Department of Homeland Security 

Office of Inspector General 

Efficacy of DHS Grant Programs 
 

OIG-10-69 March 2010 
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, Offke ofinSpector, Ge'.'t!ral 

U.S. Department of Homeland S~curity

Washington, DC 20528 

Homeland 

Security 

MAR 2 2 2010 

Preface 

The Department of Homeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of the Federal Emergency 

Management Agency's efforts to mitigate duplication or redundancy within the 

department's various preparedness grant programs. It is based on interviews with 

employees and officials of relevant agencies and institutions, direct observations, and a 

review of applIcable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

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

Richard L. Skinner 

Inspector General 
Table of Contents/Abbreviations 

Executive Summary ........................................................................................................... 1
 


Background ........................................................................................................................ 2 
 

Results of Audit ................................................................................................................. 4 
 

Preparedness Grant Program Applications Are Not Compared or Coordinated ......... 4 
 

Legislation Creates Barriers to Coordination ........................................................ 5 
 

Departmental Processes and Organizational Structures Present Barriers to 
 

Coordination ....................................................................................................... 7 
 

State-level Barriers Impede Coordination ........................................................... 12 
 

Grant Application Processes Can Become More Efficient ........................................ 14 
 

Inconsistent or Redundant Grant Application Requirements Preclude Efficient 
 

Planning ............................................................................................................ 14 
 

Review Panels Differ Across Grant Programs ..................................................... 17 
 

Existing Grant Application Timelines Are Not Arranged Optimally .................. 19 
 

Conclusion ................................................................................................................. 19
 


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

Management Comments and OIG Analysis .............................................................. 20 
 

Appendices 

Appendix A: Purpose, Scope, and Methodology ......................................................23 
 

Appendix B: Management Comments to the Draft Report ......................................25 
 

Appendix C: Description of Grant Programs ...........................................................31 
 

Appendix D: Major Contributors to This Report .....................................................34 
 

Appendix E: Report Distribution .............................................................................35 
 

Abbreviations 

DHS Department of Homeland Security 
 

FEMA Federal Emergency Management Agency 
 

OIG Office of Inspector General 
 
OIG
 


Department of Homeland Security 

Office of Inspector General 

Executive Summary 

In FY 2008, the Federal Emergency Management Agency awarded 

more than $3 billion to state and local governments; territories; 

tribal governments; and private, public, profit, and nonprofit 

organizations through preparedness grants and other financial 

assistance programs. These grants are intended to enhance 

preparedness, protection, response, recovery, and mitigation 

capabilities by funding such items as planning, training, exercises, 

equipment, and interoperable communications. Our objective was 

to determine whether the Federal Emergency Management Agency 

and other components of the Department of Homeland Security 

have identified and taken steps to mitigate duplication or 

redundancy within the department’s various grant programs. 

The Federal Emergency Management Agency can improve the 

efficacy of the grant application and review process by taking steps 

to mitigate duplication or redundancy within the agency’s various 

preparedness grant programs. The agency’s grant application 

process risks being ineffective because the agency does not 

compare and coordinate grant applications across programs to 

identify and mitigate potential duplications. Additionally, grant 

application processes are not efficient, requiring the Federal 

Emergency Management Agency and state and local grant 

administrators to expend time and resources fulfilling redundant 

requirements for the numerous grant programs. 

The report contains three recommendations to the Federal 

Emergency Management Agency that, when implemented, should 

improve both the effectiveness and the efficiency of the agency’s 

preparedness grant programs. In its comments on a draft of this 

report, the Federal Emergency Management Agency concurred 

with the recommendations and outlined plans and actions to 

improve the efficacy of these grant programs. We addressed 

technical comments the agency provided in its comments on the 

report, as appropriate. A copy of the comments in their entirety is 

in Appendix B. 

Efficacy of DHS Grant Programs 


Page 1 

Background 

The Federal Emergency Management Agency (FEMA) coordinates 

the federal government’s role in preparing for, preventing, 

mitigating the effects of, responding to, and recovering from all 

natural or manmade domestic disasters, including acts of terror. 

Following the September 11, 2001 attacks, federal preparedness 

guidance and financial assistance evolved and expanded. The 

President signed Homeland Security Presidential Directive 8, 

National Preparedness, December 17, 2003, to establish policies 

strengthening the preparedness of the United States. This directive 

required a national all-hazards preparedness goal, established 

mechanisms for improved delivery of federal preparedness 

assistance to state and local governments, and outlined actions to 

strengthen preparedness capabilities of federal, state, and local 

entities. 

