DEPARTMENT OF HOMELAND SECURITY

Office of Inspector General

Office of Audits

An Audit of Distributing and Spending

 “First Responder” Grant Funds

OIG-04-15 March 2004

Preface

The Department of Homeland Security (DHS) Offi ce of Inspector General (OIG) was established 

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

General Act of 1978. This is one of a series of audit, inspection, investigative, and special reports 

prepared by the OIG periodically as part of its oversight responsibility with respect to DHS to 

identify and prevent fraud, waste, abuse, and mismanagement.

This report is the result of an assessment of the strengths and weaknesses of the program, 

operation, or function under review. It is based on interviews with employees and offi cials of 

relevant agencies and institutions, direct observations, and a review of applicable documents.

The recommendations herein, if any, have been developed on the basis of the best knowledge 

available to the OIG, and have been discussed in draft with those responsible for implementation. 

It is my hope that this report will result in more effective, effi cient, and/or economical operations. 

I express my appreciation to all of those who contributed to the preparation of this report.

Clark Kent Ervin

Inspector General

An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 1

Contents

Introduction.................................................................................................................................... 3

Results in Brief .............................................................................................................................. 3

Background.................................................................................................................................... 4

States and Locals Slow to Spend Funds, Although More Had Been Committed and Obligated .. 6

 Funds Awarded and Drawn Down by the States................................................................ 6

 Funds Obligated and Spent by the States........................................................................... 8

ODP Processing Times Have Improved but State and Local Delays Continue............................. 9

Reasons for Delays ...................................................................................................................... 11

Monitoring and Measuring Performance ..................................................................................... 16

Consolidation of Preparedness Grants......................................................................................... 17

Conclusion and Recommendations.............................................................................................. 18

Appendices

Appendix A: Purpose, Scope, and Methodology...................................................................20

Appendix B: State and Local Jurisdictions Visited During the Audit.................................. 21

Appendix C: List of FY 2002 SDPP and FY 2003 SHSGP Awards to States.......................25

Appendix D: List of FY 2002 SDPP, FY 2003 SHSGP and SHSGP II Draw Downs...........27

Appendix E: Recommendations............................................................................................29

Appendix F: Management Comments ................................................................................. 30

Appendix G: OIG Analysis of Management’s Comments ....................................................43

Appendix H: Major Contributors to this Report................................................................... 45

Appendix I: Report Distribution ......................................................................................... 46
Page 2 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds

Contents

Abbreviations

DHS Department of Homeland Security

ODP Office for Domestic Preparedness

OIG Office of Inspector General

SDPP State Domestic Preparedness Program

SHSGP State Homeland Security Grant Program

SHSGP II State Homeland Security Grant Program, Part II 

DOD Department of Defense

DOJ Department of Justice

OJP Office of Justice Programs

GMS Grants Management System
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 3

OIG

Department of Homeland Security

Office of Inspector General

Introduction

Spurred by the events of September 11, 2001, Congress, state and local 

politicians, first responders, and the general public have become increasingly 

aware of the need to improve first responder preparedness for terrorist incidents. 

Federal funding for first responder grants increased 2,375 percent from 1999 to 

2003. However, reports by recipients of the funds have criticized the slow rate at 

which the funds are being distributed. 

This report describes the results of our review of the overall award, distribution, 

and spending of first responder grant funds awarded under the FY 2002 State 

Domestic Preparedness Program (SDPP), the FY 2003 State Homeland Security 

Grant Program (SHSGP), and the FY 2003 State Homeland Security Grant 

Program Part II (SHSGP II). Throughout this report, the term “first responder 

grants,” refers to all three grant programs. Department of Homeland Security 

(DHS) Office for Domestic Preparedness (ODP) is responsible for the programs.

OIG will be conducting independent audits of individual states’ management of 

first responder grants. Those audits will address how effectively the states are 

using grant funds and whether they are complying with grant requirements. In 

addition, we will conduct an audit to evaluate the effectiveness of ODP’s State 

Homeland Security Assessment and Strategy process. This process includes the 

use of a data collection tool to assist states in conducting threat, risk, and needs 

assessments. 

Results in Brief

States, local jurisdictions, and first responder organizations have been slow 

to receive and spend ODP first responder grant funds. As of February 2004, 

the majority of the $882 million in FY 2002 SDPP and FY 2003 SHSGP first 

responder grant funds were awarded by ODP but still remained in the U.S. 

Treasury. The majority of the $1.5 billion awarded in SHSGP II funds also 

remained with the U.S. Treasury. ODP statistics show drawdowns1 of 36 percent, 

1

 The term, “drawdowns,” refers to grant funds disbursed from federal accounts to state grantees to be spent on approved 

equipment, training, and exercises.
Page 4 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

13 percent, and 10 percent, respectively. However, those statistics are somewhat 

misleading, and the spending picture is not as bad as it appears. In some 

instances, states and local jurisdictions had delayed spending funds pending the 

completion of state-wide risk assessments and homeland security strategies and 

the development of detailed spending plans, believing that spending the funds 

wisely was more important than spending them immediately. In addition to 

delays caused by states’ developing strategies and detailed plans for spending the 

funds wisely, we identified numerous other reasons for delayed spending. While 

some of the delays are unavoidable, others can be reduced. ODP’s application 

process was not a major reason for delays. For the most part, state officials 

praised ODP and believed that ODP processed grant applications in a timely 

manner. 

To ensure that the nation’s first responders are prepared for incidents of terrorism, 

ODP should: 1) require more meaningful reporting by grantees and develop 

performance standards that can be used to measure the overall success of the 

grant programs; 2) assist state planning efforts by accelerating the development 

of federal guidelines for first responder capabilities, equipment, training, and 

preparedness exercises; and 3) work with grantees to identify and publicize best 

practices and strategies that speed spending. 

DHS recently proposed a consolidation of its preparedness grant programs, 

including first responder terrorism grants, and combining ODP and the Office 

of State and Local Coordination into one office. Through this consolidation, 

DHS intends to correct its fragmented approach to delivering preparedness grant 

programs, streamline the grant application process, and better coordinate federal, 

state, and local grant funding distribution and operations. 

Background

In 1996, Congress tasked the Department of Defense (DOD) with enhancing 

the capability of federal, state, and local emergency responders in incidents 

that involve nuclear, biological, or chemical terrorism. DOD began by offering 

and managing equipment loans to 68 cities for training and personal protection 

equipment.2 In 1998, the Department of Justice’s (DOJ) Office of Justice 

Programs (OJP) began offering its own preparedness grants to cities through 

its Office for State and Local Domestic Preparedness Support, which was later 

renamed the “Office for Domestic Preparedness (ODP).” In 2000, ODP was 

2

 Referred to as the Nunn-Lugar-Domenici Domestic Preparedness Program.
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 5

given responsibility for completing DOD’s preparedness grant program. Over 

the years, the grant program grew slowly and shifted from grants directly to cities 

to grants to states, which were sub-granted to local jurisdictions. Subsequently, 

the program was expanded from funding just equipment to include the cost of 

administration, training, planning, and preparedness exercises. Funding for the 

program increased from $83.53 million in 1999 to over $2 billion in FY 2003.

