Better Oversight and 

Planning are Needed to 

Improve FEMA's 

Transitional Sheltering 

Assistance Program 

February 11, 2021 

OIG-21-20 
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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

February 11, 2021 

MEMORANDUM FOR: Robert Fenton 

Senior Official Performing the Duties of the 

Administrator 

Federal Emergency Management AgencyF

FROM: Joseph V. Cuffari, Ph.D. JOSEPH V Digitally signed by JOSEPH V 

CUFFARI 

Date: 2021.02.10 15:35:02 -05'00' Inspector GeneralF

CUFFARI 

SUBJECT: Better Oversight and Planning Are Needed to Improve 

FEMA’s Transitional Sheltering Assistance Program 

For your action is our final report, Better Oversight and Planning are Needed to 

Improve FEMA’s Transitional Sheltering Assistance Program. We incorporated 

the formal comments provided by your office.F

The report contains two recommendations aimed at improving the Transitional 

Sheltering Assistance program. Your office concurred with both 

recommendations. Based on information provided in your response to the 

draft report, we consider recommendations 1 and 2 open and resolved. Once 

your office has fully implemented the recommendations, please submit a formal 

closeout letter to us within 30 days so that we may close the recommendations. 

The memorandum should be accompanied by evidence of completion of agreedupon corrective actions and of the disposition of any monetary amounts. 

Please send your response or closure request to 

OIGAuditsFollowup@oig.dhs.gov. 

Consistent with our responsibility under the Inspector General Act of 1978, as 

amended, we will provide copies of our report to congressional committees with 

oversight and appropriation responsibility over the Department of Homeland 

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

Please call me with any questions, or your staff may contactF Thomas Kait, 

Acting Assistant Inspector General for Audits, at (202) 981-6000.F

Attachment 

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DHS OIG HIGHLIGHTS 

Better Oversight and Planning Are 

Needed to Improve FEMA’s Transitional

Sheltering Assistance Program 

February 11, 2021 

Why We Did 

This Audit19F 

FEMA is responsible for 

helping state and 

territorial governments 

develop pre-disaster 

plans for mass care, 

emergency assistance, 

transitional sheltering, 

interim housing, and 

human services.20F For the 

2017 disasters, FEMA 

spent about $642 million 

for hotel rooms for 

disaster survivors in the 

TSA program.21F We 

conducted this audit to 

determine to what extent 

FEMA met survivors’ 

transitional sheltering 

needs.2F 

What We 

Recommend23F 

We made two 

recommendations that, 

when implemented, will 

improve FEMA’s 

oversight and predisaster planning of 

transitional sheltering.24F 

For Further Information25F 

Contact our Office of Public Affairs at 

(202) 981-6000, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found26F 

The Federal Emergency Management Agency 

(FEMA) provided hotel rooms to about 90,000 

households27F (nearly 227,000 survivors)28F after the 

2017 California wildfires and Hurricanes Harvey, 

Irma, and Maria. However, FEMA did not oversee 

and manage the Transitional Sheltering Assistance 

(TSA) program to ensure it operated efficiently and 

effectively to meet disaster survivors’ needs.30F 

Specifically, FEMA: 

 did not accurately validate taxes charged for 

hotel rooms 31Fand did not ensure the contractor 

responsible for administering the TSA program 

maintained accurate records to show taxes 

charged were reasonable and allocable;32F 

 paid for unoccupied rooms;3F 

 did not transition survivors from TSA hotels to 

interim or permanent housing timely;34F and 

 did not adequately coordinate with states and 

a territory to prepare initial housing strategies.35F 

The deficiencies occurred because FEMA officials 

did not establish standard operating procedures 

and a dedicated program office with sufficient staff 

to support the TSA program. As a result, FEMA 

paid more than $55.8 million in unverified taxes,37F 

disbursed indeterminate amounts for unoccupied 

rooms,38F and left over 146,000 disaster survivors to 

remain in hotels for more than the39F recommended 

30 days.40F 

FEMA Response41F 

FEMA concurred with both recommendations. 

