FEMA Mismanaged the 

Commodity Distribution 

Process in Response to 

Hurricanes Irma and Maria 

September 25, 2020 

OIG-20-76 
6HSWHPEHU
 

 

 

 

 

 

DHS OIG HIGHLIGHTS 

FEMA Mismanaged the Commodity Distribution 

Process in Response to Hurricanes Irma and Maria 

September 25, 

2020 

Why We Did 

This Audit 

We conducted this audit 

to determine the extent 

to which FEMA managed 

and distributed 

commodities in response 

to Hurricanes Irma and 

Maria. 

What We 

Recommend 

We made five 

recommendations that, 

when implemented, 

should improve FEMA’s 

management and 

oversight of its disaster 

response activities. 

For Further Information: 

Contact our Office of Public Affairs at 

(202)981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

The Federal Emergency Management Agency (FEMA) 

mismanaged the distribution of commodities in response 

to Hurricanes Irma and Maria in Puerto Rico. FEMA lost 

visibility of about 38 percent of its commodity shipments 

to Puerto Rico, worth an estimated $257 million. 

Commodities successfully delivered to Puerto Rico took an 

average of 69 days to reach their final destinations. 

Inadequate FEMA contractor oversight contributed to the 

lost visibility and delayed commodity shipments. FEMA 

did not use its Global Positioning System transponders to 

track commodity shipments, allowed the contractor to 

break inventory seals, and did not ensure documented 

proof of commodity deliveries. Given the lost visibility and 

delayed shipments, FEMA cannot ensure it provided 

commodities to Puerto Rico disaster survivors as needed 

to sustain life and alleviate suffering as part of its 

response and recovery mission. 

In addition, FEMA’s mismanagement of transportation 

contracts included multiple contracting violations and 

policy contraventions. These violations occurred because 

of poor acquisition planning that did not address 

requirements for transoceanic shipments. While we 

understand FEMA’s priority on expediting commodity 

shipments to disaster survivors, it overrode the 

importance of following sound inventory management 

practices, significantly increasing the potential for fraud, 

waste, and abuse. Contract costs grew without FEMA 

having proof that services were performed as required and 

ultimately led to contract overruns of about $179 million 

and at least $50 million in questioned costs. 

FEMA Response 

FEMA concurred with four of the five recommendations. 

Appendix B contains FEMA’s management comments in 

their entirety. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

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

Results of Audit .............................................................................................. 5 

FEMA Mismanaged the Commodity Distribution Process in Response to 

Hurricanes Irma and Maria..................................................................5 

FEMA’s Mismanagement of the Transportation Contract Led to Multiple 

Federal Acquisition Regulation Violations............................................15 

Conclusion .................................................................................................... 20 

Recommendations ......................................................................................... 20 

Appendices 

Appendix A: Objective, Scope, and Methodology ................................. 24 

Appendix B: FEMA Comments to the Draft Report ............................... 27 

Appendix C: Survey Results of Puerto Rico Municipalities .................... 38 

Appendix D: Report Distribution ......................................................... 43 

Abbreviations 

CO Contracting Officer 

CONUS Continental United States 

COR Contracting Officer’s Representative 

FAR Federal Acquisition Regulation 

FEMA Federal Emergency Management Agency 

FSA Federal Staging Area 

GAO Government Accountability Office 

GPS Global Positioning System 

LSCMS Logistics Supply Chain Management System 

MRE Meals Ready-to-Eat 

OIG Office of Inspector General 

POD Point of Distribution 

PREMA Puerto Rico Emergency Management Agency 

RSA Regional Staging Area 

SOP Standard Operating Procedure 

U.S.C. United States Code 

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Background 

On September 6, 2017, the eye of Hurricane Irma passed the northern coast of 

the U.S. Virgin Islands and Puerto Rico. On September 20, 2017, Hurricane 

Maria made landfall in Puerto Rico as a Category 4 hurricane. The storm 

severely damaged Puerto Rico’s transportation, electrical, and communication 

infrastructures. Damage to these critical infrastructures left Puerto Rico’s 

entire population of 3.7 million without electricity and 95 percent of cell towers 

out of service. All of the island’s residents were disaster survivors who had to 

rely on FEMA’s response efforts for basic commodities, such as food and water, 

for extended time periods. As of December, 2018, FEMA reported it had spent 

approximately $2.5 billion in response to Hurricane Maria. 

The Robert T. Stafford Disaster Relief and Emergency Assistant Act (Stafford 

Act), permits the President to declare a major disaster when requested by the 

state governor or tribal government chief executive.1 The Department of 

Homeland Security has the primary responsibility for coordinating disaster 

response for the Federal Government and the Federal Emergency Management 

Agency (FEMA) leads the Department’s response efforts.2 The National 

Response Framework describes how the Federal Government, states and 

localities, and public and private sectors should respond to disasters.3 State 

and local authorities usually serve as first responders to disasters. Federal 

agencies become involved in disaster response when response and recovery 

requirements exceed state and local government capabilities. 

In accordance with the FEMA Region II Hurricane Annex for Puerto Rico & Virgin 

Islands, the commodities distribution process should start with Puerto Rico 

municipalities submitting commodity requests to FEMA. Then, FEMA 

coordinates the movement of these commodities from its distribution center in 

Atlanta, GA (or other suppliers as needed) through the closest port (i.e., 

Jacksonville, FL) via maritime transportation services. FEMA relied on Crowley 

Maritime Corporation (Crowley) to ship the commodities to Puerto Rico and to 

distribute them throughout the island. 

Once commodities arrive at the Port of San Juan in Puerto Rico, FEMA 

Logistics4 (located at the Joint Field Office) coordinates the movement of these 

1 42 United States Code (U.S.C.) § 5170. 

2 6 U.S.C. § 313(c)(4). 

3 The National Response Framework is the part of the National Preparedness System 

established in Presidential Policy Directive 8 that is to be used to manage any type of disaster 

or emergency response, regardless of scale, scope, and complexity. 

4 The Joint Field Office is a temporary Federal facility where FEMA coordinates disaster 

response in the area. 

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commodities based on commodity requests. FEMA Logistics directs the 

movement of the commodities from two Federal staging areas5 (FSA) to the 

Puerto Rico government’s regional staging areas6 (RSA) or points of 

distribution7 (POD) across the island (see Figure 1). 

Figure 1. Commodity Distribution Process to Puerto Rico 

Source: DHS Office of Inspector General (OIG) analysis of the commodity distribution process to 

Puerto Rico 

FEMA uses the Logistics Supply Chain Management System (LSCMS) to track 

commodities and property shipments from initial order to final distribution. 

The state, or in the case of Puerto Rico, the Commonwealth, generally serves as 

5 A Federal staging area is a federally-managed area or facility where commodities and 

equipment are positioned by FEMA, generally in anticipation of or in response to an incident. 

6 A regional staging area (also called State staging area) is a state-managed area or facility set 

up and operated solely by the state. 

7 A point of distribution is a state-operated area where disaster relief supplies are distributed 

directly to survivors. 

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the final distribution point during a disaster response. Once FEMA transfers 

ownership of the commodities to the state for distribution to disaster survivors, 

FEMA’s responsibility ends. In the case of the Commonwealth of Puerto Rico, 

the RSAs and PODs represent the final distribution points where FEMA 

transferred ownership. FEMA can also use LSCMS to track shipments to its 

own warehouses. In these instances, FEMA maintains ownership of the 

commodities and stores them for later distribution or future disasters. 