In March 2003, the program was transferred to DHS. During this transfer, the 

grants became commonly known as “first responder” grants. First responders 

include public safety personnel working in law enforcement, emergency medical 

services, emergency management, fire service, public works, government 

administration, health care, and public health. 

ODP has continued DOD’s and DOJ’s mission to oversee the enhancement of 

state and local jurisdictions’ ability to respond to, and mitigate the consequences 

of, incidents of terrorism through the delivery of first responder grants. The 

grants aid states and local jurisdictions with administration and planning costs 

as well as the cost of acquiring specialized training, conducting preparedness 

exercises, and acquiring equipment necessary to safely respond to and manage 

terrorist incidents involving weapons of mass destruction, with a focus on 

chemical, biological, radiological, nuclear, and explosives preparedness. 

While ODP is responsible for the first responder grant program, it continues to 

rely upon DOJ’s OJP for grant distribution and financial management support. 

ODP also uses OJP’s automated Grants Management System (GMS). Once 

Congress appropriates funding, ODP uses GMS to post grant solicitation notices 

and to make grant applications available. In addition to other grants, ODP

managed one first responder grant program in FY 2002, SDPP, and two grant 

programs in FY 2003, SHSGP and SHSGP II. Funding for these programs totaled 

$2.4 billion. See appendix C for a list of the 56 states and territories awarded 

ODP grants in FY 2002 and FY 2003 and the amounts awarded.

State and territory governors are responsible for appointing a state administrative 

agency that applies for and manages the grants and acts as the liaison between 

ODP and local jurisdictions. For most of the grant awards, states are required to 

allocate at least 80 percent to local jurisdictions and use OJP’s GMS to apply for 

the grants. 

3

 1999 funding does not include amounts that may have been provided by DOD.
Page 6 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

At DHS, ODP was initially placed under the Border and Transportation Security 

Directorate. However, recently proposed legislation and a DHS realignment plan 

call for ODP and all DHS fi rst responder and emergency preparedness grants to 

be managed by DHS’s Offi ce of State and Local Government Coordination and 

Preparedness. 

States and Locals Slow to Spend Funds, Although More Had Been 

Committed or Obligated

As of February 2004, the majority of the $2.4 billion in FY 2002 and FY 2003 

fi rst responder grant funds awarded to the 56 states and territories remained 

unspent and in the U.S. Treasury. However, draw down statistics do not tell 

the whole story when trying to gauge the progress being made by states, local 

jurisdictions, and fi rst responders, because they only measure funds disbursed to 

the states. Although only a small percentage of the funds had been drawn down, 

much of the remainder had been committed or obligated4 by the states to local 

jurisdictions for specifi c purchases. 

Funds Awarded and Drawn Down by the States

As of February 10, 2004, the 56 states and territories had drawn down only 36 

percent of FY 2002 awards, and 13 percent and 10 percent, respectively, of FY 

2003 SHSGP and SHSGP II awards. The FY 2002 awards were made 16 months 

previously, and the FY 2003 SHSGP and SHSGP II awards were made eight 

months and seven months previously. (See appendix C for FY 2002 and FY 2003 

grant awards and appendix D for drawdowns.) The following charts compare the 

amounts of funds awarded with the amounts of funds drawn down.

4

 An “obligation” is a binding agreement that will result in the outlay of funds (spending).
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 7

We sampled ten states that had been awarded $124 million of FY 2002 fi rst 

responder grants. Those states received 39 percent of the total FY 2002 funding. 

As of November 4, 2003,5 12 months after the funds had been awarded, $102 

million, or 82 percent, had not been drawn down by the states. The states we 

sampled were: Texas, Georgia, Illinois, Ohio, Florida, Michigan, New York, 

New Jersey, California, and Pennsylvania. The following chart shows amounts 

awarded and drawn down by those states.

 

Of the $124 million, 18 percent, or $22 million, had been drawn down by the 

states; 33 percent, or $41 million, was not available to be drawn down because 

the states had not completed grant application requirements causing ODP to place 

5

 More recent information on funds held by ODP was not available when the audit was performed. Consequently, for 

comparability purposes, the OIG used disbursement data as of November 4, 2003, and did not include SHSGP II data.
Page 8 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

a hold on the funds. The remaining 49 percent, or $61 million, was available but 

had not been drawn down. The following chart shows those amounts for FY 2002 

and FY 2003 grants. 

GRANT FUNDS AVAILABLE AND DRAWN DOWN

Fiscal Year Date 

Awarded

Amount 

Awarded to 10 

States

Held by 

ODP

Available 

to States

Drawn Down 

by States as 

of 11/4/03

Percent 

Drawn 

Down

2002

(SDPP) 9/2002 $124m $41m $61m $22m 18%

2003 

(SHSGP) 5/2003 $224m $64m $145m $15m 7%

Total - $348m $105m $206m $37m 11%

The 10 states showed little improvement drawing down FY 2003 SHSGP first 

responder grant funds. In five months, 7 percent, or $15 million, of the $224 

million awarded, had been drawn down. 

Funds Obligated and Spent by the States

Although only a small percentage of the funds had been drawn down, much 

of the remainder had been committed or obligated. In addition, some states 

and jurisdictions had already purchased equipment but had not yet requested 

reimbursement under the grant. Also, some state officials told us that they do not 

always draw down funds immediately after incurring expenses. Some states wait 

until the end of the month to draw down grant funds. States are not required to 

draw down grant funds as they incur program expenses. 

The amounts of funds drawn down by states provide an incomplete picture of 

the progress states and local jurisdictions are making. A more accurate way to 

monitor progress would be to identify the amount of funds obligated and spent 

(outlays) by the states and local jurisdictions. For example, as of September 30, 

2003, Ohio and Pennsylvania obligated and spent over 98 percent of their FY

2002 grant awards, while ODP’s grant payment history reports showed that only 

36 percent and 8 percent, respectively, were drawn down. For the 10 states in our 

sample, obligations and spending totaled 42 percent versus 18 percent reported as 

drawn down.

Obligations represent funds that are set aside, under a binding agreement, and 

will be spent for a particular purpose. Outlays represent expenditures, whether 
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 9

or not funds have been drawn down from the federal grant account. Combining 

the two provides a better picture of what states have accomplished in executing 

the grants. States are required to report obligations and outlays quarterly on a 

federal standard form known as an SF 269, or Financial Status Report. However, 

30 of the 56 states and territories do not report obligations because they report 

grant activity on a cash, rather than an accrual basis. They report only outlays. 

ODP should collect both obligations and outlays from all states and use that 

information to monitor and report on states’ progress. 

The following chart depicts grant funds obligated and spent for the 10 states in 

our sample.