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Background42F 

In 2017, the Gulf Coast,43F U.S. Virgin Islands,4F and Puerto Rico45F endured major 

hurricanes that made landfall from August through September.46F During 

October 2017, nearly two dozen wildfires burned more than 200,000 acres of 

land in northern California.47F These events resulted in Presidential declarations 

for Hurricanes Harvey in Texas,48F Hurricane Irma in Florida49F and Puerto Rico,50F 

Hurricane Maria in Puerto Rico,51F and the wildfires in California.52F 

The Robert T. Stafford Disaster Relief and Emergency Assistance Act is the 

statutory authority for most Federal disaster response activities, especially for 

the Federal Emergency Management Agency (FEMA) and its programs.53F The 

Response – Federal Interagency Operational Plan (Plan) supports these activities 

and describes how the Federal Government should coordinate efforts in 

response to disasters.54F According to the Plan, FEMA is responsible for helping 

states and other territorial governments develop pre-disaster plans for mass 

care, emergency assistance, transitional sheltering, interim housing, and 

human services.5F Before and during disaster response,56F the Mass Care and 

Emergency Assistance Branch (Mass Care), within FEMA’s Office of Response 

and Recovery, is directly responsible for preparing and managing the 

Transitional Sheltering Assistance (TSA) program.57F 

The TSA program is a form of temporary shelter such as hotel rooms for 

survivors who will be displaced from 5 to 14 days. The program may extend to 

30 days and, in rare cases, can be extended up to 6 months.58F Survivors qualify 

for TSA if they: 

 are registered with FEMA for assistance and pass identity and citizenship 

verification; 

 have a pre-disaster primary residence in the area designated for TSA; 

 are displaced from their pre-disaster residence due to the disaster; 

 have remained in transitional, congregate, or other shelters; and 

 are unable to obtain lodging through another source.59F 

The TSA program is designed to transition survivors from congregate shelters 

to hotels.60F Survivors are then transitioned from hotels and into interim 

housing, if needed, or into a permanent residence.61F Interim housing is a longterm option up to 18 months until a permanent housing option becomes 

available.62F Interim housing includes lodging in manufactured homes63F or FEMA’s 

short-term leasing programs.64F For permanent housing, FEMA provides 

survivors with financial assistance to make repairs to their pre-disaster 

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dwellings65F or enter into leasing agreements.6F (See Figure 1 and Appendix C for 

more details on housing programs and types of sheltering.) 

Figure 1. Types of Temporary Sheltering and Housing Programs 

Source: Office of Inspector General (OIG) analysis of response – Federal Interagency 

Operational Plan (Aug. 2016)67F 

Since 2005, Corporate Lodging Consultants (CLC) has administered the TSA 

program and pays hotels for eligible stays.68F FEMA awarded CLC its latest 

contract in May 2016.69F FEMA’s responsibilities for the TSA program include 

determining disaster survivors’ eligibility for the TSA program,70F notifying 

applicants of their eligibility status,71 and sending eligibility information to CLC.72F 

Subsequently, CLC adds disaster survivors’ information to its Emergency 

Lodging Assistance system,73F which allows eligible survivors to check into 

participating hotels anywhere in the Nation.74 For the 2017 disasters, FEMA 

provided hotel rooms to about 90,000 households75F (nearly 227,000 survivors)76F 

and spent approximately $642 million7F in lodging costs for over 5 million nights 

in TSA-participating hotels, as of October 2018.78F 

We conducted this audit to determine to what extent FEMA met survivors’ 

transitional sheltering needs. This is a follow-up to prior related audits of the 

FEMA-TSA contract and program.0F 

1

1 Management Alert – FEMA Did Not Safeguard Disaster Survivors’ Sensitive Personally 

Identifiable Information, OIG-19-32, Mar. 15, 2019; Additional Controls Needed to Better 

Manage FEMA’s Transitional Sheltering Assistance Program, OIG-19-37, Mar. 29, 2019; and 

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Results of Audit81F 

FEMA Did Not Sufficiently Oversee and Manage the TSA 

Program82F 

FEMA did not sufficiently oversee and manage the TSA program to ensure it 

operated efficiently and effectively to meet disaster survivors’ needs.83F 

Specifically, FEMA officials did not validate taxes charged for hotel rooms84F and 

did not ensure CLC maintained accurate records.85F FEMA also paid for 

unoccupied rooms86F and did not ensure timely transition of survivors from hotels 

to interim or permanent housing.87F These deficiencies occurred because FEMA 

officials did not establish a dedicated TSA program office with the staff needed 

to develop standard operating procedures89F and coordinate with states to prepare 

