedited assistance, rental assistance, and 

personal property replacement

Source: GAO analysis of university data and FEMA IHP data. 

• Case 4 concerns a student in New Orleans who received more than 

$16,000 in FEMA payments, including payments for expedited

assistance, rental assistance, and personal property replacement. 

According to NEMIS data, the student’s damaged property was in the 

hardest-hit area of the city, and therefore the student’s qualification for 

IHP was performed through geospatial mapping, while his identity was 

also validated through a third-party contractor. The student told us that 

he repeatedly informed FEMA personnel that he was an international 

student on an F1 visa, and was told each time that he qualified for 

assistance. In addition to receiving rental payments from FEMA, the 

student also received a trailer in April 2006. The student stated that he 

received a letter from FEMA in August 2006 asking for the money back. 

Further, he is concerned because a FEMA representative informed him 

that he was not immune to legal action for receiving payments he was 

ineligible for, despite the fact that he had informed FEMA of his status 

all along. 

• Case 6 involves an international student in New Orleans who received 

nearly $11,000 in FEMA payments. The student had a student visa from 

Page 12 GAO-07-252T 
Brazil, and stated on his IHP registration that he owned a home in the 

New Orleans area. The registrant informed us that he applied via 

phone, and that he took care to inform the FEMA personnel that he 

was an international student. According to this student, in this and 

subsequent conversations with FEMA employees (one of whom was a 

supervisor at a relief center he visited), he was repeatedly told that he 

qualified for assistance despite his international student status. Our 

review of FEMA records confirmed the student’s assertion that he 

provided FEMA with a copy of his visa. In fact, a copy of his visa was 

scanned into NEMIS and had a note next to it stating “Proof of 

Qualified Alien,” despite the fact that the visa clearly showed he was an 

international student and therefore ineligible. 

• In case 8, a student in New Orleans at the time of Hurricane Katrina 

received three payments totaling $6,500 covering expedited assistance, 

rental assistance, and personal property replacement even though he 

repeatedly told FEMA representatives that he was an international 

student. The student registered for aid via FEMA’s Web site using a 

valid SSN. The student told us that the SSN was given to him because 

he was allowed to work in the United States. He stated that during the 

registration process, he did not find any information that made him 

aware that he was not eligible for assistance. After registering online, 

he stated that he also contacted FEMA call center employees and made 

them aware that he was not a U.S. citizen and was in the country on a 

student visa, and said he was told by call center employees that he was 

eligible. The student informed us that during an inspection process, the 

inspector certified that he was a qualified alien even after he showed 

the inspector his visa. He subsequently received more than $2,000 for 

property replacement based on the inspection. However, because the 

student’s visa was not scanned into FEMA’s system, we could not 

corroborate his statement that he repeatedly informed FEMA of his 

status. 

Payments to Other 

Nonqualified Aliens 

We also found that weaknesses in FEMA’s controls resulted in improper 

and/or potentially fraudulent IHP payments being made to other 

nonqualified aliens, such as workers in the United States on temporary 

work visas. Because of the unavailability of detailed data on other 

nonqualified aliens, we were unable to calculate the magnitude of this 

problem. However, our investigative work uncovered 25 cases where 

FEMA provided improper payments to nonqualified temporary workers. 

Specifically, we found that FEMA provided 50 disaster assistance 

payments totaling nearly $156,000 to 25 individuals who worked at a crab 

processing facility, despite the fact that FEMA records clearly showed that 

Page 13 GAO-07-252T 
11 individuals were in the United States on temporary work visas, and 

were therefore ineligible for IHP assistance.12 These payments included 

expedited assistance payments of $2,000 and payments of over $10,000 for 

replacement of property. Some registrants received as much as $15,000 in

IHP payments. In one instance, the registrant’s file at FEMA contained a

copy of a FEMA flier specifically indicating that aliens in the United States

on work visas were not eligible for IHP. Next to the flier was a copy of the 

registrant’s temporary work visa. Despite clearly having evidence that he

was ineligible for IHP payments, FEMA paid this registrant more than 

$15,000 in IHP assistance. 