With respect to all 56 states and territories, they had obligated and spent 23 

percent of their combined FY 2002 SDPP and FY 2003 SHSGP grant funds as 

of September 30, 2003. That was more than twice the amount reported as drawn 

down. 

ODP Processing Times Have Improved but State and Local Delays 

Continue

During FY 2003, ODP reduced its time to make application guidance and on-line 

applications available to states, process grant applications, and award the grants 

after the states submitted their grant applications. On average, for our sample of 

10 states, the 2002 grants took 292 days to process, whereas it took 77 days to 

process FY 2003 grants. ODP was responsible for 223 of the 292 days to process 

FY 2002 grants and 35 of the 77 days to process FY 2003 grants. The majority of 

the improvement in timeliness was due to ODP’s making applications available 

 
Page 10 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

more quickly. The remaining days were used by states to submit their grant 

applications to ODP. There was also improvement in the number of days it took 

states to submit their applications. The following chart shows average processing 

times for FY 2002 and FY 2003 grants in our sample of 10 states.

IMPROVED PROCESSING OF FIRST RESPONDER GRANTS

State 

Days for ODP to 

Make Applications 

Available from 

Legislation Date

Days for 

States to 

Submit 

Applications 

Days for ODP 

to Approve 

Applications 

(Award Grants)

Total Days 

for ODP to 

Process 

Grants

Total Days from 

Legislation to 

Award of Grants 

(ODP and State)

2002 - SDPP 

Average 165 69 58 223 292

2003 - SHSGP 

Average 17 42 18 35 77

OIG heard complaints that the number of steps in the application process inhibited 

spending. However, for the most part, states praised ODP’s technical assistance, 

automated grant application process, and reductions in the amount of time 

ODP took to approve grants. Most state officials thought ODP processed their 

applications in a timely manner. 

State and local governments were sometimes responsible for delaying the 

delivery of FY 2002 grant funds to first responders. States had to submit a 

homeland security strategy. Grants had to be accepted by the states, awarded to 

local jurisdictions by the states, and accepted by the local jurisdictions. These 

processes required approval by various governing and political bodies within the 

states and local jurisdictions. Only three states were able to provide us data on 

the time taken for these processes. In one of the three states, it took 22 days to 

accept ODP’s grant award and 51 days to award a sub-grant to one of its local 

jurisdictions; it then took 92 days for the local jurisdiction to accept the grant. 

The second state took 25 days to accept ODP’s grant award and 80 to 161 days to 

award funds to local jurisdictions; it then took 13 to 50 days for the jurisdictions 

to accept the awards. The third state took 14 days to accept the grant, 17 days to 

award funds to its jurisdictions, and the jurisdictions took from 66 to 210 days to 

accept the awards. The following chart shows processing time variances for nine 

jurisdictions in three states.
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A congressional effort to speed delivery of FY 2003 funds may not have been 

effective and, in some cases, may have slowed spending of FY 2002 funds. 

Congress adopted appropriation language for the FY 2003 SHSGP II grant 

program that required states to transfer fi rst responder grant funds within 45 days 

of the funds being awarded by ODP to ensure that states pass funds down to locals 

quickly. In response, ODP required states to obligate funds to local jurisdictions 

within 45 days. However, this action had a limited effect because most states 

are meeting the 45-day timeframe by using a loose defi nition of “obligate.” DHS 
Page 12 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

allows states to count funds as obligated when the states have agreed to allocate 

a specific amount of the grant to a state agency or local jurisdiction, even though 

the state has not determined specifically how the funds will be spent or when 

contracts for goods and services will be let. The short deadlines also force states 

to reduce the amount of time they spend planning. As a result, funds are still not 

reaching local jurisdictions in 45 days, and meeting the deadline often caused 

states and local jurisdictions to delay spending prior year grant funds. In addition, 

many of the reasons given for delays, as described below, point to administrative 

processes that need to be streamlined.

Reasons for Delays

There were numerous reasons given for delays in spending the grant funds -

- some may be unavoidable, while others indicate problems that need to be 

addressed.

States are responsible for identifying the highest priority for spending the grant 

funds. That can be an extremely difficult task, and most states we visited were not 

satisfied with needs analyses they did prior to September 11, 2001. Some states 

took the time to update outdated needs analyses, and one state delayed FY 2002 

spending until it could complete a new assessment using ODP’s FY 2003 needs 

assessment tool. Additionally, there is little consistency in how the states manage 

the grant process. They use various methods for identifying and prioritizing 

needs and allocating funds. They may rely on the work of regional taskforces, 

statewide committees, county governments, mutual aid groups, or local fire and 

police organizations. Some states purchase equipment and deliver it to users, 

while others sub-grant the money directly to jurisdictions. When deciding how 

to allocate the grants among jurisdictions, states variously use population, threat, 

risk, and governors’ discretion. 

Following are some of the specific reasons given by state, local jurisdiction, and 

first responder representatives for delays in spending. The reasons are grouped by 

category: federal requirement and guidelines; state and local planning processes; 

and procurement issues. 

Federal requirements and guidelines

1. States complained that there are too many different first responder 

preparedness grant programs that must be considered in too short a time. This 

makes processing more difficult than in the past. ODP has made progress in 
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 13

expediting the awarding of grants; however, the number and dollar volume 

of grants, and expanded planning and application requirements has reduced 

the states’ and local governments’ ability to plan for and spend the funds 

quickly. In FY 1999, there were two first responder terrorism preparedness 

grant programs valued at $83.5 million. In FY 2003 there were six terrorism 

preparedness grant programs valued at $2.8 billion. Nine of the ten states 

believed that the application process was not difficult. Others complained of 

short timelines and inconsistent guidelines.

2. There are communication problems at all levels. Inadequate communication 

creates confusion about eligibility, year-to-year changes in requirements, 

and the grant process. DHS announcements about fund availability lead to 

unrealistic expectations on the part of local governments and first responder 

organizations. States also pointed to confusion caused by changes ODP 

has made in its eligible equipment lists. While states appreciate that more 

equipment is now eligible for purchase, they believed that they should be 

allowed to purchase equipment recently added to the list with prior year 

grant funds. They said it is difficult and time consuming to track funding by 

program year to ensure that they do not use prior year funds to purchase what 

was ineligible equipment. 

3. Overall, state and local officials had very few concerns about ODP’s grant 

application process, but they did believe that aspects of the process could 

be simplified. Of the ten states in our sample, only one believed that ODP’s 

application process required too much detail to complete and that timelines 

were too short, although others agreed that they should carefully plan and 

decide how they will use the grant funds prior to receiving the funds. States 

also complained that equipment budget worksheets had to be revised several 

times before being approved by ODP, and that reporting requirements were 

continually expanding. A general complaint was that too many plans are 

required for the various preparedness grant programs. They want a “one-stop 

shop” to consolidate and standardize requirements.

4. Planning efforts are often delayed because first responders and emergency 

managers do not have clear federal guidelines for equipment, training, and 

exercises and for preparedness levels, thus making it difficult to determine 

their highest priority needs and to decide how best to spend grant funds. 