Congress also increased its attention on national preparedness and 

homeland security by passing legislation to authorize modified or 

additional preparedness initiatives and assistance programs. 

Subsequently, Department of Homeland Security (DHS) grant 

programs implemented numerous and sometimes competing 

objectives addressed in various post-9/11 laws, strategies, plans, 

and directives. 

In FY 2008, FEMA awarded more than $3 billion to state and local 

governments; territories; tribal governments; and private, public, 

profit, and nonprofit organizations through preparedness grants and 

other financial assistance programs (referred to collectively as 

grants). DHS preparedness grants are intended to enhance 

preparedness, protection, response, recovery, and mitigation 

capabilities throughout the Nation by funding such items as 

planning, training, exercises, equipment, interoperable 

communications, and personnel costs. 

Within FEMA, the Grant Programs Directorate is responsible for 

business operations, training, policy, and oversight of all FEMA 

grants. This new directorate was created on April 1, 2007, in 

response to the Post-Katrina Emergency Management Reform Act 

of 2006, to consolidate the operations of all FEMA grants under a 

single organization. The Grant Programs Directorate was formed 

from three legacy organizations: 

Efficacy of DHS Grant Programs 


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FEMA Grants Management Branch, 

DHS Office of Grants and Training – Office of Grant 

Operations, and 

DHS Office of Grants and Training – Preparedness 
 

Programs Division. 
 

The Post-Katrina Emergency Management Reform Act of 2006 

consolidated not only grant operations, but also preparedness 

grants that previously had program responsibility residing in 

various DHS organizations. 

The Grant Programs Directorate reviews, negotiates, awards, and 

manages FEMA’s preparedness grant portfolio; provides subject 

matter expertise in response to regional office and stakeholder 

inquiries; develops grant guidance and formulates risk 

methodology to support grant allocations; and analyzes 

investments. This Directorate also receives subject matter 

expertise through collaboration with the National Preparedness 

Directorate and U.S. Fire Administration within FEMA, and other 

DHS partners such as the U.S. Coast Guard, Transportation 

Security Administration, Office of Infrastructure Protection, and 

Office of Emergency Communications. 

Our review focused on 13 preparedness grant programs shown in 

Table 1. These 13 programs provide funding for a variety of items, 

including planning, training, exercises, and equipment. 

We focused our review on planning activities and interoperable 

communications equipment because they were allowable costs in 

multiple grant programs. For additional details on our purpose, 

scope, and methodology, see Appendix A. For a description of the 

13 grant programs’ objectives, see Appendix C. 

Efficacy of DHS Grant Programs 


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Table 1. Grant Program’s Allowable Funding For Selected Activities 

Funding Activity 

Grant Program 

Planning Interoperable 

Communications 

Homeland Security Grant Program 

State Homeland Security Program 

Urban Areas Security Initiative 

Citizen Corps Program 

Metropolitan Medical Response System 

Assistance to Firefighters Grant Program 

Buffer Zone Protection Program 

Commercial Equipment Direct Assistance Program 

Emergency Management Performance Grant 

Program 

Emergency Operations Center Grant Program 

Interoperable Emergency Communications Grant 

Program 

Port Security Grant Program 

Regional Catastrophic Preparedness Grant Program 

Transit Security Grant Program 

Results of Audit 

FEMA’s preparedness grant application process does not promote effectiveness 

and efficiency. The grant application process risks being ineffective because 

FEMA does not compare and coordinate grant applications across preparedness 

programs to identify and mitigate potential duplications. Without evaluating 

grant applications across grant programs, FEMA cannot ascertain whether 

multiple funding requests are being submitted for similar purposes. 

Additionally, FEMA’s preparedness grant application processes are not efficient 

because they require FEMA and the states to expend time and resources fulfilling 

redundant application and review requirements for the numerous grant programs. 

Consequently, limited federal and state resources are not being expended in the 

most beneficial manner. 

Preparedness Grant Program Applications Are Not Compared or 

Coordinated 

The preparedness grant application process risks being ineffective because 

FEMA does not compare and coordinate grant applications across 

preparedness programs to mitigate potential duplications and redundancy. 

Efficacy of DHS Grant Programs 

Page 4 
Barriers at the legislative, departmental, and state levels impede FEMA’s 

ability to coordinate these programs. Since grant programs may have 

overlapping goals or activities, FEMA risks funding potentially 

duplicative or redundant projects. 