LSCMS capabilities provide real-time visibility of commodity shipments, 

including location, quantity, movement, and status. According to the LSCMS 

Standard Operating Procedures (SOP), the commodity distribution process is 

initiated in the system with the placement of a customer order8 for 

commodities necessary to meet the anticipated needs of the affected 

population. The Logistics Management Center9 approves the customer order 

and forwards it to the Supply Chain Integration Branch.10 This branch, 

located at FEMA headquarters, sources the requested commodities, provides 

order approval, and forwards the customer order to the Transportation 

Management Branch11 for shipping. The Transportation Management Branch 

makes all transportation arrangements and moves the commodities between 

locations. The FSA receives the commodities from the sources and stages them 

for shipping to the state upon request (see Figure 2). 

8 As the initial orders for commodities in the supply chain, customer orders are placed in 

LSCMS to request movement of commodities from one location to another. 

9 The Logistics Management Center is responsible for managing, collecting, and processing all 

logistics requirements and requests. 

10 The Supply Chain Integration Branch oversees the commodity inventory at FEMA 

distribution centers and determines how to source the requested items. Items can be sourced 

from FEMA’s supply chain or from other partners and vendors. 

11 This branch is responsible for contracting the transportation of FEMA commodities through 

the use of transportation companies. 

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OFFICE OF INSPECTOR GENERAL 

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Figure 2. LSCMS Orders Overview 

Source: DHS OIG analysis of the LSCMS Orders Overview 

As reported by the Government Accountability Office12 (GAO) and in FEMA’s 

own after-action report,13 FEMA acknowledged it inadequately planned when 

stating the agency could have better leveraged open-source information and 

preparedness data, such as capability assessments and exercise findings, for 

Puerto Rico and the U.S. Virgin Islands. For example, a 2011 exercise afteraction report for Puerto Rico indicated the territory would require extensive 

12 GAO Report to Congressional Addressees, 2017 Hurricanes and Wildfires, Initial 

Observations on the Federal Response and Key Recovery Challenges, September 2018. 

13 FEMA After-Action Report, 2017 Hurricane Season, July 12, 2018. 

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Federal support in moving commodities from the mainland to the island and 

throughout to distribution points. Accordingly, FEMA listed several corrective 

actions in its after-action report to address its longstanding planning issues. 

Results of Audit 

FEMA mismanaged the distribution of commodities in response to Hurricanes 

Irma and Maria in Puerto Rico. FEMA lost visibility of about 38 percent of its 

commodity shipments to Puerto Rico, worth an estimated $257 million. 

Commodities successfully delivered to Puerto Rico took an average of 69 days 

to reach their final destinations. Inadequate FEMA contractor oversight 

contributed to the lost visibility and delayed commodity shipments. FEMA did 

not use its Global Positioning System transponders to track commodity 

shipments, allowed the contractor to break inventory seals,14 and did not 

ensure documented proof of commodity deliveries. Given the lost visibility and 

delayed shipments, FEMA cannot ensure it provided commodities to Puerto 

Rico disaster survivors as needed to sustain life and alleviate suffering as part 

of its response and recovery mission. 

In addition, FEMA’s mismanagement of transportation contracts included 

multiple contracting violations and policy contraventions. These violations 

occurred because of poor acquisition planning that did not address 

requirements for transoceanic shipments. While we understand FEMA’s 

priority on expediting commodity shipments to disaster survivors, their priority 

overrode the importance of following sound inventory management practices, 

significantly increasing the potential for fraud, waste, and abuse. Contract 

costs grew without FEMA having proof that services were performed as 

required and ultimately led to contract overruns of about $179 million and at 

least $50 million in questioned costs. 

FEMA Mismanaged the Commodity Distribution Process in 

Response to Hurricanes Irma and Maria 

FEMA lost visibility of approximately $257 million in life-sustaining 

commodities.15 The shipments successfully delivered, took an average of 69 

days to reach their final destinations. This occurred because Hurricane 

Maria’s catastrophic damage in Puerto Rico and multiple, concurrent disasters 

14 OIG makes no finding with respect to Crowley’s responsibility. 

15 Statements and conclusions within this report derived from FEMA-provided data are subject 

to the limitations and conditions described in Appendix A: Objective, Scope, and Methodology. 

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nationwide challenged FEMA. In efforts to expedite commodity shipments, 

FEMA did not follow established policies and procedures. For example, FEMA 

did not fully utilize its Global Positioning System (GPS) transponder technology 

to track commodity movements. It also allowed the transportation contractor 

to break container seals and redistribute commodities and did not require 

them to provide proof of commodity deliveries. Although FEMA delivered an 

estimated 3,743 commodity shipments to the Puerto Rico government’s RSAs 

and PODs, FEMA cannot provide reasonable assurance that it successfully 

delivered sufficient life-sustaining commodities to the disaster survivors in a 

timely manner as needed. 

FEMA Lost Visibility of Commodity Shipments to Puerto Rico 

FEMA’s LSCMS SOPs are designed to ensure that FEMA can track its 

commodities through every part of the FEMA Supply Chain, from initial order 

to final distribution. LSCMS can provide visibility of commodity movements 

through the FEMA Supply Chain through the use of GPS transponders 

attached to trailers, or in the case of Puerto Rico shipments, containers. This 

allows personnel with LSCMS access to see the location of commodities at any 

given time during their transfer from one facility location to another. When 

such capabilities are used as designed, FEMA should have real-time visibility of 

all commodity orders, order status, such as pending or filled, and the 

progressive movement of commodities from initial location to the final 

destination. 

Based on LSCMS records, FEMA lost visibility of approximately 38 percent 

(4,462) of life-sustaining commodity shipments16 to Puerto Rico. 

Approximately 98 percent (4,354) of these commodity shipments consisted of 

meals and water. FEMA personnel at the Jacksonville FSA reported that FEMA 

headquarters did not record customer orders in a timely manner, or did not 

record them at all. As such, FSA personnel in Jacksonville often did not know 

what commodities were shipped until after they had arrived because no LSCMS 

records existed. This negatively impacted the FSA’s ability to plan for 

transportation of the commodities to Puerto Rico and created backups at the 

Jacksonville port that exceeded field and vendor storage capacities. In 

response to the large volume of commodities ordered, FEMA had to open up 

two overflow sites in Jacksonville to store commodities awaiting shipment, as 

well as divert a significant amount of commodities to other locations. 

According to FSA personnel in Jacksonville, some commodity shipments 

16 A shipment represents the movement of one commodity container between one or more 

locations from its point of origin to the final destination. 

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intended for Puerto Rico likely never left the continental United States 

(CONUS). 

For supply chain accounting purposes, FEMA made adjustments to LSCMS to 

account for the lost visibility of commodity shipments. According to FEMA 

officials, they adjusted LSCMS records for these shipments by changing the 

last known locations in LSCMS to “unknown FSAs” or “unknown points of 

distribution.” FEMA officials advised us that they used ‘unknown’ as a 

destination as they believed the shipments were delivered throughout Puerto 

Rico but could not specifically identify the delivery locations. For example, in 

January 2018, FEMA adjusted 2,402 LSCMS records by changing the final 

locations to unknown FSAs. These records represented about 54 percent of the 

lost visibility commodity shipments. The estimated costs of the life-sustaining 

commodities associated with the lost visibility shipments total approximately 

$257 million, as shown in Table 1. 