Although we were not able to validate that all 25 registrants possessed 

work visas, we were informed by the registrants’ employer that all 25

employees brought their work visa documents with them to FEMA when 

they filed the disaster claims. However, data from SSA indicated that only

14 of the 25 employees used valid SSNs on their FEMA application.13 The 

remaining 11 individuals provided SSNs to FEMA that were never issued 

or belonged to other individuals in order to get IHP assistance. Payments 

made to the 11 workers who submitted fictitious information to FEMA are

therefore potentially fraudulent. 

We previously reported that inadequate preventive controls related to the 

IHP application process resulted in an estimated $1 billion of potentially 

improper and/or fraudulent payments through February 2006. As of 

November 2006, FEMA had detected through its own processes about $290 

million in overpayments and had collected nearly $7 million of the about 

$290 million identified as improper. Collection of only $7 million of an 

estimated $1 billion of potentially improper and/or fraudulent payments 

clearly supports the basic point we have previously made, that fraud 

prevention is far more effective and less costly than detection and 

monitoring. 

Ineffective Detective 

Controls Point to 

Need for Better 

Preventive Controls 

 12According to the owner of the crab processing facility, the remaining 14 individuals were 

also in the United States as temporary workers, a fact that we were unable to validate. We 

have referred the 25 individuals to the Katrina Fraud Task Force for further investigation. 

13Foreign workers who are admitted legally into the United States are issued SSNs. 

Page 14 GAO-07-252T 
In June 2006, we testified that an estimated $1 billion was potentially 

improper and/or fraudulent. We derived this estimate from statistical 

sampling work we conducted on registrations submitted to FEMA as of 

mid-February 2006. We also reported that this estimate potentially 

understates the total potentially improper and/or fraudulent payments 

because the scope of our statistical sampling work did not include 

verifying for insurance or actual property damage, among others things. 

As of November 2006, FEMA reported that it had identified about $290 

million in overpayments to nearly 60,000 registrants. This overpayment, 

which FEMA refers to as recoupments, represents the improper payments 

that FEMA reported it had detected and for which it had issued collection 

letters. According to FEMA officials, the payments identified as improper 

were based on cases referred to the fraud hotlines and registrations that 

met specific criteria of being more likely improper. 

Although FEMA had identified about $290 million in overpayments, to date 

FEMA had collected nearly $7 million. We did not validate the potential

collection amount. However, the amount that FEMA had collected on

overpayments related to hurricanes Katrina and Rita supports our prior 

statements that detective controls, while an important element of a fraud 

prevention program, are more costly and not as effective as preventive

controls. As FEMA’s historical experience demonstrated, once a payment 

had been disbursed because of weak preventive controls, it is difficult to 

identify individuals who received the improper payments, contact those 

individuals, and collect on those payments. As discussed previously, when 

system edit checks that should occur during the processing of disaster 

registration are circumvented, significant improper payments occur that 

require extensive data mining and follow-up actions to identify and 

recover improper payments. 

In addition to the difficulties in collecting overpayments, there are 

limitations to the ability of detective controls in identifying all instances of 

overpayments. For example, our conversations with several foreign 

students indicate that although some have received recoupment letters, 

others have not. 

FEMA’s Detection Controls 

Are Not Effective at 

Identifying All Potentially 

Improper and/or 

Fraudulent Payments 

FEMA Had Not Issued 

Recoupment Notice to 

GAO Registrations

The limitations of detective controls are demonstrated through GAO’s own 

experience with the FEMA registration, payment, and recoupment 

processes. As we testified previously, GAO submitted a number of 

registrations using false identities and fictitious addresses to test the 

effectiveness of FEMA’s internal controls. We also testified that we 

Page 15 GAO-07-252T 
received payments on registrations we submitted. However, to date, we 

had not received recoupment notices from FEMA indicating that it had 

identified the undercover registrations that GAO submitted. After our last 

testimony in June of 2006, we received another payment of more than 

$3,200 for rental assistance on a property that did not exist. In total, we 

received six payments on five registrations using falsified information, 

without receiving any recoupment notices from FEMA. 

We found weak accountability over FEMA property bought for hurricanes 

Katrina and Rita relief efforts using government purchase cards. Our 

investigation revealed that DHS overstated the number of items FEMA had 

actually located on the day of our July16, 2006, testimony and that 

additional items are missing. In total, of the 246 laptops, printers, flatbottom boats, and GPS units that we investigated for this testimony, 85 

items are missing and presumed lost or stolen. Moreover, during the 

course of our investigation, we found that FEMA did not have titles to any 

of the 20 flat-bottom boats it purchased for hurricanes Katrina and Rita. 