Legislation Creates Barriers to Coordination 

Three types of legislative barriers hinder FEMA’s ability to 

identify and minimize duplication and redundancy within 

preparedness grants. First, Congress enacts legislation for 

preparedness grants that have similar goals. Second, Congress 

appropriates funds on an annual basis for these grants and in most 

instances, the legislation mandates disparate application and award 

milestones. Finally, the annual appropriation law may contain 

congressional earmarks that dedicate funds towards specific grant 

projects, precluding FEMA from coordinating grant programs. 

Multiple Grant Programs Have Similar Legislated Goals 

The 13 grant programs we reviewed have similar legislated goals. 

At a broad level, these programs provide federal assistance to state 

and local governments, nonprofit organizations, emergency 

responders, and port and transit authorities to improve homeland 

security and emergency management capabilities. Specifically, the 

legislated goals of these grant programs focus on activities to 

prepare for or respond to acts of terrorism or other disasters. 

For example, states may request funding for planning projects 

through both the Urban Areas Security Initiative and the Regional 

Catastrophic Preparedness Grant Program. While the goals for 

both programs are directed at improving preparedness planning in 

high-risk urban areas, the Regional Catastrophic Preparedness 

Grant Program is focused on all-hazards planning, while the Urban 

Areas Security Initiative is focused on responding to acts of 

terrorism. 

In addition to the Urban Areas Security Initiative, other grant 

programs have legislated goals to prepare for, prevent, or respond 

to acts of terrorism. Specifically, state and local governments as 

well as port and transit authorities can request funds for, and 

respond to terrorist acts, through the State Homeland Security 

Program, the Port Security Grant Program, and the Transit Security 

Grant Program. 

Efficacy of DHS Grant Programs 

Page 5 
Disparate Milestones Are Legislatively Established 

Legislation also mandates grant application processing and award 

milestones; however, not all grants are set on the same schedule. 

The 2008 Consolidated Appropriations Act, Public Law 110-161, 

December 26, 2007, established two sets of milestones for 8 of the 

13 grant programs we reviewed. The legislation required grant 

applicants to submit applications for three of the grants in 

March 2008, with awards due in May 2008, while applications for 

five of the grants were due in April 2008, with awards in 

July 2008. With grant review periods and award dates more than 

2 months apart, FEMA may not have sufficient time to compare 

the numerous applications submitted by each state for similar or 

related projects to prevent duplication. While we are not 

advocating that all applications be due on the same date, we are 

identifying the disparate schedules as a potential barrier to 

FEMA’s ability to coordinate related projects. 

To illustrate, Figure 1 reflects the different legislated milestone 

requirements for the Urban Area Security Initiative and the Transit 

Security Grant Program. Both of these programs may be used for 

costs to develop and implement homeland security support 

programs, and adopt ongoing DHS national initiatives such as 

enhancing preventive radiological and nuclear detection programs. 

As shown in the figure below, FEMA must make award decisions 

for the Transit Security Grant Program before completing its 

review of Urban Areas Security Initiative applications, inhibiting 

coordination of potentially related projects. 

Figure 1. Legislatively Established Grant Milestones for Two Programs 

As another example, the State Homeland Security Program and the 

Buffer Zone Protection Program both fund interoperable 

communications equipment. However, legislation requirements 

Legislative Processing Timeline 

Grant Guidance Development Period 

Application Submission Period 

Application Review Period 

Transit Security Grant Program 

Urban Areas Security Initiative 

1-25-08 3/10/08 5/9/08 

1/20/08 4/19/08 7/18/09 

Efficacy of DHS Grant Programs 


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provide for different review periods and grant award dates that are 

more than 2 months apart. The State Homeland Security Program 

has the same milestones as the Urban Areas Security Initiative 

while the Buffer Zone Protection Program’s dates align with the 

Transit Security Grant Program. 

Congress Earmarks Funds for Specific Purposes 

Annual appropriation law may contain congressional earmarks that 

fund specific grant projects. These earmarks limit FEMA’s ability 

to ensure federal assistance is being provided to fund grant 

recipients’ most urgent homeland security and emergency 

management needs and priorities. They also inhibit FEMA’s 

ability for corrective action on potentially duplicative investments 

for grant recipients who received 

grants through normal risk-based 

application processes for purposes 

similar to the earmarked funds. 