State officials and first responders believed that the development of federal 

guidelines for first responders should be accelerated, and include such areas 

as interoperability, terminology and performance measurement. For example, 
Page 14 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

one official believed that the guidelines for training levels were vague and did 

not identify the level of training various first responders would need. Another 

official believed that if equipment guidelines were established there would 

be fewer problems with interoperability. Some suggested that DHS provide 

recommendations, or benchmarks, as to capability levels for first responders. 

On December 17, 2003, the President issued a Homeland Security Presidential 

Directive requiring that DHS develop a national domestic all-hazards 

preparedness goal. This goal will establish measurable readiness priorities and 

targets, including development of standards for preparedness assessments and 

strategies, and a system for assessing the nation’s overall preparedness. It is to 

be submitted to the President with DHS’s FY 2006 budget submission.

State and local planning processes 

1. The planning process is complex and takes time. Grant applications require 

threat, risk, capability, vulnerability, and needs assessments. Finding 

consensus among hundreds of local jurisdictions and first responders on 

priorities and what to buy takes time. For example, in Texas, there are 1,449 

local jurisdictions eligible to receive first responder grant funds. The state 

requires that the local jurisdictions participate in its statewide planning 

and assessment process to be eligible for an award. While only 95 local 

jurisdictions participated in the state’s 2000 process, 753 participated in 2003. 

The planning and assessment process required each jurisdiction and its first 

responders to evaluate its needs and capabilities in ten responder disciplines, 

i.e., fire services, hazardous materials, emergency medical services, law 

enforcement, public works, government administration, public safety 

communication, health care, public health, and emergency management. 

Jurisdictions use the assessment to create an equipment list that they forward 

to a regional council established by the state. The councils review the lists 

and send a final list to the state for further review and approval.

Georgia created All Hazard Councils (AHCs) in each of the eight regions 

within the state. These teams are made up of first responders from each of the 

first responder areas. The planning process begins with the locals, who send 

information up to the AHC in their region. The AHC, in turn, gathers and 

submits these local views to the state. These examples illustrate how creating 

a needs assessment and determining an appropriate equipment list can be a 

lengthy process.
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 15

We also visited Massachusetts, which was outside our sample, because it was 

the only state that had spent most of its FY 2002 first responder grant funds 

when the audit began in April 2002. Within a year of receiving its award, 

Massachusetts had spent 86 percent of its total grant award. The state was 

able to do this by forming a state strategy team that set spending priorities 

relatively quickly, and by using state staff to procure equipment centrally for 

all local jurisdictions. The Strategy Team was comprised of representatives 

from Massachusetts’ Emergency Management Agency, State Police, National 

Guard, Hazardous Response Teams, and Department of Public Health, 

and from the Fire Chiefs Association, the Police Chiefs Association, and 

local Emergency Management Directors. The team met numerous times 

and reviewed the state’s pre-September 11, 2001, needs analyses and 

recommendations from local officials before reaching a consensus. The 

team decided not to prioritize FY 2002 spending as outlined in the needs 

analyses but chose to: 1) use 64 percent of the funds to purchase 65 mass 

decontamination units; 2) enhance statewide communication capabilities; 

and 3) purchase specialized personal protective and detection equipment. 

Therefore, most of the funding was spent quickly on a fairly expensive type of 

equipment, from one vendor. 

2. Building regional structures within the states, which some states have and 

some have not, takes time. In our sample of 10 states, California, Georgia 

Florida, Illinois, Pennsylvania, and Texas used a regional approach, while 

the others did not. While we were unable to determine the impact of these 

regional structures on spending delays, some regions are finding it difficult 

to recruit members and chairpersons, and to find jurisdictions willing to take 

on the responsibility of providing purchasing and accounting services for 

the entire region. Another state, Ohio, said it would soon adopt a regional 

structure but was unsure about how best to group its 88 counties and 5 state 

agencies.

3. State officials told us that they prefer to go slow to get it right. The consensus 

was that it is more important to spend time planning than to spend money 

quickly. For most of the grants, states have two or three years to spend the 

money. Some prefer to spend prior-year money first.

4. State legislatures and county and city boards or councils sometimes cause 

administrative delays in accepting grants, approving distribution, and 

approving expenditures. Six of the ten states we sampled cited the length of 
Page 16 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

their own state’s review and approval process as one of the top three reasons 

that the funds have not been spent. 

5. Inadequate staffing is a problem in many states and jurisdictions. The recent 

economic downturn and budget shortages have made it difficult for states 

to fund administrative positions. FY 2003 grants added more funding for 

administering the grants.

Procurement issues

1. State and local procurement processes can be long. Many of the equipment 

purchase methods have proved to be slow due to internal processing delays. 

Some states purchase equipment centrally for all jurisdictions, while others 

sub-grant funds so that purchases are made by local jurisdictions. 

2. Equipment delivery delays may be unavoidable. Many of the equipment 

items being purchased are the same items purchased by the military – a higher 

priority for the vendors. Representatives for seven states in our sample of 

10 said that purchasing equipment was challenging. Five said equipment 

backorder was one of the main reasons for spending delays. 

3. State and local officials and first responders were fearful that the federal 

funding stream may not continue, so that equipment purchased with the 

grants cannot be maintained or replaced when obsolete, and training and 

exercises will have to be stopped. Long-term and stable funding would allow 

state and local governments to plan for, build, and maintain an appropriate 

emergency preparedness and response capability. This concern may have 

been exacerbated since the department’s FY 2005 DHS budget request reduces 

terrorism preparedness grant funding by $800 million from the previous year.

Monitoring and Measuring Performance 

Efforts to monitor and measure the impact of first responder grants needs to be 

improved. 

ODP has not implemented a formal grant monitoring system, nor has ODP staff 

conducted frequent field visits to grant recipients. None was conducted in FY 

2002 or FY 2003. ODP has drafted monitoring guidance but has only partially 

implemented it. Overall, the draft guidance appears reasonable, and should be 

finalized and implemented as soon as possible.
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 17

OJP and state program officials are responsible for financial monitoring of first 

responder grants. OJP conducted 19 reviews of FY 2002 ODP grants, and only 

six reviews of the FY 2003 grants. OJP did not provide a specific explanation for 

the drop in reviews, but did note that ODP grants are only a small portion of the 

DOJ grants that it is responsible for reviewing. In addition, OJP’s policy is not to 

review the same grantee within a two-year period, unless there are extraordinary 

circumstances. ODP needs to ensure that financial monitoring of its first 

responder grant programs is conducted more frequently to ensure that the states 

are effectively using grant funds.