disaster-housing strategies in advance of disasters.90F 

FEMA Did Not Verify Accuracy of Hotel Taxes and Records91F 

According to Standards for Internal Control in the Federal Government, FEMA 

must ensure efficient operations that minimize waste of resources. Consistent 

with Federal Acquisition Regulations, contractors are responsible for 

appropriately accounting for costs by maintaining accurate records to ensure 

costs are reasonable and allocable.93F 

Despite these requirements, FEMA officials did not accurately validate taxes 

charged for hotel rooms under the TSA program94 and did not ensure CLC 

maintained accurate records to confirm taxes charged were reasonable and 

accurate.95F Specifically, CLC used its Emergency Lodging Assistance system to 

receive hotel payment requests, in the form of electronic invoices, but did not 

require hotels to provide detailed itemization of room rates, taxes, and fees.96F As 

permitted by the TSA contract,2 CLC sent FEMA invoice reports that lumped all 

hotel charges together in one total that included room costs, taxes, and fees.97F 

FEMA’s review process to identify erroneous charges on the invoice reports98F 

consisted of only two steps: 

1) FEMA verified whether the dates billed for the hotel nights were 

within the survivor’s eligibility period; and 

FEMA Did Not Properly Award and Oversee the Transitional Sheltering Assistance Contract, OIG20-58, Aug. 5, 2020. 

2 FEMA Transitional Sheltering Assistance Contract with CLC (Order Number: HSFE80-16-0211; 

May 13, 2016). 

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2) FEMA verified whether the total nightly amounts billed did not exceed 

the FEMA approved lodging rate for the corresponding disasters.9F 

This two-step process could not fully determine if TSA program costs were 

allowable and did not permit FEMA to ensure costs were accurate, reasonable, 

and allocable as required by Federal Acquisition Regulations. The review 

process limited FEMA’s reimbursements to ceilings based on the approved 

lodging rates. FEMA’s review process also did not align with the TSA contract 

stating FEMA would cover the lodging taxes and fees in addition to applicable 

lodging rates. Therefore, FEMA should consider all those components 

separately when reviewing hotel charges. As such, the process adversely 

affected hotels’ ability to accurately charge room taxes for survivors sheltered 

under the TSA program.103F 

Based on our review of lodging data reported to CLC by hotels, we requested an 

itemization of the underlying hotel charges including taxes. In February 2019, 

CLC provided OIG with data for 4,120105F TSA-participating hotels that reported 

taxes charged to CLC for rooms supplied to survivors of the 2017 disasters. 

These hotels charged about $471 million107F for about 3.9 million hotel room 

nights, of which $55.8 million was for taxes109F. 

We reviewed the tax data provided by CLC and identified numerous instances 

in which the amounts listed in the tax lines did not align with the 

corresponding city’s tax rate.10F For example, the New York, NY tax rate is 14.75 

percent.1F However, according to CLC’s data, the taxes charged by hotels in New 

York city ranged from 1 percent to as high as 22 percent.12F Similarly, the CLC 

data showed tax amounts charged by hotels in Orlando, FL; Houston, TX; and 

Santa Rosa, CA, that also did not align with the corresponding city’s tax rates.13F 

We reviewed a judgmental sample of 2,964 hotel bills14F of which only 744 (about 

25 percent) matched the corresponding city’s tax rate.15F (See Table 1 and 

Appendix D for details.) 

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Table 1. Percent of Bills with Questionable Tax Charges 

Source: OIG analysis of CLC data 6F 

Without reviewing the itemized costs, FEMA has no assurance the hotel costs 

charged were accurate or allowable. We therefore question the accuracy of the 

$55.8 million FEMA paid in taxes to hotels during the 2017 disasters.18F 

FEMA Paid for Unoccupied Hotel Rooms19F 

To verify applicant eligibility for the TSA program,3 FEMA requires hotel 

personnel to ensure disaster survivors complete TSA Terms and Conditions 

forms120F with survivor information, FEMA registration number, check-in date, 

signature, and date acknowledging acceptance of TSA program requirements.21F 

As indicated in our March 2019 report12F, FEMA paid hotels participating in the 

TSA program for an indeterminate number of unoccupied rooms.124F For example, 

FEMA identified five instances of disaster survivors departing the TSA program 

without notifying FEMA or hotel personnel.125F The hotels continued to bill FEMA 

3 As required per FEMA’s Transitional Sheltering Assistance Playbook, Aug. 2017. 

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for the rooms even though the disaster survivors had vacated the hotels.126F In 