Table 1. Estimated Costs of Lost Visibility Commodities 

Commodity Total Product Cost 

Per Unit Estimated Costs 

Meals 43,788,042 $5.16 $225,946,297 

Water 40,033,770 $0.55 $22,018,574 

Blankets 32,025 $12.95 $414,724 

Cots 36,972 $39.00 $1,441,908 

Tarps 33,520 $40.00 $1,340,800 

Sheeting 26,738 $212.40 $5,679,151 

Totals $256,841,454 

Source: DHS OIG analysis of estimated commodity costs 

The loss of visibility resulted in actual financial loss to the Government. 

According to FEMA, they conducted a physical re-organization of more than 

3,000 shipping containers dispersed throughout Puerto Rico. The contents of 

these containers were reconciled with LSCMS records. After final accounting 

for all meal and water shipments, FEMA indicated it was unable to locate 19 

containers and their associated contents valued at $303,000. However, we 

cannot determine the extent of what was lost due to the internal control 

failures addressed in this report and acknowledged by FEMA. 

Commodity Shipments Successfully Delivered Were Significantly Delayed 

In a post-disaster situation, FEMA must ensure survivors receive lifesustaining commodities as quickly as possible to help with the recovery 

process. However, FEMA took an average of 69 days to transfer commodities 

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valued at approximately $154 million to the Commonwealth’s RSAs and PODs. 

Specifically, it took FEMA an average of 13 days to ship the commodities from 

various contractor sites located within CONUS to Puerto Rico. Once on the 

island, commodities sat in FEMA’s custody at various locations on the island 

approximately 48 days. The final transfer of the commodities from FEMA’s 

custody to their end destinations took about 7.5 additional days. 

Water and food, two of the most important life-sustaining commodities, 

experienced average shipping delays of 71 and 59 days, respectively. Of the 

approximately 97 million liters of water FEMA shipped to Puerto Rico between 

September 2017 and April 2018, 36 million liters (approximately 37 percent) 

reached the RSAs or PODs for distribution. Likewise, during the same period, 

of the 53 million meals FEMA shipped to Puerto Rico, 24 million (approximately 

45 percent) reached the RSAs or PODs for distribution. The remaining 

commodity shipments for both water and meals that arrived in the 

Commonwealth either remained in FEMA’s custody, were in contractor 

facilities, or had unknown destinations. Figures 3 and 4 illustrate water and 

food quantities arriving in Puerto Rico versus quantities received by the 

municipalities for distribution to survivors. 

Figure 3. Water Shipments Arriving at the Puerto Rico Port versus Those 

Delivered to the Commonwealth’s RSAs and PODs 

Source: DHS OIG analysis of LSCMS-extracted data 

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Figure 4. Meal Shipments Arriving at the Puerto Rico Port versus Those 

Delivered to the Commonwealth’s RSAs and PODs 

Source: DHS OIG analysis of LSCMS-extracted data 

As part of our audit, we conducted a Puerto Rico municipality survey,17 the 

results of which supported this conclusion regarding delayed commodity 

shipments. According to our survey results, it took FEMA an average of 10 

days immediately after the hurricanes to deliver the first food and water to the 

disaster survivors.18 Furthermore, only 27 percent (8 of 30) of the 

municipalities received sufficient amounts of water and only 20 percent (6 of 

30) received sufficient amounts of food in the first commodity delivery. 

17 In October 2018, OIG issued a survey consisting of 45 questions to Puerto Rico’s 78 

municipalities to obtain their perspective of FEMA’s response to commodity distribution after 

Hurricane Maria. 

18 While awaiting the arrival of commodities via maritime transportation, FEMA sent 

commodities by airplane and helicopter to Puerto Rico in the days immediately following the 

disaster. These airdropped commodities provided minimal assistance to the disaster survivors 

while waiting for the maritime shipments to arrive in Puerto Rico. However, these quantities 

were insufficient to meet the survivors’ needs. 

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Although commodity distribution improved over the first 2 months after 

Hurricane Maria, approximately 24 percent (6 of 25) of municipalities did not 

receive sufficient food and water to support their disaster survivors. 

Furthermore, 40 percent (12 out of 30) of municipalities said they experienced 

significant problems with receiving expired food. 

Moreover, the food that was delivered was nutritionally deficient. In an effort to 

quickly ship commodities to survivors, FEMA provided various food types such 

as meals ready-to-eat (MRE), snack boxes, and shelf-stable food that it deemed 

as meals.19 However, these meals varied widely in food type, and some meal 

types contained questionable nutritional value. For example, FEMA sent 

“meal” boxes that included junk food such as Oreos, candy, cereal bars, and 

other similar items that lacked sufficient nutritional value (see Figure 5). 

Figure 5. Contents of Meal Boxes 

Source: Photos provided by the Puerto Rico State Guard 

FEMA sent these snack boxes because it was unable to order additional meals 

ready-to-eat due to the demand from concurrent disasters. Advance contract 

vendors were at capacity in providing nutritional meals following Hurricane 

Harvey and could not produce any more to support the effort in Puerto Rico. 

As a result, Puerto Rico increased the number of snack boxes distributed per 

survivor to account for the nutritional deficiencies of the food items. Puerto 

Rico officials reported one meal for approximately every 12 snack boxes 

distributed to a survivor. This created challenges for FEMA when it attempted 

to reconcile Puerto Rico’s meal distribution records with its LSCMS records as 

19 Shelf stable food is non-perishable food that can be safely stored at room temperature or on 

the shelf. 

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the meal figures did not match FEMA’s distribution figures. Approximately 4 

months into the disaster response, FEMA and Puerto Rico came to an 

agreement on the meal conversion factors for reporting purposes, which 

significantly reduced the number of meals FEMA reported for certain meal 

types. 

FEMA’s Inadequate Oversight of the Transportation Contractor 

Contributed to the Lost Visibility and Delayed Commodity Shipments 

The Federal Acquisition Regulation (FAR) requires agencies to establish 

effective management practices to prevent fraud, waste, and abuse in service 

contracting. It also requires agencies to ensure supplies or services tendered 

by contractors meet contract requirements. However, Hurricane Maria’s 

catastrophic damage in Puerto Rico and multiple, concurrent disasters 

nationwide challenged FEMA. FEMA’s efforts to expedite commodity shipments 

resulted in lost visibility and delayed commodities because FEMA did not 

provide adequate oversight of the transportation contractor responsible for 

shipping commodities to and within Puerto Rico. For example, FEMA 

disregarded commodity tracking SOPs, allowed the contractor to break 

container seals to redistribute commodities, and did not require the contractor 

to provide proof of delivery. 

FEMA Did Not Fully Utilize Its Global Positioning System Technology to Track 

Commodity Movements 

LSCMS Program SOPs emphasize the importance of maintaining visibility of 

commodity movements. GPS technology serves as one of the most critical 

control components in the commodity distribution process. GPS facilitates 

decision-making processes during a disaster response by providing the 

physical location of commodities at any given time. When commodity 

containers arrive within 5 miles of the designated coordinates, GPS capabilities 

automatically populate LSCMS with the date and time of their arrival. 