In March 2002, DOJ OIG reported that ODP had not established performance 

measures or a method for determining whether grant funding provided to states 

improved their capability to respond to terrorist incidents. Since that report, ODP

has provided states guidance on performance measures and plans to integrate 

information received from the states with data received from its new assessment 

tool. ODP requires states to measure performance improvement by the number 

of local jurisdictions that conducted exercises and enhanced capability with 

new equipment and training. However, such measures do not fully address 

how federal funding has increased preparedness and response capabilities. For 

example, the training measure does not describe how first responders’ skills 

have been improved or the level to which they have been trained. ODP should 

design measures that can be used to create a national picture of the increases in 

first responder preparedness and response capabilities and that can demonstrate 

the overall success of its grant programs. In addition, most state and local 

officials we spoke with said they have not yet had the time or resources to address 

measuring performance improvements resulting from the grants. This issue is 

quickly increasing in importance and will need ODP’s attention in the near future.

Consolidation of Preparedness Grants

Since FY 1998, state and local governments responsible for emergency 

preparedness and response have been calling for the establishment of a “one-stopshop” that would consolidate the various federal preparedness grants into a single, 

streamlined comprehensive program. In response, DHS is moving selected 

grants currently in the Emergency Preparedness & Response Directorate and the 

Border and Transportation Security Directorate into the Office of State and Local 

Government Coordination and Preparedness. Grants proposed for moving to the 

new office include Homeland Security Grants, Assistance to Firefighters Grants, 

Emergency Management Performance Grants, Port Security Grants, and other 

grant programs. 
Page 18 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

DHS believes that the benefits of the consolidation will include a simplified 

application and award process, enhanced assistance that would allow states 

to better implement their Statewide Homeland Security Strategies, and the 

development of comprehensive preparedness programs in support of those 

strategies. Overall, the department should be better positioned to provide 

consistency in policy and program development, improved efficiency in program 

management and implementation, and a greater ability to evaluate program 

success. OIG strongly supports this effort and will monitor its implementation.

Conclusion and Recommendations

States, local jurisdictions, and first responder organizations have been slow 

to receive and spend ODP first responder terrorism preparedness grant funds. 

However, the statistics on drawdowns are somewhat misleading, and the spending 

picture is not as bad as it appears. In some instances, states and local jurisdictions 

had delayed spending funds pending the development of detailed spending plans, 

believing that spending the funds wisely was more important than spending them 

immediately. In addition to delays caused by states developing detailed plans 

for spending the funds wisely, we identified numerous other reasons for delayed 

spending. While some of the delays are unavoidable, others can be reduced. 

ODP’s application process was not a major reason for delays. For the most part, 

state officials praised ODP and thought ODP processed grant applications in a 

timely manner. The OIG recommends that the Director, Office for Domestic 

Preparedness:

1. Require more meaningful reporting by states so ODP can track progress 

more accurately and assist states when necessary. Specifically, ensure that 

the definition of obligation is consistent for both programmatic and financial 

reporting purposes and require states using a “cash basis” accounting system 

to report the value of binding agreements to be funded by first responder grant 

funds.

2. Seek a legislative change to revise or eliminate the 45-day transfer rule to 

allow more time for planning.

3. Identify and publish best practices that result in faster and more efficient grant 

processing and spending. For example, identify state procurement practices 

that result in first responder equipment being supplied in a timely and cost 

effective manner.
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 19

4. Accelerate the development of federal guidelines for first responder 

capabilities, equipment, training, and exercises. 

5. Publish program monitoring guidance and ensure that states report their 

progress in achieving program and performance goals and objectives.

6. Monitor state oversight of local jurisdictions’ compliance with grant 

requirements, and develop performance standards that can be used to measure 

the overall success of the grant programs, including baselines against which to 

measure progress. 

7. Consider allowing states to use the most recent ODP-approved equipment list 

when purchasing equipment with prior-year grant funds.
Page 20 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix A

Purpose, Scope and Methodology

Purpose, Scope, and Methodology

The objective of the audit was to determine whether the distribution and spending 

of first responder grant funds were being delayed and, if so, to identify the reasons 

for delays. We evaluated ODP’s grant award process, drawdowns and spending 

by each state, and distributions to local governments to identify significant delays. 

We visited the emergency management or homeland security offices of 11 states, 

31 local governmental organizations that manage first responder funds, and 

38 first responder organizations. We selected as our sample the ten states that 

received the most funding: Texas, Georgia, Illinois, Ohio, Florida, Michigan, New 

York, New Jersey, California, and Pennsylvania. These ten states were awarded 

$124 million, or 39 percent, of the $316 million in grant funds awarded in FY

2002. We also visited Massachusetts, which was outside our sample, because it 

was the only state that had spent most of its FY 2002 grant funds. In each of the 

states, we interviewed responsible program officials and first responders. Also, 

we reviewed ODP and OJP program and financial files, as well as documentation 

provided to us by state and local officials. We relied upon OJP’s draw down 

data to determine the amount of grant funds that remained with ODP. Specific 

information on state, local jurisdictions, and first responder organizations that we 

visited is identified in appendix B.

Audit work was conducted between April 2003 and December 2003 and was 

performed under the authority of the Inspector General Act of 1978, as amended, 

and according to government auditing standards.

Throughout the audit, OIG worked closely with ODP and OJP officials. The 

cooperation and courtesies extended to the audit team are appreciated. The 

principal OIG points of contact for the audit are Assistant Inspector General 

for Audits, J. Richard Berman, (202) 254-4100, and Dennis White, Director, 

Emergency Preparedness and Response, (202) 254-4157. Major OIG contributors 

to the audit are identified in appendix H.
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 21

Appendix B

State and Local Jurisdictions Visited During the Audit

1. California

a. State Agencies

i. California Office of Homeland Security 

ii. California Office of Emergency Services

b. Local Governmental Organizations

i. Santa Clara County - Office of Emergency Services

ii. City of San Jose – Office of Emergency Services

iii. Los Angeles County - Office of Emergency Management 

iv. San Diego County - Office of Emergency Services

c. First Responders

i. Santa Clara County, Office of the Sheriff

ii. San Jose Police

iii. City of Solana Beach - Public Safety

2. Florida

a. State Agencies

i. Florida Department of Community Affairs, Division of Emergency 

Management Agency

b. Local Governmental Organizations

i. Broward County Commission, Department of Safety and 

Emergency Services, Fire Rescue Division

ii. Miami-Dade County Office of Emergency Management

c. First Responders

i. Broward County Sheriff’s Office

ii. City of Hollywood – Fire/Rescue

iii. Miami-Dade Fire Rescue

iv. City of Miami – Fire Department

v. Jackson Memorial Hospital

vi. University of Miami, School of Medicine, Florida Poison 

Information Center

vii. City of Hialeah - Fire Department

viii. Palm Beach County Sheriff’s Office

ix. Delray Beach - Fire Department

x. St. Mary’s Medical Center

3. Georgia

a. State Agencies

i. Georgia Emergency Management Agency

ii. Georgia Public Safety Training Center
Page 22 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

b. First Responders

i. Cobb County Fire and Emergency Services

ii. Fulton County Fire Department

iii. DeKalb County Fire and Rescue Department

4. Illinois

a. State Agencies

i. Illinois Emergency Management Agency

b. Local Governmental Organizations

i. Mutual Aid Box Alarm System (Fire)