these five instances, FEMA collectively paid TSA hotels about $4,700 for 41 

nights of unoccupied rooms.127F 

Although FEMA required disaster survivors to sign and date TSA Terms and 

Conditions forms at check-in128F, FEMA did not require survivors to document or 

notify FEMA or hotel personnel upon checkout. Additionally, we determined 

that FEMA did not provide information on its TSA Terms and Conditions form 

for reporting allegations of fraud, waste, and abuse130F.4 As a result, FEMA is 

uncertain about the true magnitude of unnecessary payments for unoccupied 

hotel rooms31F from August 27, 2017, to September 14, 2018132F. Further, in 

response to our March 2019 interim report, FEMA has updated its Terms and 

Conditions forms, starting with Hurricane Florence in 2018, to include a 

hotline number for reporting fraud.5 

FEMA Did Not Ensure Survivors’ Timely Transition from TSA Hotels to 

Interim or Permanent Housing134F 

The DHS Response Federal Interagency Operational Plan6 135F and FEMA’s National

Disaster Housing Strategy7 136F direct FEMA to work with states to create initial

housing strategies in preparation for disasters. To do so, FEMA will work with 

state entities to conduct joint planning to address housing needs, engage 

appropriate stakeholders, identify a range of options, describe how those 

options would be implemented, and identify the necessary resources138F. Once 

disasters occur, FEMA is required to adapt the initial housing strategies to 

address actual incidents.139F An initial housing strategy helps ensure FEMA is 

better prepared and able to transition survivors quickly from congregate and 

transitional shelters to interim140F or permanent housing41F. 

However, FEMA did not transition survivors from TSA hotels timely following 

the 2017 disasters.142F FEMA officials acknowledged143F that the DHS Response 

Federal Interagency Operational Plan instructs the component to work with the 

states prior to a disaster to develop a temporary housing strategy14F. However, for 

the 2017 disasters, FEMA did not dedicate staff to support this effort,145F and 

many states did not have temporary housing strategies in place. Further, 

FEMA also stated that although some states used housing strategies in 2018, 

FEMA did not have a standardized national approach for the 2017 disasters. 

Consequently, FEMA allowed TSA program extensions beyond the 

4 FEMA TSA Terms and Conditions Form – DR-4339-PR (Updated Nov. 1, 2017). 

5 FEMA TSA Terms and Conditions Form – DR-4393-NC (Updated Sept. 20, 2018). 

6 DHS Response Federal Interagency Operational Plan (Second Edition; Aug. 2016). 

7 FEMA’s National Disaster Housing Strategy (Jan. 16, 2009). 

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15F 156F 157F 158F 159FQQQQ1

160F 187F 18F 189F

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recommended 30-day stay for the 2017 disaster survivors147F without transitioning 

them to interim or permanent housing as required148F. To illustrate, FEMA 

extended hotel stays up to 4 months for all survivors participating in the TSA 

Program from the four disasters149F and did not transition survivors as required. 

Further, based on our analysis of the various FEMA Transitional Sheltering 

Assistance Extension Request memos, for disaster survivors of Hurricanes Irma, 

Maria, and Harvey, FEMA waived the recommended 6-month maximum 

timeframe for participation and extended some survivors’ hotel stays to almost 

a year.51F 

Because FEMA did not have a strategy to transition survivors to interim or 

permanent housing,152F more than 26,700 disaster survivors remained in hotels 

past the TSA Program’s recommended 6-month timeframe. (See Table 2 

column A for TSA disaster declaration dates and column B for disaster 

survivors participating during the 2017 disasters.) 

Table 2. TSA Activation Timelines and Populations after the 2017 

Hurricanes and Wildfires154F 

Disaster and 

Location 

Disaster 

Declaration 

Date 

(A) 

Survivors 

in Hotels 

after 3O 

Days

(B) 

Survivors 

in Hotels 

after 6 

Months 

(C) 

End Date 

for TSA 

Programs

(D) 

Survivors in 

Hotels at 

End of TSA 

Programs

(E) 