For example, one county in 

Washington applied for the 

Emergency Operations Center Grant 

in FY 2008. The state ranked the 

application as a low priority and the 

project did not receive grant funding. However, the county 

received an earmark for $1 million in the following year’s 

FY 2009 Emergency Operations Center Grant appropriations, 

although it may not have been the state’s highest priority. While 

earmarks do not directly prohibit FEMA from comparing similar 

projects funded by different grants, they do inhibit FEMA’s ability 

to take action if a lower priority project with earmarked funds 

overlaps with another higher priority project funded by a grant that 

uses a risk-based allocation methodology. 

Earmarks: Funds provided by 

Congress for projects, programs, 

or grants where the purported 

congressional direction 

circumvents otherwise applicable 

merit-based or competitive 

allocation processes, or specifies 

the location or recipient. 

Source: Office of Management 

and Budget 

Departmental Processes and Organizational Structures 

Present Barriers to Coordination 

In addition to legislative barriers, FEMA faces department-level 

challenges that impede its ability to coordinate grant applications 

across the many programs. Departmental barriers include: 

Interpreting legislation, 

Developing grant guidance, 

Requiring investment justification details, 

Reviewing applications, and 

Efficacy of DHS Grant Programs 

Page 7 
�	 Coordinating with subject matter experts located in 
 

separate program offices. 
 

Grant-Related Legislation Requires Interpretation 

FEMA, or its predecessor organizations, created a barrier to 

coordination in establishing separate stand-alone grant programs to 

accomplish congressional objectives. Typically, once Congress 

authorizes a grant to fund an emerging homeland security or 

emergency management need, FEMA develops a new and separate 

grant program. For example, Public Law 110-53, Implementing 

Recommendations from 9/11 Commission Act, August 3, 2007, 

directed FEMA to make grants to states for equipping, upgrading, 

and constructing emergency operations centers. While the 

legislation did not direct FEMA to establish a separate program, 

FEMA interpreted the legislation as such. FEMA’s development 

of separate grant programs promotes fragmentation and 

complicates coordination at both the federal and state level. 

Grant Guidance Is Developed for Individual Programs 

Creating individual guidance for each grant program deters 

coordination because the individual guidance documents establish 

a separate identity for each program and each grant application will 

be tailored specifically to the guidance. Grant guidance establishes 

the individuality and details the scope of a grant program. The 

substance of individual grant guidance includes identifying 

funding priorities, describing the application and review process, 

providing the investment justification template, and other year-toyear changes. 

The FEMA Grant Programs Directorate has the main responsibility 

for issuing grant guidance, yet the directorate coordinates with 

individual program offices to develop the substance of the grant 

guidance for each individual grant program. The grant program 

offices can be within or outside of the Grant Programs Directorate. 

With the exception of the Homeland Security Grant Program, 

which combines grant guidance for four interrelated grant 

programs into one guidance document, individual grant guidance 

results in a deterrence to coordination because of the number of 

organizations involved. 

Efficacy of DHS Grant Programs 


Page 8 

Applications and Investment Justifications Request Different 

Levels of Detail 

Typically, the level of detail in grant applications and investment 

justifications is not sufficient for FEMA to identify potential 

duplication and redundancy. Investment justifications are a part of 

a grant application and provide a template for the applicant to 

describe the proposed project and demonstrate how it addresses 

deficiencies in current capabilities. However, the level of detail on 

each project makes it difficult to identify whether states are 

applying for similar projects under another grant program. The 

investment justification template for the State Homeland Security 

Program, for instance, does not provide grant applicants the ability 

to provide specific details on their proposed projects. The 

investment template covers topics including critical infrastructure, 

preparedness planning, and interoperable communications. It also 

requests a high-level purpose statement, funding plan, and 

outcomes. 

As an example, one state submitted an investment justification 

under the State Homeland Security Program to provide exercises to 

emergency responders to reinforce the principles of the National 

Response Framework and the National Incident Management 

System. Similarly, the state requested funding through the 

Emergency Management Performance Grant to develop, design, 

and conduct exercises focusing on enhancing regional 

collaboration and coordination and to reinforce the implementation 

of the National Incident Management System. Both investments 

address exercises related to the National Incident Management 

System, but without additional details, FEMA cannot readily 

identify whether these projects overlap. 

Applications Are Reviewed At the Department Level Without 

Considering Other Grant Programs 

FEMA’s ability to determine whether the proposed grant 

application investments contain duplicative or redundant requests 

is impeded when grant applications and investment justifications 

are reviewed one program at a time. After a grant application is 

submitted, a review panel evaluates applications and proposed 

investments. While the panel compares the proposed investments 

to the grant guidance for that program, the panel does not compare 

proposals against applications for other grant programs submitted 

by the same grantee. 