However, FEMA did not fully utilize its GPS technology to monitor commodity 

movements for over 75 percent of its shipments to Puerto Rico, and over 96 

percent of its shipments within Puerto Rico. To illustrate, FEMA did not 

ensure GPS transponders worked properly or record GPS numbers in LSCMS. 

Additionally, FEMA had challenges using its GPS for commodity shipments to 

Puerto Rico because the vertical stacking of containers on barges and at 

staging yards caused signal loss that prohibited the transmission of geographic 

data. 

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Given inadequate use of the GPS technology, FEMA had GPS data recorded for 

only 3.4 percent of the commodity shipments transported within Puerto Rico. 

FEMA consequently had limited knowledge about the location of the commodity 

shipments. LSCMS technicians had to manually monitor commodity 

movements and update LSCMS well after the movements had occurred and 

without proof of delivery as required by LSCMS policies. This resulted in 

untimely entries that hampered FEMA’s ability to track commodity movements 

and to manage commodity distribution. FEMA also could not strategically 

move commodities that it could not locate on the island. 

FEMA Allowed the Contractor to Break Container Seals and Redistribute 

Commodities in Different Containers 

FEMA’s LSCMS Program SOPs require the use of seals as a means of inventory 

control and accountability. Seals with unique numbers are affixed to shipping 

containers to ensure container contents are not modified, stolen, or damaged 

during shipment. Upon initially receiving ordered commodities, FEMA 

supervises the packing of each container with the commodities and enters a 

description into LSCMS regarding the container’s contents. FEMA personnel 

place a seal on each container and record the number in LSCMS immediately 

prior to transferring the container to the transportation contractor. At the time 

of removal, FEMA personnel verify the seal numbers against LSCMS records. 

However, due to inadequate FEMA oversight, Crowley Maritime Corporation 

(Crowley), FEMA’s transportation contractor, broke the FEMA inventory seals 

and repackaged commodities at a second cross-docking location20 in 

Jacksonville, FL. Disregarding the original packing slips and cargo manifests 

provided by FEMA, Crowley created generic cargo manifests labeled “relief 

supplies” that negatively impacted subsequent commodity shipment 

operations. Cargo manifests are critical as they provide details such as 

descriptions of the goods and their respective quantities, and relevant 

consignor and consignee information. According to FEMA personnel, the 

accuracy of Crowley’s manifests was questionable. Crowley did not know the 

contents of all containers shipped due to its generic cargo manifests. 

Consequently, our data analysis indicates about 1,000 containers may have 

never left the Jacksonville port. FEMA personnel in Jacksonville indicated that 

over 1,500 containers that FEMA packed — most of them early in the disaster 

— may have never made it to Puerto Rico. 

20 A Cross Docking Operation takes a product from a truck or trailer and moves that material 

in its entirety to another trailer or container. 

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The contractor reported that it broke the seals to cross-dock and maximize 

shipping space to balance commercial and FEMA requirements. This 

contributed to delays in providing commodities to disaster survivors. For 

example, of the 7,942 commodity shipments sent from the CONUS to Puerto 

Rico, 41 percent took longer than 14 days to arrive on the island (see Figure 6). 

Figure 6. Shipment Times from CONUS to Puerto Rico by Commodity 

Type 

Source: DHS OIG 

Not only did the practice of breaking seals to cross-dock delay shipments 

leaving CONUS, it also delayed shipments traveling within Puerto Rico. For 

example, LSCMS data shows that 538 shipments departed the Crowley 

Bayamon Yard in Puerto Rico, where each of these shipments was subject to 

an additional delay of about 9 days. 

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FEMA Did Not Require the Contractor to Provide Proof of Commodity Delivery 

The FAR21 requires agencies to ensure that services provided by contractors 

meet contract requirements. Additionally, the LSCMS Program SOPs and the 

LSCMS Closeout Process Overview require that delivery personnel obtain 

signatures from receiving officials and return the signed receipt to the FSA. 

FEMA’s process documents also require the use of gate logs22 to record 

deliveries. FEMA must retain the signed receipts as part of the disaster file. 

Despite these requirements, our review of a random sample of 90 LSCMS 

commodity shipments from September 2017 through April 2018 showed that 

FEMA could not always substantiate delivery of commodities. Our sample 

included 45 commodity shipments from CONUS to the Puerto Rico FSA, and 

another 45 commodity shipments from the Puerto Rico FSA to the Puerto Rico 

government’s regional staging area. We requested documentation required for 

point-to-point shipping, including gate logs, packing slips, shipping sheets, 

bills of lading, and manifests. 

FEMA could not provide supporting documentation for 86 of the 90 (96 

percent) commodity shipments reviewed. FEMA provided packing slips for 4 

Puerto Rico FSA shipments to the Puerto Rico government’s regional staging 

area. FEMA did not require Crowley to return proof of delivery for commodities 

transported from the ports to facilities throughout the island. FEMA also did 

not require Crowley to provide access to its logistics tracking system. 

Consequently, FEMA cannot provide assurance that Crowley successfully 

delivered the commodities to their intended destinations. 

FEMA Cannot Provide Reasonable Assurance It Distributed Sufficient 

Amounts of Life-Sustaining Commodities to Disaster Survivors in a Timely 

Manner 

With limited real-time visibility of commodity movements and over-reliance on 

the transportation contractor for commodity distribution, FEMA cannot provide 

reasonable assurance it distributed a sufficient amount of life-sustaining 

commodities in a timely manner. Because FEMA lacked accountability over 

the commodities it distributed, FEMA, as previously stated, reconciled its 

distribution figures with Puerto Rico government-provided data to determine 

the number of commodities distributed to disaster survivors. We attempted to 

21 FAR Part 46.102(b). 

22 A gate log is a written record of commodity shipments either to or from a given facility 

consisting of information such as date, time, trailer number, and commodities. 

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verify this data with the Puerto Rico government’s distribution numbers but 

determined the data was not reliable for reporting purposes. 

The Puerto Rico government lacked a formal records management system to 

track commodities received from FEMA and distributed to the municipalities. 

Instead, Puerto Rico government personnel maintained manual records that 

were not filed in an organized manner in a designated location where they 

could be easily retrieved. For example, we requested supporting 

documentation to verify commodity distribution numbers in the Puerto Rico 

government’s summary reports provided to FEMA. Puerto Rico government 

officials could not provide the supporting commodity distribution records 

because they were dispersed throughout various locations on the island, 

including a personal residence. 

FEMA’s Mismanagement of the Transportation Contracts Led to 

Multiple Federal Acquisition Regulation Violations 

FEMA’s mismanagement of its transportation contracts23 with Crowley and 

Estes Express Lines (Estes) resulted in multiple violations of Federal 

regulations. Specifically, we noted the following: 

x FEMA’s advanced transportation contracts did not include adequate 

transportation services necessary for disaster response; 

x FEMA awarded an unauthorized sole source contract with no reasonable 

price determination; 

x FEMA did not practice sound funds management; and 

x FEMA improperly validated and approved payment on contractor 

invoices. 

