FEMA Should Recover 

$25.4 Million in Grant 

Funds Awarded to 

Louisville, Mississippi, for 

an April 2014 Disaster 

September 29, 2016 

OIG-16-143-D 
 

 

 

 

 

 

 

DHS OIG HIGHLIGHTS 

FEMA Should Recover $25.4 Million in
 

Grant Funds Awarded to
 

Louisville, Mississippi, for an April 2014 Disaster 

September 29, 2016 

Why We Did 

This Audit 

The City of Louisville (City), 

Mississippi, received a 

Federal Emergency 

Management Agency (FEMA) 

grant award of $61.7 million 

for damages resulting from 

an April 2014 disaster. We 

had concerns about how 

effectively the City complied 

with the Public Assistance 

Alternative Procedures Pilot 

Program (PAAP program) 

authorized by the Sandy 

Recovery Improvement Act of 

2013. 

What We 

Recommend 

FEMA should disallow 

$25.4 million of ineligible 

costs ($23.9 million for 

improper contract costs and 

$1.5 million of duplicate 

benefits). FEMA should also 

direct Mississippi, as its 

grantee, to provide 

additional technical 

assistance and monitoring 

to the City. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-IG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

The City generally followed Federal regulations 

and FEMA guidelines when accounting for FEMA 

funds; however, the City did not follow Federal 

procurement standards in awarding 12 contracts 

totaling $23.9 million. Specifically, for 11 

contracts totaling $23.3 million, the City did not 

take the required affirmative steps to ensure the 

use of disadvantaged firms when possible; and, 

for a $600,000 project management contract, the 

City did not provide full and open competition, 

use cost as a basis for selection, or perform an 

adequate cost or price analysis. As a result, 

FEMA has no assurance that disadvantaged firms 

had sufficient opportunities to bid on federally 

funded work or that the City always paid 

reasonable prices for services. 

Finally, although the City advised FEMA that it 

had received funding from other Federal sources, 

FEMA did not reduce eligible costs by 

$1.5 million, which resulted in a duplication of 

benefits. 

These issues generally occurred because the 

grantee (Mississippi) did not ensure that the City 

understood and complied with Federal 

procurement requirements. In addition, FEMA 

did not follow established procedures for 

obligating Federal funds. 

FEMA Response 

FEMA officials agreed with our findings and 

recommendations. Appendix C includes FEMA’s 

written response in its entirety. 

www.oig.dhs.gov OIG-16-143-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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


September 29, 2016 


MEMORANDUM FOR: Gracia Szczech 

Regional Administrator, Region IV 

Federal Emergency Management Agency 

~1t1·~ 

FROM: Thomas M. Salmon 

Assistant Inspector General 

Office of Emergency Management Oversight 

SUBJECT: FEMA Should Recover $25.4 Million in Grant Funds 

Awarded to Louisville, Mississippi, for an April 2014 

Disaster ' 

Audit Report Number OIG-16-143-D 

We audited Federal Emergency Management Agency (FEMA) Public Assistance 

grant funds awarded to the City of Louisville (City), Mississippi. As of 

October 13, 2015, the City had received a Public Assistance award of 

$61.7 million from the Mississippi Emergency Management Agency 

(Mississippi), a FEMA grantee, for damages resulting from severe storms, 

tornadoes, and flooding that occurred in April 2014. The award provided 

75 percent funding for debris removal, emergency protective measures, and 

permanent work. We audited Project 104, Destroyed Plywood Facility, totaling 

$57.3 million ($47.3 million net of insurance), or about 93 percent of the 

$61.7 million award. As of October 13, 2015, the cutoff date of our audit, the 

City had submitted a cost claim of $19.6 million to Mississippi for 

reimbursement. Therefore, the City had not completed work on all projects and 

had not submitted a final claim to Mississippi for all project expenditures. 

Table 1 shows the gross and net awards before and after insurance and other 

reductions for the total award and for the project we audited. 