ii. Illinois Law Enforcement Alarm System (Police)

iii. City of Chicago Grants Management

c. First Responders

i. Elmhurst Police

ii. Plainfield Police

5. Massachusetts

a. State Agencies

i. Massachusetts Executive Office of Pubic Safety (Boston)

ii. Massachusetts Emergency Management Agency (Framingham)

iii. Massachusetts State Police Marine Section (Boston Harbor)

b. First Responders

i. City of Concord Fire Department

ii. City of Worcester Fire Department

6. Michigan

a. State Agencies

i. Michigan Department of State Police, Homeland Security

b. Local Governmental Organizations

i. Kent County Sheriff Department

ii. Oakland County –

iii. County Executives Office, Special Projects

iv. Emergency Response and Preparedness Unit

v. City of Detroit, Office of Homeland Security and Emergency 

Management

vi. Wayne County, Department of Homeland Security and Emergency 

Management

vii. The Downriver Community Conference 

c. First Responders

i. Kent County Sheriff Department

Appendix B

State and Local Jurisdictions Visited During the Audit
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 23

ii. Spectrum Health

iii. Commerce Township Fire Department

iv. Milford Township Fire Department

v. City of Detroit - Fire Department

vi. City of Taylor- Fire Department

vii. City of Trenton – Disaster Emergency Response Team

7. New Jersey

a. State Agencies

i. New Jersey Department of Law and Public Safety

b. Local Governmental Organizations

i. Essex County - Office of Emergency Management

ii. Middlesex County - Health Department

c. First Responders

i. Bergen County Police

8. New York

a. State Agencies

i. New York State Executive Director of the Weapons of Mass 

Destruction Task Force (Albany)

b. Local Governmental Organizations

i. Erie County - Emergency Services Commissioner

ii. New York City –

1. Office of Management and Budget

2. Office of Emergency Management

iii. Suffolk County –

1. Office of Emergency Management 

2. Suffolk County Deputy Commissioner

3. Department of Health Services, Division of Emergency 

Services

c. First Responders

i. Suffolk County Fire and Rescue

ii. Suffolk County Police Department

9. Ohio

a. State Agencies

i. Ohio Emergency Management Agency (EMA)

ii. Ohio Department of Administrative Services

b. Local Governmental Organizations

i. Franklin County – Emergency Management Agency

Appendix B

State and Local Jurisdictions Visited During the Audit
Page 24 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

ii. Cuyahoga County - Emergency Services Division

10. Pennsylvania

a. State Agencies

i. Pennsylvania Emergency Management Agency

b. Local Governmental Organizations

i. Southeastern Pennsylvania Regional Terrorism Task Force

ii. Southwestern Pennsylvania Emergency Response Group

iii. South Central Pennsylvania Region Counter-Terrorism Task Force

c. First Responders

i. Northampton Township Police

ii. Southampton Fire Co.

iii. Bucks County Hazardous Incident Response Team

11. Texas

a. State Agencies

i. Texas Engineering Extension Services (TEEX), College Station - a 

component of the Texas A&M University system

b. Local Governmental Organizations

i. City of Houston – Office of Emergency Management

ii. City of Dallas – Emergency Preparedness

iii. City of San Antonio Office of Emergency Management

c. First Responders

i. Dallas Fire-Rescue

ii. Dallas Police Department

iii. San Antonio Fire Department

iv. San Antonio Police Department

v. Corpus Christi Fire Department

Appendix B

State and Local Jurisdictions Visited During the Audit
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 25

STATE 2002 SDPP 2003 SHSGP 2003 SHSGP II

TOTAL AWARDS

Amount Percentage 

of Total

Alabama $5,317,000 $9,457,000 $25,049,000 $39,823,000 1.7%

Alaska 2,783,000 4,995,000 13,230,000 21,008,000 0.9%

American Samoa 828,000 1,482,000 3,926,000 6,236,000 0.3%

Arizona 5,770,000 10,584,000 28,033,000 44,387,000 1.9%

Arkansas 4,141,000 7,394,000 19,585,000 31,120,000 1.3%

California 24,831,000 45,023,000 119,256,000 189,110,000 7.9%

Colorado 5,220,000 9,480,000 25,111,000 39,811,000 1.7%

Connecticut 4,626,000 8,265,000 21,893,000 34,784,000 1.5%

Delaware 2,887,000 5,185,000 13,733,000 21,805,000 0.9%

District of Columbia 2,747,000 4,910,000 13,006,000 20,663,000 0.9%

Florida 12,967,000 23,654,000 62,655,000 99,276,000 4.2%

Georgia 7,797,000 14,188,000 37,579,000 59,564,000 2.5%

Guam 892,000 1,596,000 4,226,000 6,714,000 0.3%

Hawaii 3,172,000 5,693,000 15,079,000 23,944,000 1.0%

Idaho 3,226,000 5,803,000 15,375,000 24,404,000 1.0%

Illinois 10,604,000 18,879,000 50,005,000 79,488,000 3.3%

Indiana 6,400,000 11,399,000 30,194,000 47,993,000 2.0%

Iowa 4,308,000 7,656,500 20,282,000 32,246,500 1.4%

Kansas 4,151,000 7,401,000 19,603,000 31,155,000 1.3%

Kentucky 5,048,000 9,001,000 23,838,000 37,887,000 1.6%

Louisiana 5,331,000 9,451,000 25,037,000 39,819,000 1.7%

Maine 3,213,000 5,751,000 15,232,000 24,196,000 1.0%

Maryland 5,881,000 10,585,000 28,037,000 44,503,000 1.9%

Massachusetts 6,579,000 11,711,000 31,020,000 49,310,000 2.1%

Michigan 8,958,000 15,918,000 42,162,000 67,038,000 2.8%

Minnesota 5,631,000 10,076,000 26,690,000 42,397,000 1.8%

Mississippi 4,255,000 7,582,000 20,083,000 31,920,000 1.3%

Missouri 6,079,000 10,834,000 28,697,000 45,610,000 1.9%

Montana 2,967,000 5,303,000 14,047,000 22,317,000 0.9%

Nebraska 3,502,000 6,254,500 16,568,000 26,324,500 1.1%

Nevada 3,693,000 6,771,000 17,935,000 28,399,000 1.2%

New Hampshire 3,328,000 5,727,000 15,172,000 24,227,000 1.0%

New Jersey 7,948,000 14,222,000 37,671,000 59,841,000 2.5%

New Mexico 3,574,000 6,401,000 16,956,000 26,931,000 1.1%

New York 14,953,000 26,492,000 70,172,000 111,617,000 4.7%

North Carolina 7,706,000 13,908,000 36,840,000 58,454,000 2.5%

North Dakota 2,794,000 4,983,000 13,200,000 20,977,000 0.9%

Northern Mariana Islands 835,000 1,496,000 3,963,000 6,294,000 0.3%

Appendix C

FY2002 SDPP and FY2003 SHSGP and SHSGP II Awards
Page 26 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Ohio 9,897,000 17,510,000 46,378,000 73,785,000 3.1%