These actions occurred because FEMA did not develop an acquisition plan that 

adequately addressed commodity distribution requirements for transoceanic 

shipments at various surge levels and corresponding cost estimates. Further, 

management’s priority on disaster response, which overrode adherence to 

sound business practices, contributed to the violations. As a result, FEMA 

allowed transportation contractors to exceed their contract ceilings by a 

combined $179 million. These actions also resulted in significant risk for 

fraud, waste, and abuse, including questioned costs of approximately $50 

million. 

23 FEMA awarded a transportation contract (Contract No. HSFE70-16-D-0204) to Crowley on 

August 30, 2016. FEMA awarded another transportation contract (Contract No. HSFE70-16-

D-0209) to Estes Express Lines on September 30, 2016. 

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FEMA’s Advanced Transportation Contract Did Not Include Adequate 

Transportation Services Necessary for Response to Puerto Rico Disaster 

The Post-Katrina Emergency Management Reform Act of 200624 requires FEMA 

to establish advanced contracts for quick disaster response. The FAR25 also 

requires agencies to perform acquisition planning and to conduct market 

research for all acquisitions to ensure that the Government meets its needs in 

the most effective, economical, and timely manner possible. 

FEMA awarded an advanced contract to Crowley on August 30, 2016, for the 

purpose of commodity prepositioning for the U.S. Virgin Islands. However, the 

contract did not meet the needs of FEMA for a quick disaster response to 

provide life-sustaining commodities to disaster survivors. The original contract 

quickly reached its capacity because it did not effectively outline the following 

basic transportation services needed for transoceanic shipments: 

x cross-docking services, 

x transportation to port of embarkation, 

x point of embarkation processing, 

x transportation to port debarkation, 

x port of debarkation processing, and 

x transportation to the FSA and regional staging areas. 

The planning process should have included early consultation with logistics 

personnel concerning quantity and delivery requirements. Sound acquisition 

planning prior to a disaster through the establishment of advanced contracts is 

essential for FEMA to provide life-sustaining goods and services in the 

immediate aftermath of disasters. 

FEMA Awarded an Unauthorized Sole Source Contract with No Reasonable 

Price Determination 

FAR Part 6.101(b) requires full and open competition using competitive 

procedures. Any additional work that falls outside of an original contract’s 

scope requires competition unless the agency makes a valid determination that 

a sole source justification exists and obtains the appropriate approvals.26 

Nonetheless, with surging needs for transportation of life-sustaining 

commodities, FEMA verbally directed Crowley to perform commodity 

transportation services that significantly exceeded the contract’s original scope 

24 Pub. L. No. 109-295, § 691 (codified at 6 U.S.C. § 791). 

25 FAR Part 7.102 and 7.104. 

26 FAR 6.303-1(a) and 6.304(a). 

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of work to provide commodity pre-positioning in the U.S. Virgin Islands. The 

revised, expanded scope provided all-inclusive transportation and shipping 

services in response to Hurricanes Irma and Maria, triggering competitive 

requirements that required action from FEMA. 

Although FEMA justified its scope revision by citing unusual and compelling 

urgency, it did not obtain the proper approvals to execute a sole source 

contract. On September 30, 2017, the contracting officer (CO) initiated a new 

sole source contract and a justification for other than full and open 

competition, with a $250 million contract ceiling. The CO then sent the new 

sole source justification to FEMA management for review but did not receive 

any feedback. In the meantime, Crowley continued to perform services and 

incur costs based on FEMA’s verbal direction with no contract in place. 

When FEMA officials did not approve the new contract, the CO awarded a 

contract modification to the existing contract on October 24, 2017. The 

modification increased the contract ceiling to $100 million, and added more 

than 100 contract line item numbers. However, these modifications exceeded 

the CO’s $25 million warrant authority. According to FAR Part 1.602-1, a CO 

may bind the Government only to the extent of the authority delegated to them. 

As a result, the CO made an unauthorized commitment. FAR Part 1.602-3(a) 

defines an unauthorized commitment as “an agreement that is not binding 

solely because the Government representative who made it lacked the authority 

to enter into that agreement on behalf of the Government.” 

Even if the CO had retained the appropriate authority to modify the contract, 

the CO did not establish price reasonableness before doing so, as required by 

Federal regulations.27 Price reasonableness ensures COs purchase supplies 

and services at fair and reasonable prices. Instead, the CO took the list of 

services and prices provided by Crowley and incorporated them into the 

contract without questioning costs. 

In March, 2018, Crowley submitted a consolidated invoice totaling 

approximately $159 million for services performed from August 27, 2017, to 

March 7, 2018. This included a $155 million cost overrun of the $4 million 

contract ceiling. FEMA requested assistance from a DHS price analyst to help 

determine price reasonableness. This price reasonableness determination 

included reviewing supporting documentation provided by Crowley, examining 

another Federal contract Crowley had with the Department of Defense for 

similar services, and consulting with FEMA’s Logistics Division. On April 6, 

2018, FEMA determined that approximately $114 million represented a fair 

27 FAR 15.402. 

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and reasonable price for the services performed and ratified the contract. The 

agency questioned the approximately $45 million that remained, stating it 

would be ratified in an amendment to the document should the prices be found 

fair and reasonable. Crowley later filed a claim for unpaid or partially paid 

invoices, including the remaining $45 million, so this matter is currently in 

litigation. 

FEMA Did Not Practice Sound Funds Management 

Acquisition planning includes developing written acquisition plans that contain 

action plans addressing budget estimates and how the agency intends to 

obtain funding when required.28 This ensures that government agencies do not 

violate the Anti-Deficiency Act.29 Government officials may not make or 

authorize an obligation exceeding the amount available in an appropriation or 

fund for that obligation. According to FAR 32.702, the CO must obtain written 

assurance of the availability of adequate funds or include a contract clause 

that limits funds availability. 

FEMA’s verbal direction to transportation contractors and delays in approving 

contracting actions contributed to unfunded commitments and potential AntiDeficiency Act violations. FEMA did not develop cost estimates for surge 

operations during the acquisition planning phase and had significant difficulty 

determining spending rates on various transportation contracts. 

When FEMA received Crowley’s consolidated invoice in March 2018 totaling 

approximately $159 million, it had only committed and obligated funds totaling 

$48 and $47 million, respectively. Additionally, FEMA’s contract with Crowley 

did not contain any availability of funds clauses until it attempted a fourth 

contract modification, which was not a valid modification. 

Similarly, when FEMA received Estes Express Lines30 invoices totaling 

approximately $33 million as of April 20, 2018, FEMA did not modify the Estes 

contract and increase the ceiling from approximately $9 million to almost $64 

million until April 26, 2018 — 6 days after it received the latest invoice from 

the contractor. This resulted in a $24 million cost overrun of the contract 

ceiling. The contract was subsequently ratified after Estes performed work in 

April 2018. 

28 FAR Part 7.105(b)(6). 

29 31 U.S.C. § 1341(a)(1)(A). 

30 Contract No. HSFE70-16-D-0209 was a transportation contract awarded by FEMA to Estes 

on September 30, 2016. 

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FEMA Improperly Validated and Approved Payment on Contractor 

Invoices 

According to FAR 37.102 (f), agencies shall establish effective management 

practices to prevent fraud, waste, and abuse in service contracting. 