Table 1: Gross and Net Award Amounts 

Gross Award 

Amount 

Insurance 

Reduction 

Other 

Reduction 

Net Award 

Amount 

All Projects $61,711,649 $10,010,000 $200 1 $51,701,449 

Audit Scope $57,309,126 $10,010,000 $0 $47,299,126 

Source: FEMA project worksheets 

In Project #09 "Vehicle Replacement," the City of Louisville received $200 salvage value from 

the disposal of one of its vehicles. 

www.oig.dhs.gov OIG-16-143-D 

i 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

This report is the second and final report on our audit of Public Assistance 

grant funds awarded to the City. In August 2016, we issued a management 

advisory report (Audit Report OIG-16-119-D) recommending that FEMA 

disallow $47.3 million from Project 104 as ineligible and unauthorized or 

conduct an environmental and historic preservation review and approve the 

City’s new scope of work to redesign a new plywood facility and 

acquire/replace/repair 11 additional facilities. FEMA officials agreed with our 

finding and recommendation and stated they would conduct an environmental 

and historic preservation review and approve the City’s new scope of work. 

Background 

On April 28, 2014, a treacherous EF-4 tornado tore a path through the City of 

Louisville, Mississippi, killing 10 people.2 The powerful storm was measured at 

34 miles long, up to 3⁄4 miles wide with wind speeds up to 185 mph. The City 

suffered catastrophic damages to residential neighborhoods, infrastructure, 

businesses, and other public facilities. 

From the 1960s until 2009, Georgia Pacific operated a plywood facility in the 

City. Upon closure of the Georgia Pacific facility, the City purchased the 

property, including the main plywood factory building and all of the supporting 

exterior facilities. On April 29, 2013, the City leased the facility to a for-profit 

entity. The lease places the responsibility for facility repairs on the City. 

The tornado destroyed the City-owned plywood facility, which was weeks away 

from opening. The City expected the plywood facility to provide over 400 new 

jobs to the community; therefore, the economic impact of losing it could have 

been devastating. On April 30, 2014, the President issued a major disaster 

declaration for certain areas in Mississippi for damages resulting from severe 

storms, tornadoes, and flooding during the period of April 28, 2014, and 

continuing. 

2 The Enhanced Fujita (EF) Scale is a measurement system for rating the intensity of tornadoes 

by type and severity after their impact. The EF Scale ranges from F0 (light) to F5 (incredible); 

an F4 has devastating winds ranging from 166 to 200 miles per hour. 

www.oig.dhs.gov 2 

OIG-16-143-D 
 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1: City of Louisville, Mississippi, Plywood Facility 

Source: City of Louisville, Mississippi 

Results of Audit 

The City generally followed Federal regulations and FEMA guidelines when 

accounting for FEMA funds; however, the City did not follow Federal 

procurement standards in awarding 12 contracts totaling $23.9 million related 

to the new plywood facility. Specifically, for 11 contracts totaling $23.3 million, 

the City did not take the required affirmative steps to ensure the use of 

disadvantaged firms, such as small and minority firms, when possible; and, for 

a $600,000 project management contract, the City did not provide full and 

open competition, use cost as a basis for selection, or perform an adequate cost 

or price analysis. As a result, FEMA has no assurance that disadvantaged 

firms had sufficient opportunities to bid on federally funded work or that the 

City always paid reasonable prices for services. 

Finally, even though the City advised FEMA that it had received funding from 

other Federal sources, FEMA did not reduce otherwise eligible costs by 

$1.5 million, which resulted in a potential duplication of benefits. 

These issues occurred primarily because the grantee (Mississippi) did not 

ensure that the City understood and complied with Federal procurement 

requirements, and FEMA did not follow established procedures for obligating 

www.oig.dhs.gov 3 

OIG-16-143-D 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Federal funds. Mississippi is responsible for ensuring that its subgrantee (the 

City) is aware of and complies with Federal procurement requirements, as well 

as for providing technical assistance and monitoring grant activities. 

Therefore, FEMA should — 

•	 disallow $23.9 million of ineligible contract costs that the City did not 

procure in accordance with Federal requirements, 

•	 disallow $1.5 million of ineligible duplicate benefits for which the City 

received funding from another source to cover eligible costs, and 

•	 direct Mississippi to provide additional technical assistance and 

monitoring to the City to correct the deficiencies we identified in this 

report and to ensure compliance with grant requirements. 

Finding A: Contracting Procedures 

The City did not follow Federal procurement standards in awarding 

12 contracts totaling $23,943,436 related to the new plywood facility. 