Hurricane Harvey 

in Texas61F 

8/25/2017162F 92,278163 20,919164F 6/30/2018165F 1,184 

Hurricane Irma in 

Puerto Rico167F 

9/10/2017168F 

17,000169F* 5,814*170F 9/13/201871F 2,082172F 

Hurricane Maria 

in Puerto Rico173F 

9/20/2017174F 

Hurricane Irma in 

Florida175F 

9/10/2017 36,179 -178F 3/10/2018179F 2,439180F 

Wildfires in 

California81F 

10/10/2017182F 915183F -184F 3/15/2018185F 2186F 

TOTAL 146,372 26,733 5,707 

Source: DHS OIG analysis of FEMA data91F 

* Combined registrant count for Hurricanes Irma and Maria 

Further, thousands of survivors were still sheltering in TSA-participating hotels 

when FEMA ended the TSA programs and stopped providing these transitional 

sheltering benefits. (See Table 2, columns D and E for details)192. FEMA was 

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unable to confirm193F whether the more than 5,700 survivors in hotels 

successfully transitioned to interim or permanent housing.195F 

FEMA Did Not Have Standard Operating Procedures and a Dedicated 

Program Office for the TSA Program196F 

According to the Standards for Internal Control in the Federal Government,8 1F 

management should establish an organizational structure, assign 

responsibility, and delegate authority to achieve the entity’s objectives.197F This 

entails management providing an understanding of the overall responsibilities, 

assigning the responsibilities to discrete business units to enable the 

organization to operate in an efficient and effective manner, and implementing 

control activities through policies and procedures.198F 

Deficiencies in the TSA program19F were due to FEMA officials not implementing 

effective internal controls20F. Specifically, FEMA did not develop and implement 

standard operating procedures to carry out processes and activities of the TSA 

program201F. Additionally, FEMA did not establish a dedicated program office with 

staff to oversee and manage the TSA program. FEMA assigned a single 

headquarters official203F as the TSA program manager during the 2017 disasters, 

but the role was secondary to the official’s primary duties. FEMA also assigned 

field personnel in the regions to oversee disaster activities of their TSA 

program, but the program tasks were either secondary or tertiary duties.205F 

According to FEMA management, the component plans to create a dedicated 

TSA program office.206F However, as of May 2020, FEMA’s Office of Response and 

Recovery had not yet formally approved the proposed TSA business unit 

concept or assigned full-time employees to manage the TSA program.207F Without 

a dedicated TSA program office to improve overall program oversight and 

management, develop standard operating procedures,209F and work with states to 

develop housing strategies prior to disasters210F, FEMA risks not meeting disaster 

survivors’ needs in future catastrophic events.21F 

Recommendations12F 

Recommendation 1: We recommend FEMA’s Office of Response and Recovery 

direct the Mass Care and Emergency Assistance Branch to establish a business 

unit, assign responsibility, and delegate authority to ensure the effective and 

efficient implementation, oversight, and management of the TSA program.214F 

8 Standards for Internal Control in the Federal Government, GAO-14-704G, Sept. 2014. 

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Recommendation 2: We recommend FEMA’s Office of Response and Recovery 

direct the Mass Care and Emergency Assistance Branch to develop, document, 

and implement standard operating procedures for the TSA Program specifically 

designed and implemented to ensure: 

 CLC collects and maintains detailed cost data and FEMA verifies that 

costs and taxes are reasonable, allocable, and accurate; 

 FEMA does not pay for unoccupied hotel rooms and consistently requires 

disaster survivors to personally sign and date the TSA Terms and 

Conditions form during the hotel checkout process; 

 FEMA and CLC transition survivors from hotels to interim or permanent 

housing within the TSA program’s 6-month timeframe;216F and 

 FEMA works with states and territories to develop initial temporary 

sheltering and interim housing strategies before disasters occur, as 

required by the Response Federal Interagency Operational Plan, so FEMA 

best meets the needs of disaster survivors going forward217F. 

FEMA Management Comments and OIG Analysis 218F 

FEMA concurred with both recommendations. We included a copy of the 

Management Comments in their entirety in Appendix B. We also received 

technical comments to the draft report and revised the report as appropriate. 

A summary of FEMA’s responses and our analysis follows. 

FEMA Response to Recommendation 1: Concur. According to FEMA, the 

Individual Assistance Division established a dedicated TSA unit under the 

Mass Care, Voluntary Agency Coordination and Community Services Branch to 

oversee the implementation and management of the TSA program and noncongregate sheltering efforts in response to future events. Currently, there is 

one full-time dedicated staff member with three additional detailees to provide 

support. Mass Care is preparing to on-board additional staff to support this 

unit. 

OIG’s Analysis: We are pleased FEMA is standing up the TSA unit. This 

recommendation will remain resolved and open until FEMA provides 

documentation showing that the additional staff are on-board, assigned 

responsibility, and delegated authority to ensure the effective and efficient 

implementation, oversight, and management of the TSA program. 