The fact that FEMA could not locate two of the flat-bottom boats raises 

additional concerns about DHS’s accountable property controls. 

FEMA Cannot 

Adequately Track Its 

Property 

Missing Items FEMA 

Purchased for Hurricane 

Relief 

As part of our July 19, 2006, testimony, we reported that poor controls 

over property acquired with DHS purchase cards may have resulted in lost 

or misappropriated assets. Specifically, we reported that FEMA could not 

account for 143 items purchased in September and October 2005 for 

Hurricane Katrina and Hurricane Rita relief efforts. On the morning of the 

testimony, DHS sent your office an e-mail indicating that 87 of the 143 

items had been found.14 At the hearing, DHS’s Chief Financial Officer 

reiterated that most of the missing property had been found, but 

acknowledged that the items had not yet been physically verified. 

Our investigation revealed that DHS’s July 19 e-mail overstated the number 

of items FEMA had located. By October 2006, a year after the property was 

purchased, we could only account for 79 of the 87 items that FEMA 

claimed it had found.15 In addition, of the 143 items that we reported as 

 14In our testimony, we reported as missing 107 laptop computers, 22 printers, 12 flat-bottom 

boats, and 2 GPS units. DHS’s e-mail claimed that FEMA found 74 of the 107 missing 

laptops, all 12 missing flat-bottom boats, and 1 of the 2 missing GPS units. The e-mail also

stated that FEMA was in the process of locating the missing printers. 

15Specifically, we found 69 printers and 10 boats. 

Page 16 GAO-07-252T 
missing in our July testimony, 48 are still missing and presumed lost or 

stolen. Moreover, 37 of items were missing from an additional 103 new 

items we investigated. In total, of the 246 items we investigated for this 

testimony, 85 items (34 percent) are lost or stolen.16 A November 27 DHS 

memo supports the results of this investigation, acknowledging that many

items purchased for hurricane relief efforts are still missing. Figure 1 

details the results of our investigative work as of October 16, 2006.

17

Figure 1: Status of Property as of October 16, 2006 

 16We were able to locate eight printers because we discovered that the bar codes FEMA 

reported as being assigned to the serial numbers on the printers had actually been affixed

to different items. Consequently, when FEMA staff tried to locate these printers using their 

own bar code information, they could not find them—even though the printers actually 

were in FEMA’s possession.

17After October 16, FEMA sent us additional photographs of laptops, printers, and GPS 

units. However, because we received this information after our October 16 deadline, we did 

not include it as part of our final property count for the purposes of this testimony. 

Page 17 GAO-07-252T 
In our July 2006 testimony, we also reported on several issues surrounding 

the purchase of 20 flat-bottom boats needed for hurricane relief efforts. 

Specifically, we found that FEMA paid $208,000—about twice the retail 

price—to a broker, who in turn obtained the boats (17 new and 3 used) 

from several different retailers. Further, although the broker billed FEMA 

and was paid for all 20 of the boats, he failed to pay one retailer that 

provided 11 of the boats. The retailer subsequently reported the boats as 

stolen and did not provide FEMA with title to the boats. Consequently, in

our testimony, we concluded that FEMA paid for, but did not receive title 

to, at least 11 of the boats. 

However, upon further investigation, we found that FEMA also did not 

have title to the remaining 9 boats. Thus, FEMA did not have title to any of 

the boats. Specifically, our searches for boat titles found that no transfer 

of title and/or registration had taken place on any of the 17 new boats, that 

is, the serial numbers were “not on file.” Of the remaining 3 used boats, 

title searches revealed that all 3 remain registered to their previous 

owners. 

Furthermore, FEMA could not provide us with any information about the 

two boats that are still not in its possession as of October 2006. However, 

using the serial numbers and manufacturer information on the make and 

model, local law enforcement located one of the boats in a shed at the

house of its previous owner. According to the previous owner, he sold the 

boat to FEMA and delivered it to the New Orleans Convention Center in 

September 2005. In March 2006, he received a call from the New Orleans 

Convention Center requesting that he retrieve his abandoned boat. When

he went to retrieve the boat, he found that the tires on the boat’s trailer 

were flat, the boat’s battery had been removed, and the anchor rope had 

been cut. This boat is one of the three still registered under its previous 

owner’s name and no application for transfer of title has been recorded.