Specifically, for 11 contracts totaling $23,343,436, the City did not take the 

required affirmative steps to ensure the use of disadvantaged firms, such as 

small and minority firms, when possible; and, for a $600,000 project 

management contract, the City did not provide full and open competition, use 

cost as a basis for selection, or perform an adequate cost or price analysis. 

Federal procurement standards at 44 Code of Federal Regulations (CFR) 13.36 

required the City, among other things, to — 

1. take all necessary affirmative steps to assure the use of small and 

minority firms, women’s business enterprises, and labor surplus area 

firms when possible (44 CFR 13.36(e)(1)); 

2. conduct all procurement transactions in a manner providing full and 

open competition. Subgrantees may use noncompetitive procurement 

under certain circumstances, one of which is when the public exigency or 

emergency will not permit a delay resulting from competitive solicitation 

(44 CFR 13.36(c)(1) and 44 CFR 13.36(d)(4)(i)(B)); 

3. procure architectural and engineering (A/E) professional services using a 

method where price is not used as a selection factor but competitors' 

qualifications, subject to negotiation of fair and reasonable 

compensation. However, a subgrantee cannot use this method to 

www.oig.dhs.gov	 4 

OIG-16-143-D 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

purchase other types of services from A/E firms (44 CFR 13.36(d)(3)(v)); 

and 

4. perform a cost or price analysis in connection with every procurement 

action, including contract modifications, to determine the reasonableness 

of the proposed contract price (44 CFR 13.36(f)(1)). 

FEMA may grant exceptions to Federal administrative grant requirements — 

which include Federal procurement standards — on a case-by-case basis 

(44 CFR 13.6(c)). Table 1 summarizes the 12 contracts the City awarded and 

the associated $23,943,436 that we question as ineligible. 

Table 2. Contracts Noncompliant with Procurement Standards 

Scope of Work 

Award 

Amount 

1 Architect & Engineering Services $ 3,192,973 

2 Construction Manager 2,514,863 

3 Construction - Foundation 2,048,000 

4 Construction – Demolition 866,117 

5 Construction - Hog & Glue Room, Lathe 1,489,000 

6 Construction - Metal Building 7,474,000 

7 Construction - Site and Utilities 2,742,594 

8 Construction - Regenerative Thermal Oxidizer Relocation 332,895 

9 Construction - Electrical Ducts & Equipment Pad 752,000 

10 Construction - Augured Pressured Grouted Piles 655,994 

11 Construction - Fire Suppression 1,275,000 

12 Professional Project Management Services 600,000 

Total Amounts Awarded and Questioned $23,943,436 

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

Disadvantaged Firms 

The City did not take all the required affirmative steps in awarding 

11 contracts for disaster work valued at $23,343,436. Therefore, FEMA has no 

assurance that disadvantaged firms received sufficient opportunities to bid on 

federally funded work, as Congress intended. The required steps listed at 

44 CFR 13.36(e)(2)(v) include using the services and assistance, as appropriate, 

of organizations such as the Small Business Administration and the 

Department of Commerce’s Minority Business Development Agency in the 

solicitation and use of these firms. The City awarded only one of the contracts 

www.oig.dhs.gov 5 

OIG-16-143-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

we reviewed to a disadvantaged firm. City officials said that they were not 

aware of this requirement and had relied on their A/E firm to award contracts 

properly. However, after we informed City officials of this Federal requirement, 

they registered with the Mississippi Development Authority to ensure the City 

solicited disadvantaged firms for future contracts. 

Full and Open Competition 

The City did not provide full and open competition when awarding a contract 

for professional project management services valued at $600,000. Full and 

open competition increases the probability of reasonable pricing from the most 

qualified contractors and helps discourage and prevent favoritism, collusion, 

fraud, waste, and mismanagement of Federal funds. 

City officials were not aware of their noncompliance with Federal procurement 

regulations. The City considered proposals that multiple project management 

firms delivered to City Hall and believed these efforts were adequate. The City 

officials thought they procured these services properly because the State of 

Mississippi purchasing laws do not require public solicitations for professional 

services contracts. However, the City is not a State entity and, therefore, must 

at minimum comply with Federal procurement standards at 44 CFR 13.36(b) 

through (i). As previously stated, 44 CFR 13.36(c)(1) and (d)(4)(i)(B) require full 

and open competition unless a public exigency or emergency will not permit a 

delay. However, we found no evidence that a public exigency or emergency 

existed to justify the lack of full and open competition for the professional 

project management services contract. 