FEMA’s Response to Recommendation 2: Concur. According to FEMA, the 

TSA unit is actively developing resources, tools, and procedures to support a 

more effective TSA program. 

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OIG’s Analysis: Recommendation 2 is resolved and open until FEMA provides 

supporting documentation, including final approved copies of the Transitional 

Sheltering Assistance Policy (FEMA Policy #104-009-20), the TSA Tool Kit, a 

sample of the new Terms and Conditions documents, and the Quality 

Assurance Surveillance Plan signed by both FEMA and the contractor. 

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Appendix A 

Objective, Scope, and Methodology20F 

The Department of Homeland Security Office of Inspector General was 

established by the Homeland Security Act of 2002 (Public Law 107−296)21F by 

amendment of the Inspector General Act of 1978.2F This audit addresses the 

extent to which FEMA met disaster survivors' transitional sheltering needs 

after the California wildfires and Hurricanes Harvey, Irma, and Maria in 2017.23F 

To accomplish our objective, we reviewed Federal guidance, relevant 

documents, and applicable Federal laws. In addition, we conducted visits to 

Texas, Florida, and Puerto Rico to gather documentation25F and visually inspect 

hotels in the TSA program. We judgmentally selected locations based on the 

duration of participation and expenditures in the FEMA TSA program after the 

2017 disasters. We interviewed Federal and state officials, officials from 

Florida, Texas, and Puerto Rico’s departments of emergency management,27F and 

more than 50 hotel managers from TSA-participating hotels in the locations.28 

We telephonically interviewed Federal29F and state officials in California assigned 

to the same roles.230F 

At the national level, we interviewed officials from FEMA231F and the Department of 

Housing and Urban Development to understand the process for planning, 

coordinating, and providing sheltering and interim housing services after major 

disasters.32F Similarly, we interviewed officials from CLC, the contractor FEMA 

selected to administer the TSA program, to understand their roles and 

responsibilities in implementing the program.23F We also interviewed a 

representative of the National Low Income Housing Coalition to gather 

information about experiences with disasters and observations regarding 

transitional sheltering and interim housing in response to the 2017 hurricanes 

and California wildfires. 

We performed extensive analyses using TSA records FEMA provided from 

August 2017 to October 2018.235F The data contained records for eligible 

applicants participating in the TSA programs in California, Florida, Puerto 

Rico, and Texas and billing and invoices from TSA-participating hotels that 

served eligible disaster survivors from these locations.236F To assess the reliability 

of the data, we interviewed knowledgeable FEMA officials237F about their process 

for ensuring accurate applicant information is entered into CLC’s Emergency 

Lodging Assistance system,238F and reviewed a sample of the submissions to 

identify missing or invalid data elements.239 We found the data to be sufficiently 

reliable for the purposes of our reporting objective.240F 

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We evaluated FEMA’s actions against Federal internal control standards for 

oversight and documentation. We also evaluated FEMA’s efforts to develop predisaster strategies for sheltering and interim housing with Florida, Puerto Rico, 

and Texas against FEMA’s responsibilities outlined in the Response Federal 

Interagency Operational Plan.42F 

We conducted this performance audit between June 2018 and September 2019 

pursuant to the Inspector General Act of 1978, as amended,243F and according to 

generally accepted government auditing standards.24F 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.245F 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 Report247F 

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Appendix C 

Type of Sheltering and Interim Housing Options Provided to 

Survivors during the 2017 Responses9 249F 

Sheltering Options250F 

Congregate Sheltering251F 

Local and state territorial governments establish initial shelter operations.52F The 

operations are often in public buildings, including coliseums, stadiums, and 

sports arenas,253F to provide a safe and secure environment for survivors.254F This 

option is a short-term solution ordinarily open for 60 days.256F Wrap-around 

services include childcare; feeding; medical and mental health; access and 

functional needs support services; and support to children, household pets, 

and service animals.257F 

Transitional Sheltering Assistance (TSA)258F 

FEMA may provide TSA services to applicants who are unable to return to their 

pre-disaster primary residence because the home is either uninhabitable or 

inaccessible. The goal of this program is to reduce the number of disaster 

survivors in congregate shelters by transitioning survivors into short-term 

accommodations, typically hotels. The program is usually intended to end 

after 30 days, but may be extended up to 6 months.261F 

Sheltering and Temporary Essential Power62F 

FEMA used Sheltering and Temporary Essential Power to assist state, 

territorial, and tribal governments in performing work and services essential to 

saving lives, protecting public health and safety, and protecting property to 

enable survivors to shelter at home.263F FEMA determined that this program could 

not be implemented as intended and discontinued use of the program in 2019.264F 

Recreational Vehicles 

FEMA leases recreational vehicles from vendors and provides them to disaster 

survivors. Survivors may use the vehicles for up to 6 months during the 

sheltering phase.26F 

9 Catastrophic Housing Annex to the 2012 Federal Interagency Operations Plan – Hurricane (Aug. 

2012). 