Additionally, the Homeland Security Acquisition Manual Section 3032.7002 

states the CO is responsible for review and approval of invoices. It also 

provides examples of invoice review tasks that include ensuring billed costs are 

allocable and allowable to the contract. 

FEMA did not perform a sufficient review to validate and substantiate charges 

in contractor invoices prior to invoice payment or contract ratification. We 

sampled and reviewed 45 line items totaling approximately $50 million from 

contractor invoices. FEMA could not provide detailed supporting 

documentation for these line items. In another review, we could not trace and 

verify $72 million of line item expenses to the summary documentation 

provided with the invoices. Also, the contracting officer representative (COR) 

files contained no proof of delivery of commodity shipments or support for 

leased and rented equipment. Instead, the COR relied on verbal statements 

and emails from FEMA personnel in Puerto Rico to confirm the contractor 

provided required services and potentially paid for services not rendered. 

Poor Acquisition Planning and Mission Focus Contributed to the Federal 

Contract Violations 

Numerous FAR violations, policy contraventions, and potential Anti-Deficiency 

Act violations occurred because of poor acquisition planning and management 

focus on FEMA’s disaster response mission in lieu of following and enforcing 

essential internal controls. For example, FEMA did not develop an acquisition 

plan that adequately addressed commodity distribution requirements for 

transoceanic shipments at various surge levels and corresponding cost 

estimates. Consequently, poor planning placed the agency in a reactive mode 

to ensure the continuity of services during the disaster response. Better 

acquisition planning would have helped ensure timely, successful commodity 

shipments and lessened the negative impact of the catastrophic disaster on 

Puerto Rico. 

This situation resulted in FEMA making unauthorized, constructive31 contract 

changes it did not legally formalize until well after the response period closed. 

Contract costs grew without FEMA having proof that services were performed 

31 A constructive change is when a contractor performs work beyond the contract requirements, 

without a formal order under the changes clause through the fault of the buyer. 

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as required and resulted in at least $50 million in questioned costs. While we 

acknowledge emergencies often require improvisation and process adaptation, 

disregarding management controls had a negative impact on FEMA’s 

administration of critical transportation contracts. 

Conclusion 

FEMA faced tremendous challenges meeting mission requirements because of 

the catastrophic nature of Hurricane Maria and multiple, concurrent, 

nationwide disasters. Although we understand FEMA’s priority on expediting 

commodity shipments to disaster survivors, the extent of the deviations from 

established operating procedures significantly increased the risk for fraud, 

waste, and abuse. Some flexibility and adaptation of normal processes is 

expected during disaster responses, but controls necessary to safeguard 

commodities cannot be altogether ignored. FEMA’s emphasis on delivering 

commodities to disaster survivors overrode the importance of following sound 

inventory management practices. When combined with poor acquisition 

planning prior to the hurricanes, FEMA’s management of the commodity 

distribution process did not function properly. 

FEMA lost visibility of approximately 38 percent of its life-sustaining 

commodity shipments to Puerto Rico worth an estimated $257 million. 

Commodities successfully delivered to the Puerto Rico government took an 

average of 69 days to reach their final destinations. Consequently, FEMA 

cannot provide reasonable assurance it provided sufficient life-sustaining 

commodities to Puerto Rico disaster survivors in a timely manner. 

Furthermore, FEMA’s mismanagement included multiple contracting violations 

and policy contraventions that ultimately led to contract overruns of about 

$179 million and at least $50 million in questioned costs. 

Recommendations 

We recommend the FEMA Administrator: 

Recommendation 1: Develop a comprehensive strategy and implementation 

plans for improving asset tracking and in-transit visibility across all modes of 

transportation. These plans should also include specific goals and corrective 

actions to address the agency’s commodity distribution challenges in managing 

the end-to-end distribution process, ensure the accuracy of underlying data, 

and strengthen and integrate distribution policies and the governance 

structure. 

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Recommendation 2: Develop and improve management reporting and data 

gathering business processes to address the data reporting challenges, 

resulting in more accurate and near-real-time information that enables quality 

decision making in assessing disaster survivor support needs. 

Recommendation 3: Establish robust transportation, supply chain, and 

general logistics contingency contracts to provide more timely and effective 

delivery of disaster support. 

Recommendation 4: Develop internal controls over contract administration 

from initiation to closeout. These controls should: 1) ensure all contract 

requirements are met in accordance with the Federal Acquisition Regulation 

and corresponding DHS and FEMA policies and procedures; 2) ensure training 

needs are met by procurement personnel and appropriate approvals are 

obtained prior to the award or modification of contracts; and 3) ensure contract 

oversight officials adequately review invoices, including verifying costs, to the 

extent possible, based on source documentation to ensure billed costs are 

supported and allowed. 

Recommendation 5: Investigate FEMA’s transportation contracts in response 

to the Puerto Rico disaster for potential Anti-Deficiency Act violations and 

appropriately report the results of the review. 

Management Comments and OIG Analysis 

Although FEMA concurred with four of the five recommendations, it disagreed 

with our conclusions concerning commodity distribution. According to FEMA, 

its reconciliation resulted in accounting for all but 19 of 9,775 containers 

shipped to Puerto Rico. It took FEMA several months to locate these 

containers throughout the island, and it acknowledged some were empty or 

were filled with different products than expected. Finding lost containers does 

not mean FEMA found the commodities in the containers. The amount of 

commodities that FEMA lost because of its mismanagement of the distribution 

process is undeterminable. 

We consider recommendations 1 through 4 resolved and open. 

Recommendation 5 is resolved and closed. A copy of FEMA’s response in its 

entirety is included in Appendix B. FEMA also provided technical comments 

and suggested revisions to our report in a separate document. We reviewed the 

technical comments and made changes to the report where appropriate. A 

summary of FEMA’s response and our analysis follows. 

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FEMA’s Comments to Recommendation 1: Concur. FEMA’s strategy in 

response to this recommendation is to address the multi-modal components of 

asset tracking along with in-transit visibility of FEMA’s systems, processes, 

training, and personnel. FEMA has taken several targeted improvements such 

as deploying the Transportation Procurement module and implementing other 

LSCMS system improvements, publishing guidance like the Transportation 

Management Guide, and procuring solar satellite transponders to replace the 

legacy transponders. Estimated Completion Date: July 30, 2021 

OIG Analysis of FEMA’s Comments: FEMA’s corrective actions are 

responsive to the recommendation. However, the recommendation will remain 

open and resolved until we receive and evaluate a comprehensive supply chain 

strategy and corresponding initiatives, in conjunction with implementation 

plans that include estimated completion dates, for all critical aspects of supply 

chain management and distribution. At a minimum, the strategy and 

implementation plans should address the use of technology for evaluating 

supply and demand and tracking visibility; communication, collaboration, and 

accountability with third-party vendors; contracting; key performance metrics 

for timeliness and delivery based on severity of a disaster; and risk factors 

impacting the distribution process. 