Basis for Contract Award 

Although the work was not A/E type work, the City improperly used a 

qualifications-based contracting method that did not consider price to select a 

firm to perform project management services. City officials said they selected 

the contractor based on its experience, qualifications, and recommendations 

from previous work. City officials said that they did not obtain bids based on 

price because State guidelines do not require price to be a factor in awarding 

contracts for professional services. However, Federal procurement standards 

prohibit using qualifications-based procurements, where price is not an 

evaluation factor, for non-A/E professional services. 

www.oig.dhs.gov 6 

OIG-16-143-D 
 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Cost or Price Analysis 

The City also did not perform an adequate cost or price analysis in awarding a 

project management services contract. The absence of a cost or price analysis 

increases the likelihood of unreasonable contract costs and misinterpretations 

or errors in pricing. City officials believed they performed an adequate cost or 

price analysis because one of the factors they considered in the proposals was 

the hourly rates of each firm. Although the City considered the hourly rates, it 

did not take into account other elements, such as the number of hours to 

perform the work, which can also affect overall contract cost. The City may not 

have chosen the most economical approach or received the best price because 

the selected firm could have charged more hours than a firm with higher 

hourly rates. Therefore, the cost comparison is inadequate and does not meet 

Federal procurement requirements. We were not able to evaluate the number of 

hours each firm proposed to complete the work because that data was not in 

the proposal packages. 

Summary 

Because of the City’s procurement actions, FEMA has no assurance that 

disadvantaged firms had sufficient opportunities to bid on $23,343,436 of 

federally funded work. Additionally, the lack of full and open competition, 

improper use of cost as a basis for selecting a contractor, and lack of an 

adequate cost or price analysis for the $600,000 contract increased the risk of 

unreasonable costs, favoritism, collusion, fraud, waste, and mismanagement of 

Federal resources. Therefore, we question $23,943,436 as ineligible 

procurement costs. 

Finding B: Duplicate Benefits (Other Federal Grants) 

For Project 104, FEMA did not deduct $1,470,285 for funding received from 

other sources granted for the same purpose. Section 312 of the Robert T. 

Stafford Disaster Relief and Emergency Assistance Act, as amended, states that 

no entity will receive assistance for any loss for which it has received financial 

assistance from any other program, insurance, or any other source. Before the 

April 2014 disaster, the City received Community Development Block Grant 

(CDBG) funds from the U.S. Department of Housing and Urban Development 

(HUD) and an Appalachian Regional Commission Grant (ARC). The two grants 

were for (1) installation of electrical wiring, (2) a motor control center, (3) log 

conditioning kilns, and (4) restoration of a regenerative thermal oxidizer on the 

City’s main plywood factory building and supporting exterior facilities. At the 

time of the disaster, the City had not completed this work and had $1,070,285 

www.oig.dhs.gov 7 

OIG-16-143-D 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

remaining of the CDBG funds and $400,000 of the ARC funds to complete this 

work. Although FEMA was aware of these funds, it did not reduce otherwise 

eligible funding by the $1,470,285. Therefore, FEMA did not follow established 

procedures for obligating Federal funds. When it became aware of the other 

funding sources for the same purpose, FEMA should have reduced the 

obligated amount for Project 104. Federal appropriations law requires Federal 

agencies to deobligate funds when they are no longer needed or exceed 

amounts obligated for a project.3 

Neither the City nor FEMA knows the estimated costs for the work associated 

with the HUD/ARC grants — it may be more or less than $1,470,285. FEMA 

agreed on the possible duplication of benefits; however, FEMA contends that 

the subgrantee may apply its CDBG and ARC grant funds toward the nonFederal cost share of the Public Assistance grant. FEMA will apply the CDBG 

and ARC grants toward the non-Federal share only up to the cost of the 

electrical work. It will consider any remaining CDBG and ARC funds to be a 

duplication of benefits and reduce the grant accordingly. 