Ineffective preventive controls for FEMA’s IHP have resulted in 

substantial fraudulent and improper payments. The additional examples of

potentially fraudulent and improper payments in our testimony today 

further show that our estimate of $1 billion in improper and/or fraudulent 

payments through February is likely understated. With respect to property 

bought with government purchase cards, items not found 1 year after they 

were purchased, and over 8 months after we selected them for 

investigation, shows that ineffective FEMA property accountability 

controls resulted in lost or stolen computers, printers, and GPS units. 

Title and Location of FlatBottom Boats 

Conclusions 

Page 18 GAO-07-252T 
We have provided 25 recommendations to DHS and FEMA to improve 

management of IHP and the purchase card program. FEMA and DHS had 

fully concurred with 19 recommendations, and substantially or partially 

concurred with the remaining 6 recommendations. DHS and FEMA also 

reported that they have taken actions, or plan to take actions, to 

implement many of our recommendations; however, we have not 

determined if these actions adequately address our recommendations. If 

properly implemented, our prior recommendations should help to address 

control weaknesses identified in this testimony. As with prior work, we 

will refer cases we deem to be potentially fraudulent to the Katrina Fraud 

Task Force for further investigation.

Madam Chairman and Members of the Committee, this concludes my 

statement. Special Agent Ryan and I would be pleased to answer any 

questions that you or other Members of the Committee may have at this 

time. 

For further information about this testimony, please contact Gregory D. 

Kutz at (202) 512-7455 or kutzg@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this testimony. The individuals who made major contributions to this 

testimony were Kord Basnight, Gary Bianchi, Matthew Brown, Norman 

Burrell, Jennifer Costello, Thomas Dawson, Dennis Fauber, Christopher 

Forys, Alberto Garza, Adam Hatton, Christine Hodakievic, Ryan Holden, 

Jason Kelly, John Ledford, Barbara Lewis, Jonathan Meyer, Andrew 

McIntosh, Kristen Plungas, John Ryan, Viny Talwar, Tuyet-Quan Thai, and

Matthew Valenta. 

Contacts and 

Acknowledgments 

Page 19 GAO-07-252T 
Page 20 GAO-07-252T 

Appendix I: Scope and Methodology 

To assess whether the Federal Emergency Management Agency (FEMA) 

provided potentially improper and/or fraudulent rental payments to 

individuals at the same time it was providing the registrant’s free lodging 

in FEMA trailers and rent-free (i.e., FEMA-provided) apartments, we 

interviewed FEMA officials, reviewed Title 8 of the United States Code, 

and reviewed the Stafford Act (Pub. L. 93-288) and its implementing 

regulations. We obtained the FEMA Individuals and Households Program 

(IHP) databases as of June 2006 and data on individuals residing in FEMA 

trailers and rent-free apartments. We performed data reliability 

assessment for these databases. In addition, we validated that the FEMA 

IHP database was complete and reliable by comparing the total payment 

against reports FEMA provided to the Appropriations Committee on 

hurricanes Katrina and Rita disbursements. We then compared FEMA paid 

housing data to IHP registration data to determine whether FEMA 

provided duplicate benefits to the same registrants. We also conducted 

field visits to Texas and Louisiana to view the property and interview 

individuals who received IHP payments after they had moved into free 

housing. While we were able to determine the number of individuals 

staying in FEMA trailers who received duplicate housing assistance, the 

data related to individuals staying in FEMA-provided apartments were not 

sufficiently reliable for us to perform the same analysis. 

To determine whether FEMA made duplicate payments to individuals who 

claimed damages for both hurricanes Katrina and Rita using the same 

damaged addresses, we compared the social security numbers and 

damaged addresses maintained in the FEMA databases for hurricanes 

Katrina and Rita, and reviewed National Emergency Management 

Information System (NEMIS) data on selected individuals. 