FEMA’s Comments to Recommendation 2: Concur. FEMA’s efforts to 

address this recommendation consist of planning, upgrading, and 

implementing aspects of information technology and data analysis. FEMA has 

undertaken LSCMS improvements and data collection tasks such as expanded 

Business Intelligence data models to improve ad-hoc, operational, and 

management reporting; moved LSCMS to the Cloud resulting in improvements 

to system agility; and developed a multi-layered disaster logistics reporting and 

data gathering business tool. Estimated Completion Date: December 31, 2020 

OIG Analysis of FEMA’s Comments: FEMA’s corrective actions are 

responsive to the recommendation. The recommendation will remain open and 

resolved until we have reviewed and analyzed documentation supporting 

actions taken to improve management reporting and data gathering. 

FEMA’s Comments to Recommendation 3: Concur. FEMA Logistics has 

improved its logistics capabilities for response operations, including updates 

and expansions to high-priority, national-level commodity contracts. 

Improvements include replacement of a previous inter-island contract with a 

contract that has all-inclusive transportation and shipping services from a 

CONUS point of origin to Puerto Rico and the U.S. Virgin Islands. FEMA also 

awarded a National Cross Dock and Incident Support Base contract to aid in 

the movement control and management of disaster response resources. FEMA 

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also plans to award a multi-year contract vehicle to vendors, replacing a 

previous version, while also developing robust OCONUS transportation 

contracts for Hawaii, the Commonwealth of Northern Mariana Islands, and 

Alaska to provide transportation services for the movement of resources during 

a disaster response. Estimated Completion Date: August 31, 2021 

OIG Analysis of FEMA’s Comments: FEMA’s corrective actions are 

responsive to the recommendation. The recommendation will remain open and 

resolved until we have reviewed contract documentation supporting these 

actions. 

FEMA’s Comments to Recommendation 4: Non-Concur. FEMA’s Office of 

the Chief Procurement Officer has processes and procedures in place for 

internal controls addressing contract administration from initiation to closeout. 

FEMA contracting personnel receive updated policy guidance through the 

issuance of standard operating procedures and acquisition alerts throughout 

the fiscal year. FEMA OCPO continues to refine the internal control processes 

on an ongoing basis. Among other policies, FEMA issued the “Disaster 

Contracting Desk Guide,” which covers the entire disaster procurement process 

from submittal of a requisition through contract closeout. FEMA also created a 

draft FEMA Acquisition Manual that establishes the FEMA component-wide 

acquisition procedures that supplement the FAR and other requirements or 

policies. 

OIG Analysis of FEMA Comments: Although FEMA did not concur with the 

recommendation, the agency’s actions to continuously refine internal control 

processes are responsive to this recommendation. The recommendation will 

remain open and resolved until we have received and reviewed the policies and 

procedures outlined in the response. 

FEMA’s Comments to Recommendation 5: Concur. FEMA investigated the 

possibility of an Anti-Deficiency Act violation while assessing the unauthorized 

commitment in October 2018. During that assessment, FEMA OCPO analyzed 

the contract action and used cost and price analysts to demonstrate fair and 

reasonable pricing. FEMA determined there was no violation as there was 

money in the Disaster Relief Fund account at the time of the procurement. 

These conclusions are supported in the ratification letter, which was approved 

by the Office of General Counsel and the Head of the Contracting Activity. 

OIG Analysis of FEMA Comments: FEMA’s corrective actions are responsive 

to this recommendation, and we have reviewed the signed ratification letter 

along with documentation supporting the cost assessment. The 

recommendation is considered resolved and closed. 

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Appendix A 

Objective, Scope, and Methodology 

Department of Homeland Security Office of Inspector General was established 

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

the Inspector General Act of 1978 (5 U.S.C. app. 3 (1978). 

Our audit objective was to determine to what extent FEMA managed and 

distributed commodities in the Commonwealth of Puerto Rico in response to 

Hurricanes Irma and Maria. To answer the objective, we interviewed FEMA, 

Puerto Rico, and contract officials, reviewed applicable policies and procedures 

related to disaster support, conducted site visits, observed operations, and 

analyzed LSCMS data. 

We evaluated FEMA’s internal controls to the extent necessary to accomplish 

our objective. Specifically, we developed an understanding of internal controls 

over the commodity distribution process by reviewing program documentation 

and other FEMA and DHS guidance, and interviewing FEMA personnel 

assigned to oversee and manage the process. We assessed the internal 

controls in place at the time of the response, and examined their effectiveness 

in light of the evidence obtained throughout the audit. 

To determine how FEMA managed and distributed commodities in the 

Commonwealth of Puerto Rico in response to Hurricanes Irma and Maria, we 

met with officials from FEMA including FEMA Headquarters, FEMA Region II, 

the Joint Field Office, and the FSAs in Puerto Rico. We interviewed 

representatives from the National Response Coordination Center. We also 

interviewed officials from across the Commonwealth of Puerto Rico, including 

the Puerto Rico Emergency Management Agency (PREMA), the Puerto Rico 

National Guard, the Puerto Rico State Guard, and the Puerto Rico 

municipalities. 

We conducted site visits in Jacksonville, FL, which included the Port of 

Jacksonville and a Federal Staging Area. We also conducted site visits in 

Puerto Rico, which included the Joint Field Office, the Port of San Juan, 

FEMA’s Caribbean Distribution Center, two FSAs, one RSA, and several 

warehouse facilities used to store commodities. 

We obtained an understanding of FEMA’s supply chain management process, 

including use of LSCMS. We also obtained an understanding of FEMA’s 

regional planning and preparedness process, including PREMA’s role and 

responsibilities in that process. 

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Our fieldwork procedures included testing a random, judgmental sample of 90 

LSCMS commodity shipments from September 2017 through April 2018 to 

determine whether FEMA could substantiate delivery of commodities. 

Supporting documentation requested consisted of required shipping 

documentation for point-to-point shipping such as gate logs, packing slips, 

shipping sheets, bills of lading, and manifests. 

To analyze FEMA’s commodity movements in LSCMS, we performed an 

analytical review of LSCMS data for 20,012 Puerto Rico commodity shipments 

for Hurricanes Maria and Irma. We identified our universe by matching unique 

shipping numbers, purchase orders, and disaster numbers. From the 

universe, we focused our review on the 11,883 shipments, between September 

2017 and April 2018, that contained life-sustaining commodities, specifically 

meals, waters, blankets, cots, tarps, and sheeting. 

LSCMS has data reliability issues, such as missing fields, unknown locations, 

and no source documentation to provide proof of delivery. However, despite the 

known challenges, it remains FEMA’s system of record for all commodity 

shipments. 

To increase the overall data reliability of the LSCMS records, we accounted for 

fields containing inconsistent information, such as those with incorrect or 

mismatched disaster names or numbers. Likewise, we extracted FEMA’s 

shipments to unknown locations. Many of the unknown shipments likely 

contained erroneous transit data that would have skewed overall transit time 

and quantity analyses. We analyzed these separately from shipments that 

never passed through unknown locations. Additionally, we used GPS 

information, where available, to assess the overall reliability of received dates 

and determined the data fields, including those with manual entries, were 

sufficiently reliable for reporting purposes. 