We agree in part with FEMA’s position. Grantees and subgrantees cannot use 

Federal grant funds toward the non-Federal cost share of another Federal grant 

program unless the authorizing legislation specifically allows doing so.4 In this 

case, both the CDBG and ARC legislation allows those funds to be used for a 

non-Federal cost share of another Federal grant program as long as the nonFederal share of the Public Assistance grant falls within the scope of the 

CDBG and ARC grants.5 However, FEMA should not reimburse the City for 

the estimated cost of any work on Project 104 until the City exhausts the entire 

$1,470,285 in HUD/ARC funds for the work specified under those grants. 

Therefore, because neither the City nor FEMA knows the estimated costs, we 

maintain that FEMA should have deducted the entire $1,470,285 from the 

approved estimate for Project 104 before setting the cap for the approved 

project. Because the $1,470,285 represented potential duplicate benefits, 

FEMA should have applied this amount to reduce the amount of obligated 

3 E.g., B-286929 (2001); B-207433 (1983) (“[W]hen an agency obligates more funds than are 

needed for a project, it must, upon learning the correct amount, deobligate the excess 

amount.”). See also B-321297 (2011). 4 U.S. Government Accountability Office (GAO), Principles of Federal Appropriations Law, Third 

Edition, Volume Il, February 2006, chapter 10, section E: Grant Funding 

5 ARC’s grant-making authority at 40 U.S.C. Section 14321(a)(4) states, “Notwithstanding any 

law limiting the federal share in any other federal or federal grant program, amounts 

appropriated to carry out this section may be used to increase that federal share, as the 

Commission decides is appropriate.” In a similar fashion, HUD’s statute at 42 U.S.C. Section 

5305(a)(9) also authorizes payment of the non-Federal share required in connection with 

another Federal grant program. 

www.oig.dhs.gov 8 

OIG-16-143-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

funds it considered eligible to restore the pre-disaster function of the damaged 

facility. Therefore, we question $1,470,285 as ineligible duplicate benefits. 

Finding C: Grant Management 

Mississippi did not fulfill its grantee responsibility to ensure the City followed 

applicable Federal procurement regulations. The nature and extent of ineligible 

costs we identified demonstrate that Mississippi should have been more 

thorough in reviewing the City’s contracting methods. Federal regulations 

require grantees to (1) ensure that subgrantees are aware of Federal 

regulations, (2) manage the operations of subgrant activity, and (3) monitor 

subgrant activity to ensure compliance. Therefore, FEMA should direct 

Mississippi to provide additional technical assistance and monitoring to the 

City to ensure compliance with all Federal grant requirements for future 

disasters. 

Recommendations 

We recommend that the Regional Administrator, FEMA Region IV: 

Recommendation 1: Disallow $23,943,436 (Federal share $17,957,577) of 

ineligible contract costs that the City did not procure in accordance with 

Federal requirements, unless FEMA decides to grant an exception for all or part 

of the costs as 44 CFR 13.6(c) allows and determines that the costs are 

reasonable (finding A). 

Recommendation 2: Disallow $1,470,285 of ineligible duplicate benefits from 

eligible project costs unless the City can provide sufficient evidence that 

funding from the other sources did not cover the eligible costs (finding B). 

Recommendation 3: Direct Mississippi to provide additional technical 

assistance and monitoring to the City to correct the deficiencies we identified in 

this report and to ensure compliance with grant requirements (finding C). 

www.oig.dhs.gov 9 

OIG-16-143-D 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Discussion with Management and Audit Follow-up 

We discussed the results of our audit with City, Mississippi, and FEMA officials 

during our audit. We also provided a draft report in advance to these officials 

and discussed it at the exit conference on August 17, 2016. 

Your office provided a written response on September 15, 2016, and agreed 

with our findings and recommendations. The response indicated that FEMA 

has taken corrective action to resolve recommendations 1 and 3; therefore, we 

consider these recommendations resolved and closed with no further action 

required from FEMA. FEMA expects to complete its proposed corrective actions 

to close recommendation 2 by January 31, 2017. Therefore, we consider report 

recommendation 2 resolved and open. We will post the final report on our 

website, including your formal comments as an appendix to the report. We will 

close recommendation 2 when we receive and review documentation that FEMA 

has completed its proposed corrective actions. Please provide our office 

documentation necessary to inform us about the status of the open 

recommendations by January 31, 2017, the estimated completion date of 

proposed action. 