To determine whether FEMA made potentially improper payments to 

ineligible foreign students, we contacted officials at four Louisiana and

Texas universities and obtained the names and identifying numbers of 

enrolled foreign students. We compared the listing of students provided by

the universities to FEMA payment data. We also interviewed foreign 

students at those four schools receiving IHP assistance in order to 

determine what guidance FEMA provided them on eligibility. We also 

conducted investigative work to determine whether FEMA made improper 

and potentially fraudulent payments to nonqualified aliens, such as those 

in the United States on work visas. Because we did not receive data on all 

foreign students and nonqualified aliens in the United States, we were not 

able to determine the magnitude of potentially improper and fraudulent 

payments to these individuals. Further, because of data availability issues, 

our work was not designed to identify illegal aliens receiving improper 
payments. We also received FEMA data on its recoupment program, but 

did not validate data on identified overpayments and collections provided

to us by FEMA officials. 

To conduct our investigation into the Department of Homeland Security 

(DHS) purchase card program, we traveled to New Orleans and Baton 

Rouge, Louisiana, and Fort Worth, Texas, in September 2006, to physically 

inspect selected property. If we could not physically inspect the property 

during our visit, we requested that DHS, FEMA, or the New Orleans Police 

Department send us a clear photograph of the property and its serial 

number as proof of possession. We ultimately requested that photographic 

evidence be sent to us no later than October 16, 2006, nearly a year after 

most of the property was acquired. 

To obtain information on the case study detailed in appendix II, we 

reviewed data from the U.S. Department of the Treasury’s Financial 

Management Service, FEMA’s NEMIS database, the Texas Department of 

Motor Vehicles, the Social Security Administration, and the U.S. Postal 

Service, and we conducted field investigations. 

We conducted our audit and investigations from June 2006 through 

November 2006. We conducted our audit work in accordance with 

generally accepted government auditing standards and conducted our 

investigative work in accordance with the standards prescribed by the 

President’s Council on Integrity and Efficiency. 

Page 21 GAO-07-252T 
Page 22 GAO-07-252T 

Appendix II: Potentially Improper and/or 

Fraudulent Rental Assistance Payments Case 

Study 

When Hurricane Katrina came ashore in late August 2005, 15 of the 16 total 

units in a single Gulfport, Mississippi, apartment building were occupied 

by tenants. The landlord of this building told us that damage to the 

apartment building was minimal. Although one apartment had a broken 

window and some personal property damage, the only real effect of the 

hurricane was water damage from rain and water seepage from missing 

roof tiles. The landlord also said that anyone who left after Hurricane 

Katrina did so voluntarily, and that they were not required (e.g., forced) to 

leave as a result of damage by the storm. 

During a visit to the apartment building, we spoke to the landlord about an 

individual we identified as receiving potentially improper rental assistance 

payments. Subsequently, we conducted additional data mining on the 

apartment address to determine whether other tenants applied for and 

received FEMA disaster assistance. We found that 8 tenants of this 

apartment building received FEMA disaster assistance. The remaining 7 

tenants did not file any disaster assistances claims, as a result of being 

displaced because of uninhabitable or inaccessible living quarters as a 

result of Hurricane Katrina. In addition, we were able to confirm with the 

building landlord that 6 additional individuals who did not live at the 

apartment building at the time of hurricane Katrina also made disaster 

assistance claims. Table 3 lists 14 individuals who improperly received

disaster assistance using the apartment building as their hurricanedamaged address. 
Table 3: Apartment Building Tenants Receiving Disaster Assistance

Individual Date applied Notes IHP assistance

1 9-6-2005 Lived at apartment during storm $4,358

2 9-6-2005 Never lived at address 3,810

3 9-7-2005 Lived at apartment during storm 26,200

4 9-9-2005 Lived at apartment during storm 772

5 9-9-2005 Lived at apartment during storm 1,725

6 9-10-2005 Lived at apartment during storm 7,160

7 9-12-2005 Moved out before storm 4,358

8 9-12-2005 Lived at apartment during storm 4,358

9 9-14-2005 Lived at apartment during storm 2,000

10 9-16-2005 Never lived at address 2,000

11 9-19-2005 Evicted before storm 8,716

12 9-21-2005 Never lived at address 2,000

13 9-24-2005 Moved out before storm 4,358

14 9-24-2005 Lived at apartment during storm 4,358

Total $76,173

Source: GAO analysis of FEMA data. 

Page 23 GAO-07-252T (192226) 
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