Oklahoma 4,656,000 8,304,000 21,996,000 34,956,000 1.5%

Oregon 4,637,000 8,336,000 22,081,000 35,054,000 1.5%

Pennsylvania 10,512,000 18,570,000 49,189,000 78,271,000 3.3%

Puerto Rico 4,894,000 8,727,000 23,118,000 36,739,000 1.5%

Rhode Island 3,063,000 5,489,000 14,540,000 23,092,000 1.0%

South Carolina 5,028,000 9,017,000 23,882,000 37,927,000 1.6%

South Dakota 2,868,000 5,131,000 13,591,000 21,590,000 0.9%

Tennessee 6,140,000 10,978,000 29,080,000 46,198,000 1.9%

Texas 16,196,000 29,538,000 78,238,000 123,972,000 5.2%

Utah 3,849,000 6,937,000 18,374,000 29,160,000 1.2%

Vermont 2,772,000 4,963,000 13,147,000 20,882,000 0.9%

Virginia 7,062,000 12,716,000 33,683,000 53,461,000 2.2%

Virgin Islands, U.S. 861,000 1,542,000 4,085,000 6,488,000 0.3%

Washington 6,276,000 11,294,000 29,917,000 47,487,000 2.0%

West Virginia 3,567,000 6,340,000 16,792,000 26,699,000 1.1%

Wisconsin 5,925,000 10,565,000 27,985,000 44,475,000 1.9%

Wyoming 2,696,000 4,827,000 12,784,000 20,307,000 0.9%

GRAND TOTAL $ 315,841,000 $ 566,295,000 $1,500,000,000 $ 2,382,136,000 100.0%

Appendix C

FY2002 SDPP and FY2003 SHSGP and SHSGP II Awards
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 27

State

FY 2002 SDPP FY 2003 SHSGP FY 2003 SHSGP II

Awarded 

($316M) Drawn ($115M) Awarded ($566M) Drawn ($71M) Awarded ($1,500M) Drawn ($156M)

Alabama $5,317,000 $2,866,889 $9,457,000 $98,821 $25,049,000 $1,622,255

Alaska 2,783,000 71,600 4,995,000 25,255 13,230,000 42,651

American Samoa 828,000 181,808 1,482,000 0 3,926,000 214,152

Arizona 5,770,000 2,552,407 10,584,000 1,440,515 28,033,000 1,268,220

Arkansas 4,141,000 1,409,372 7,394,000 2,521,666 19,585,000 3,241,401

California 24,831,000 2,519,960 45,023,000 2,966,828 119,256,000 19,071,957

Colorado 5,220,000 528,749 9,480,000 0 25,111,000 36,388

Connecticut 4,626,000 1,245,655 8,265,000 0 21,893,000 0

Delaware 2,887,000 0 5,185,000 0 13,733,000 0

District of Columbia 2,747,000 2,558,690 4,910,000 0 13,006,000 1,734,000

Florida 12,967,000 8,702,835 23,654,000 2,273,323 62,655,000 5,871,373

Georgia 7,797,000 942,500 14,188,000 1,858,500 37,579,000 2,171,100

Guam 892,000 753,037 1,596,000 75,566 4,226,000 0

Hawaii 3,172,000 74,071 5,693,000 127,534 15,079,000 1,144,242

Idaho 3,226,000 640,401 5,803,000 572,511 15,375,000 890,469

Illinois 10,604,000 5,777,509 18,879,000 4,955,513 50,005,000 0

Indiana 6,400,000 1,151,268 11,399,000 4,859,562 30,194,000 9,763,354

Iowa 4,308,000 3,444,273 7,656,500 58,210 20,282,000 267,648

Kansas 4,151,000 3,940,345 7,401,000 252,327 19,603,000 18,143

Kentucky 5,048,000 759,630 9,001,000 1,655,413 23,838,000 728,915

Louisiana 5,331,000 686,341 9,451,000 95,686 25,037,000 543,563

Maine 3,213,000 2,657,172 5,751,000 1,009,281 15,232,000 672,150

Maryland 5,881,000 4,244,702 10,585,000 275,912 28,037,000 379,785

Massachusetts 6,579,000 5,929,733 11,711,000 40,803 31,020,000 3,020,181

Michigan 8,958,000 5,875,820 15,918,000 574,941 42,162,000 194,246

Minnesota 5,631,000 3,014,307 10,076,000 351,914 26,690,000 494,163

Mississippi 4,255,000 107,619 7,582,000 724,245 20,083,000 391,420

Missouri 6,079,000 4,225,100 10,834,000 1,815,200 28,697,000 3,092,700

Montana 2,967,000 1,245,902 5,303,000 233,966 14,047,000 86,157

Nebraska 3,502,000 1,865,113 6,254,500 551,663 16,568,000 1,503,965

Nevada 3,693,000 2,874,192 6,771,000 1,259,919 17,935,000 845,534

New Hampshire 3,328,000 424,849 5,727,000 334,006 15,172,000 61,911

New Jersey 7,948,000 0 14,222,000 0 37,671,000 2,318,265

New Mexico 3,574,000 106,091 6,401,000 73,673 16,956,000 0

New York 14,953,000 0 26,492,000 13,000,000 70,172,000 60,000,000

North Carolina 7,706,000 3,517,086 13,908,000 516,434 36,840,000 250,620

North Dakota 2,794,000 1,240,166 4,983,000 565,640 13,200,000 148,962

Northern Mariana 

Islands 835,000 545,917 1,496,000 0 3,963,000 0

Appendix D

FY2002 SDPP and FY2003 SHSGP and SHSGP II Draw Downs as of February 2004
Page 28 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Ohio 9,897,000 5,435,537 17,510,000 2,652,971 46,378,000 1,500,277

Oklahoma 4,656,000 0 8,304,000 0 21,996,000 183,362

Oregon 4,637,000 682,682 8,336,000 199,478 22,081,000 675,958

Pennsylvania 10,512,000 2,578,458 18,570,000 209,395 49,189,000 866,720

Puerto Rico 4,894,000 182,426 8,727,000 0 23,118,000 0

Rhode Island 3,063,000 1,170,550 5,489,000 1,899,312 14,540,000 9,285,838

South Carolina 5,028,000 2,539,155 9,017,000 276,082 23,882,000 262,375

South Dakota 2,868,000 1,362,448 5,131,000 1,011,363 13,591,000 0

Tennessee 6,140,000 2,026,109 10,978,000 22,742 29,080,000 0

Texas 16,196,000 1,587,327 29,538,000 1,652,929 78,238,000 649,310

Utah 3,849,000 2,001,356 6,937,000 1,190,913 18,374,000 3,388,303

Vermont 2,772,000 1,883,177 4,963,000 1,466,921 13,147,000 559,084

Virginia 7,062,000 5,560,966 12,716,000 4,175,589 33,683,000 11,140,543

Virgin Islands 861,000 125,923 1,542,000 14,173 4,085,000 0

Washington 6,276,000 2,527,968 11,294,000 6,355,323 29,917,000 1,211,789

West Virginia 3,567,000 3,567,000 6,340,000 1,319,768 16,792,000 0

Wisconsin 5,925,000 2,724,977 10,565,000 3,109,642 27,985,000 4,595,725

Wyoming 2,696,000 0 4,827,000 0 12,784,000 0

GRAND TOTAL $315,841,000 $ 114,637,167 $ 566,295,000 $ 70,721,430 $ 1,500,000,000 $ 156,409,171 

Appendix D

FY2002 SDPP and FY2003 SHSGP and SHSGP II Draw Downs as of February 2004
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 29