Although we could not substantiate the total amount of commodities received 

by Puerto Rico during our testing because FEMA did not maintain adequate 

documentation, we believe other corroborating evidence mitigates this issue at 

a summary level. This included testimonial evidence from FEMA, Puerto Rico, 

and local government officials along with evidence gathered through a survey of 

78 Puerto Rico municipalities to obtain their perspective on FEMA’s response 

to commodity distribution in the aftermath of Hurricanes Irma and Maria. We 

administered the survey as a structured interview questionnaire via an official 

DHS OIG email account which yielded a response rate of approximately 38 

percent. Additionally, we observed the commodity distribution process and 

discussed FEMA’s performance with Puerto Rico officials, including the Puerto 

Rico National Guard. 

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Overall, while the data is not without errors and FEMA cannot provide proof of 

delivery, we conclude that our adjustments, in conjunction with corroborating 

evidence, make the data sufficiently reliable to support the findings, 

conclusions, and recommendations in this report. 

In response to Hurricanes Irma and Maria, FEMA heavily relied on 

transportation contracts to fulfill transportation needs outside of the 

continental United States. To obtain an understanding of FEMA's 

administration and oversight of these contracts, we met with officials in 

FEMA’s Office of Contracting and Procurement. We also met with 

representatives from Crowley Maritime Corporation. Further, we performed a 

review and conducted testing of the contracts, including their respective 

invoices and supporting documentation. 

We conducted this performance audit between November 2017 and February 

2020 pursuant to the Inspector General Act of 1978, as amended, and 

according to generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, 

appropriate evidence to provide a reasonable basis for our findings and 

conclusions based upon our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

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Appendix B 

FEMA Comments to the Draft Report 

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Appendix C 

Survey Results of Puerto Rico Municipalities 

We conducted a survey of the 78 municipalities of Puerto Rico to assess and 

incorporate their perspectives into our analysis of the overall commodity 

distribution mission. The emailed survey consisted of 45 questions; each 

question was designed and tested to ensure that responses could be used to 

further inform our analysis of this mission. 

Lack of Coordination and Pre-positioned Commodities Hampered Initial 

Distribution Operations 

Survey responses indicated that, in spite of widespread participation in various 

disaster response exercises and the existence of municipality-level commodities 

distribution plans, the responding municipalities were generally not adequately 

prepared to conduct the commodities distribution operation in the days 

immediately following Hurricanes Irma and Maria. The most relevant issues 

addressed in the survey occurred in the areas of planning and coordination 

and commodity pre-positioning. 

The state-level planning document, “Plan de Distribucion de Suministros” 

(Emergency Commodities Distribution Plan), is a flawed, yet comprehensive, 

document that outlines roles, responsibilities, and expectations for 

municipalities and other key stakeholders positioned throughout the 

distribution process. We found that 27 percent of responding municipalities 

claim to have had no familiarity with this document. Furthermore, only 23 

percent of responding municipalities participated in the creation of this critical 

plan. 

In addition to the comprehensive plan just mentioned, most municipalities 

received additional guidance from state and Federal entities on their 

commodities distribution process. We determined that 73 percent of 

responding municipalities received such guidance; however, 20 percent of 

responding municipalities neither received this guidance nor had familiarity 

with the Commodities Distribution Plan. This lack of coordinated guidance 

contributed to lapses in plan performance, further compounding the additional 

responsibilities that would, at least partially, fall on FEMA. 

An additional component of preparedness cited in the survey is the prepositioning, or pre-distribution, of commodities in advance of the Hurricanes of 

2017. Current plans do not call for any commodities to be distributed to 

municipalities in advance of an incident. In accordance with these plans, 90 

percent of respondents reported they did not receive any commodities in 

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preparation for Hurricane Maria. This result, while not surprising, further 

substantiates a lack of pre-positioned items on Puerto Rico. 

In the days immediately following the Hurricanes of 2017, most of the 

municipalities were either without needed commodities, guidance, or 

communication. These shortcomings led to delays in the receipt of life saving 

commodities. However, disaster responders would soon ramp up their efforts 

to aid survivors. 

The Disaster Response Effort Improved Dramatically over the Following 

Weeks, Though Some Problems Persisted 

Initial response efforts were largely unprepared to supply survivors with needed 

commodities. Deficiencies in communication and coordination, coupled with a 

lack of pre-positioned commodities hampered the response following Hurricane 

Maria, yet in the weeks that followed, marked improvements would be made to 

the efficiency and effectiveness of the operation. 

On average, municipalities received their first deliveries of food and water 

about 10 days after Hurricane Maria. The first deliveries of blue tarps, 

generators, and fuel were received after 22, 31, and 27 days, respectively. 

However, only 27 percent of responding municipalities received enough water 

in that first shipment while only 20 percent received enough food. 

Over time the distribution process would become more effective at meeting the 

commodities needs of municipalities. Within the first week, less than 30 

percent of responding municipalities stated they had received enough food to 

sustain survivors; that proportion nearly doubled by the end of week two, and 

reached its peak of 76 percent within 4 weeks. The progress in distribution of 

tarps, generators, and fuel lagged behind — the 50 percent threshold was 

exceeded for tarps and fuel beyond 30 days, while the proportion of responding 

municipalities that received enough generators never exceeded 33 percent (see 

Figure 7). 

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Figure 7. Percent of Municipalities Receiving ‘Enough’ Commodities 

Source: DHS OIG analysis of Puerto Rico Municipality survey responses 

Specifically, the commodities distribution effort became markedly more 

responsive to municipality requests over time. Within the first 2 weeks, half of 

the responding municipalities reported they waited, on average, more than 3 

days for requested commodities to be provided; 38 percent experienced average 

wait times of more than 7 days. However, in weeks three and four, more than 

81 percent of municipalities stated that requested commodities were provided 

within 3 days; more than 40 percent received them within 24 hours. 

Responsiveness improved even further after the first month of operations. 

Figures 8, 9, and 10 illustrate the increasing responsiveness to commodities 

requests from municipalities over time. Within the first 2 weeks, half of the 

responding municipalities experienced wait times of longer than 3 days; that 

proportion shrank to 19 percent after week two. 

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Figure 8. Responsiveness to Requests 

Source: DHS OIG analysis of Puerto Rico Municipality survey responses 

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Despite the marked increase in the amount of commodities received over time, 

municipalities faced issues with the commodities received. To illustrate, 27 

percent of responding municipalities stated that they had “significant 

problems” with the packaging of water. More concerning is the proportion of 

responding municipalities that had significant problems with food; the 

combination of expired or damaged meals, meals with damaged packaging, or 

other issues were a “significant problem” for a majority of municipalities. Only 

40 percent of responding municipalities reported no “significant problems” with 

meals. Figure 11 shows an example of damaged meal packaging. 

Figure 11: Example of damaged meal packaging 

Source: Picture taken by DHS OIG 

Even with the aforementioned issues pertaining to the quality of commodities 

received, the overall satisfaction of municipalities regarding the response 

increased dramatically over time. Only 7 percent of responding municipalities 

stated Federal efforts were effective in meeting the needs of the municipality 

with the first 2 days following Hurricane Maria. This proportion increased to 

81 percent after 2 weeks, and eventually 89 percent indicated Federal efforts 

were effective in meeting their needs. 

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Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Under Secretary, Office of Strategy, Policy, and Plans 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

FEMA Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

Senator Richard Blumenthal 

www.oig.dhs.gov 43 OIG-20-76 
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To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

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OIG Hotline 

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click 

on the red "Hotline" tab. If you cannot access our website, call our hotline at 

(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at: 

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305