The Office of Emergency Management Oversight major contributors to this 

report are Larry Arnold, Director; Melissa Powe Williams, Audit Manager; 

Katrina Griffin, Auditor-in-charge; and Rickey Smith, Auditor. 

Please call me with any questions at (202) 254-4100, or your staff may contact 

Larry Arnold, Director, Gulf Coast Regional Office, at (228) 822-0387. 

www.oig.dhs.gov 10 

OIG-16-143-D 
 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

We audited Public Assistance grant funds awarded to the City (Public 

Assistance Identification Number 159-42280-00). Our audit objective was to 

determine whether the City accounted for and expended FEMA grant funds 

according to Federal regulations and FEMA guidelines. 

As of October 13, 2015, the City had received a Public Assistance award of 

$51.7 million (net) for damages resulting from FEMA Disaster Number 4175­

DR-MS that occurred in April 2014. The audit covered the period April 28, 

2014, through October 13, 2015, the cutoff date of our audit and provided 

75 percent funding for five large projects and three small projects.6 We 

reviewed Project 104, Destroyed Plywood Facility, totaling $47.3 million (net), 

or 92 percent of the net Federal funds awarded to the City. See additional 

discussion about the audit scope and gross and net awards (p. 1 and table 1). 

We interviewed FEMA, Mississippi, and City officials; gained an understanding 

of the City’s method of accounting for disaster-related costs; reviewed the City’s 

procurement policies and procedures and contracting documents; judgmentally 

selected and reviewed (generally based on dollar values) project costs and 

procurement transactions for Project 104. We also performed other procedures 

considered necessary to accomplish our objective. We did not perform a 

detailed assessment of the City’s internal controls over its grant activities 

because it was not necessary to accomplish our audit objective. 

We conducted this performance audit between October 2015 and August 2016, 

under the authority of 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 objective. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based 

upon our audit objective. We conducted this audit by applying the statutes, 

regulations, and FEMA policies and guidelines in effect at the time of the 

disaster. 

6 Federal regulations in effect at the time of the 2014 storms set the large project threshold 

at $120,000 [Federal Register Volume 79, Number 38, Page 10685, Amendment to the Public 

Assistance Program’s Simplified Procedures Project Thresholds (February 26, 2014)]. 

www.oig.dhs.gov 11 

OIG-16-143-D 
 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Potential Monetary Benefits 

Table 3: Projects Audited and Questioned Costs 

Project 

Number 

Category 

of Work7 

Net Amount 

Awarded 

Questioned 

Costs 

Finding A 

Questioned 

Costs 

Finding B 

Total 

Questioned 

Costs 

104 E $ 47,299,126 $ 23,943,436 $ 1,470,285 $ 25,413,721 

Totals $47,299,126 $23,943,436 $1,470,285 $25,413,721 

Source: FEMA project worksheet, City records, and OIG analysis 

Table 4: Summary of Potential Monetary Benefits 

Type of Potential Monetary Benefit Amount Federal 

Share 

Questioned Costs - Ineligible $ 25,413,721 $ 19,427,862 

Questioned Costs - Unsupported 0 0 

Funds Put to Better Use 0 0 

Totals $25,413,721 $19,427,862 

Source: OIG analysis of report findings 

7 FEMA classifies disaster-related work by type: debris removal (Category A), emergency 

protective measures (Category B), and permanent work (Categories C through G). 

www.oig.dhs.gov 12 

OIG-16-143-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

FEMA’s Response to Report 

www.oig.dhs.gov 13 

OIG-16-143-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 14
 

OIG-16-143-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Chief of Staff 

Chief Financial Officer 

Under Secretary for Management 

Chief Privacy Officer 

Audit Liaison, DHS 

Federal Emergency Management Agency 

Administrator 

Chief of Staff 

Chief Financial Officer 

Chief Counsel 

Chief Procurement Officer 

Director, Risk Management and Compliance 

Audit Liaison. FEMA Region IV 

Audit Liaison, FEMA (Job Code G-15-050) 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

External 

Executive Director, Mississippi Emergency Management Agency 

State Auditor, Mississippi 

FEMA Coordinator, City of Louisville 

www.oig.dhs.gov 15 

OIG-16-143-D 
 

 

 

 

 

 

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