The OIG recommends that the Director, Office for Domestic Preparedness:

1. Require more meaningful reporting by states so ODP can track progress 

more accurately and assist states when necessary. Specifically, ensure that 

the definition of obligation is consistent for both programmatic and financial 

reporting purposes and require states using a “cash basis” accounting system 

to report the value of binding agreements to be funded by first responder grant 

funds.

2. Seek a legislative change to revise or eliminate the 45-day transfer rule to 

allow more time for planning.

3. Identify and publish best practices that result in faster and more efficient grant 

processing and spending. For example, identify state procurement practices 

that result in first responder equipment being supplied in a timely and cost 

effective manner.

4. Accelerate the development of federal guidelines for first responder 

capabilities, equipment, training, and exercises. 

5. Publish program monitoring guidance and ensure that states report their 

progress in achieving program and performance goals and objectives.

6. Monitor state oversight of local jurisdictions’ compliance with grant 

requirements, and develop performance standards that can be used to measure 

the overall success of the grant programs, including baselines against which to 

measure progress. 

7. Consider allowing states to use the most recent ODP-approved equipment list 

when purchasing equipment with prior-year grant funds.

Appendix E

Recommendations
Page 30 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 31

Appendix F

Management Comments
Page 32 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 33

Appendix F

Management Comments
Page 34 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 35

Appendix F

Management Comments
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Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 37

Appendix F

Management Comments
Page 38 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 39

Appendix F

Management Comments
Page 40 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 41

Appendix F

Management Comments
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Appendix F

Management Comments
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 43

Appendix G

OIG Analysis of Management Comments

The OIG evaluated the Office for Domestic Preparedness’ written comments and has made changes 

to the report where appropriate. A summary of the written comments and our analysis regarding the 

recommendations made in the report are as follow:

Recommendations

1. Require more meaningful reporting by states so ODP can track progress more accurately 

and assist states when necessary. Specifically, ensure that the definition of obligation is 

consistent for both programmatic and financial reporting purposes and require states using 

a “cash basis” accounting system to report the value of binding agreements to be funded by 

first responder grant funds.

ODP agrees with the intent of this recommendation, but responded that implementing parts of 

our recommendation, such as a consistent definition of obligation, would be difficult. For its FY 

2004 grant programs, ODP has instituted a new reporting template. This template, according to 

ODP, allows better tracking of grantee progress in achieving the goals and objectives detailed in 

their State Homeland Security Strategies.

The OIG’s purpose in making this recommendation is to have ODP collect information that will 

allow it to measure the use of grant funds more effectively. We will review ODP’s new reporting 

template to determine whether it accomplishes that purpose.

2. Seek a legislative change to revise or eliminate the 45-day transfer rule to allow more time 

for planning.

ODP responded that in FY 2004 the states were given 60 days, as opposed to 45, in which to 

make funds available to local governments.

The OIG agrees that this is an improvement. ODP, though, should evaluate the effectiveness of 

the time limit to determine whether or not it results in a more rapid use of grant funds.

3. Identify and publish best practices that result in faster and more efficient grant processing 

and spending. For example, identify state procurement practices that result in first 

responder equipment being supplied in a timely and cost effective manner.

ODP did not comment on this recommendation.
Page 44 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds 

Appendix G

OIG Analysis of Management Comments

4. Accelerate the development of federal guidelines for first responder capabilities, 

equipment, training, and exercises.

ODP responded that it has produced numerous guidelines and protocols for the emergency 

responder community and defined a methodology for evaluating performance-based exercises.

The OIG agrees that such activities are important. However, states and jurisdictions were 

looking to DHS for performance standards, as well as equipping and training standards, that they 

can apply to their first responder organizations to help them determine where their shortfalls are 

and identify their highest priority needs. The OIG is not sure that what ODP has accomplished 

thus far meets those expectations.

5. Publish program monitoring guidance and ensure that states report their progress in 

achieving program and performance goals and objectives.

ODP responded that it has formal monitoring protocols that call for Preparedness Officers to 

review progress that states are making toward their State Homeland Security Strategies.

The OIG will review ODP’s published monitoring guidance.

6. Monitor state oversight of local jurisdictions’ compliance with grant requirements, and 

develop performance standards that can be used to measure the overall success of the grant 

programs, including baselines against which to measure progress.

ODP did not comment on this recommendation.

7. Allow states to use the most recent ODP-approved equipment list when purchasing 

equipment with prior-year grant funds.

ODP responded that this recommendation would have a negative impact on accounting practices, 

vendor selection, equipment maintenance, and training and calibration programs managed by 

ODP grantees.

The OIG based this recommendation on the simple logic that current equipment lists have added 

items of equipment that have been determined to be appropriate for first responders, and that 

states and jurisdictions should be able to purchase those items with funds from prior years. The 

OIG changes this recommendation to state that ODP should consider allowing the use of the 

most recent equipment lists, and we will discuss this recommendation further with ODP.
An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds Page 45

Kim Hurley, Audit Manager

Gina Smith, Audit Manager

Deirdre Hines, Program Analyst

Nicki Miller, Auditor 

Cynthia Noel, Auditor 

Leslie Anne Sibick, Program Analyst

John Woo, Auditor

Appendix H

Major Contributors to this Report
Page 46 An Audit of Distributing and Spending ODP’s “First Responder” Grant Funds

Appendix I

Report Distribution

Department of Homeland Security

Office of the Under Secretary for Border and Transportation Security

Office for Domestic Preparedness 

Office of State and Local Coordination

Office of Management and Budget

Homeland Bureau Chief

DHS OIG Budget Examiner

Congress

 Congressional Oversight and Appropriations Committees as Appropriate

Additional Information and Copies

To obtain additional copies of this report, call the Office of Inspector General (OIG) 

at (202) 254-4100, fax your request to (202) 254-4285, or visit the OIG web site at 

www.dhs.gov.

OIG Hotline

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal 

or noncriminal misconduct relative to department programs or operations, call the OIG 

Hotline at 1-800-323-8603; write to Department of Homeland, Washington, DC 20528, 

Attn: Office of Inspector General, Investigations Division – Hotline. The OIG seeks to 

protect the identity of each writer and caller.