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Interim Housing Options267F 

Direct Lease268F 

FEMA leases property from landlords269F and then provides housing units to 

survivors when rental resources are unavailable in specific areas.270F 

Manufactured Housing Units271F 

Manufactured homes or other readily fabricated dwellings owned by FEMA72F are 

provided to eligible applicants for use as interim housing for a limited time.273F 

Multi-family Lease and Repair274F 

FEMA repairs existing multi-family housing units, such as apartments, to use 

as interim housing275F for eligible applicants who are unable to use rental 

assistance.276F 

Rental Assistance27F 

FEMA provides financial assistance to disaster survivors to rent interim 

housing units. The amount of rental assistance is based on the Department of 

Housing and Urban Development’s Fair Market Rents in the area where the 

rental resource is located.279F2F 

10 280 

10 The Department of Housing and Urban Development calculates Fair Market Rents including 

the cost of housing plus the cost of utilities to determine payment standard amounts for 

several of its housing programs. 

www.oig.dhs.gov 18 OIG-21-20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Detailed Sample of Hotels Participating in the TSA Program by 

City and Analysis of Hotel Tax Rates 

City, State New York 

City, NY * 

Orlando, 

FL 

Houston, 

TX 

Santa Rosa, 

CA 

Total # of Hotels 25281F 52 347 8 

Total # of Nights 35,834285F 114,006286F 878,832287F 6,43128F 

Total # of Bills 152289F 504290F 2,229291F 7992F 

# of Bills Over 

Location Tax Rate 34293F 268 586 3296F 

% of Bills Over 

Location Tax Rate 22%297F 53%298F 26%29F 4% 

# of Bills At 

Location Tax Rate 80301F 40 57603F 48304F 

% of Bills At 

Location Tax Rate 53%305F 8%306F 26%307F 61%308F 

# of Bills Under 

Location Tax Rate 38309F 196310F 1,067 28312 

% of Bills Under 

Location Tax Rate 25%13F 39%314F 48%315F 35%316F 

Location Tax Rates 14.75%** 317 12.50% 17.00% 14.00%** 320F 

Highest Over 

Taxed Rate 20.78% 30.01%32F 30.10%23F 30.00%324F 

Lowest Under 

Taxed Rate 0%325F 0.51%326F 0.03%327F 11.40%328F 

Source: OIG analysis of CLC-provided data329F 

* New York, NY data includes all five boroughs (New York, Staten Island, Queens, Brooklyn, 

and the Bronx) and accounting for New York City and New York State Excise Taxes. 

** Base lodging tax rate, but varying excise taxes also applicable and considered in our 

calculations. 

www.oig.dhs.gov 19 OIG-21-20 
 

 

 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Office of Audits Major Contributors to This Report31F 

Yesi Starinsky, Director32F 

Andrew Smith, Audit Manager3F 

James Lloyd, Auditor-in-Charge34F 

Lauren Bullis, Auditor35F 

Stephanie Holloway, Auditor36F 

Corinn King, Auditor37F 

Yvette Mabry, Auditor38F 

Jessica Makowski, Program Analyst 

James Townsend, Program Analyst340F 

Deborah Mouton-Miller, Communications Analyst;341F and 

Barry Bruner, Auditor, Independent Report Referencer342F 

www.oig.dhs.gov 20 OIG-21-20 
 

 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Report Distribution34F 

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 

DHS Component Liaison 

Office of Management and Budget 345F 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 21 OIG-21-20 
Additional Information and Copies 

To view this and any of our other reports, please visit our website at: 

www.oig.dhs.gov. 

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

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

Follow us on Twitter at: @dhsoig. 

OIG Hotline 

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

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

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

Department of Homeland Security 

Office of Inspector General, Mail Stop 0305 

Attention: Hotline 

245 Murray Drive, SW 

Washington, DC 20528-0305