Efficacy of DHS Grant Programs 

Page 9 
With the availability of funds from numerous individual 

preparedness grant programs for similar purposes, applicants may 

apply for multiple grant programs for the same items to maximize 

their chances to fully fund a project. Eleven of the 13 programs 

reviewed allow applicants to purchase interoperable 

communications equipment, such as radios. Therefore, it is 

possible for a single organization within a state to receive funding 

from multiple grant programs for similar items. As one example, it 

is possible for a law enforcement organization to build a cache of 

radios through multiple grant programs, as shown in Figure 2 

below. As these four programs undergo different review 

processes, FEMA cannot readily identify whether funds requested 

are for similar or overlapping projects. 

Figure 2. Use of Multiple Grant Programs for Similar Equipment Requests 

*

 Subject matter experts perform the technical review of investment proposals. FEMA 

also has a role in the application process for all four grant programs. 

FEMA has taken initial steps to coordinate application and 

investment justification reviews for four individual grant programs. 

The Homeland Security Grant Program is comprised of four 

interconnected grant programs: (1) the State Homeland Security 

Program, (2) Urban Areas Security Initiative, (3) Metropolitan 

Medical Response System, and (4) Citizen Corps Program. During 

the review process, state and local peer reviewers evaluate and 

score applications and investment justifications for all four of the 

individual grant programs in a single application submission and 

Efficacy of DHS Grant Programs 


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review process. However, while state and local peer reviewers 

have the capability to perform an internal comparison of grant 

programs under the Homeland Security Grant Program, they do not 

have access to applications and investment proposals submitted in 

response to other grant programs with similar purposes or 

allowable activities. 

Separate Program Office Responsibilities Hamper Coordination 

Grant program management split among several offices creates 

organization barriers to coordination. Although the Grant 

Programs Directorate is responsible for managing DHS 

preparedness grants, program-specific management is split among 

different directorates within DHS. FEMA has the lead for 

managing the review and approval processes and coordinating 

grant guidance, while separate organizations within DHS identify 

the funding priorities, provide guidance input, and participate in 

the review process. While each grant program has a guidance 

document defining the application and review process for the 

individual program, FEMA does not have an overarching policy to 

outline the roles and responsibilities for coordinating applications 

across grant programs. 

As shown in Table 2, responsibility for the 13 grant programs we 

reviewed is split among five different organizations. 

Table 2. Program Responsibility for Grant Programs 

FEMA Grant Programs Directorate FEMA National Preparedness 

Directorate 

Homeland Security Grant Program Commercial Equipment Direct 

– State Homeland Security Program Assistance Program 

– Urban Areas Security Initiative Regional Catastrophic 

– Citizen Corps Program Preparedness Grant Program 

– Metropolitan Medical Reserve System 

Transportation Security 

Assistance to Firefighters Grant Program Administration 

Transit Security Grant Program 

Emergency Management Performance 

Grant Program U.S. Coast Guard 

Emergency Operations Center Grant Port Security Grant Program 

Program 

Interoperable Emergency DHS Office of Infrastructure 

Communications Grant Program Protection 

Buffer Zone Protection Program 

When subject matter experts, who define funding priorities and 

review investment justifications, reside outside of FEMA, the 

Efficacy of DHS Grant Programs 
 

Page 11
 

agency’s ability to coordinate across grant programs is impeded. 

For example, the Buffer Zone Protection Program is not 

coordinated with other grant programs at the department level. 

This program provides funding to secure predesignated critical 

infrastructure sites, which are preselected by the DHS Office of 

Infrastructure Protection. Once DHS selects the sites, local 

officials work with site owners to develop security plans and 

identify equipment needed to implement the plan. Because FEMA 

does not have a process for ensuring applications are coordinated 

across grant programs, the Office of Infrastructure Protection is 

unable to validate with FEMA whether the applicant had requested 

similar equipment items under other grant programs. 

FEMA also encounters barriers to coordination when different 

organizations within FEMA are responsible for managing 

preparedness grants. The Grant Programs Directorate has 

programmatic responsibility for 8 of the 13 programs we reviewed, 

while the National Preparedness Directorate has programmatic 

responsibility for 2 grant programs. Because these 10 grant 

programs have overlapping funding activities and have different 

organizations participating in the investment justification review 

and approval process, FEMA cannot readily identify redundancy in 

funding requests across the different grant programs. While 

FEMA relies on the subject matter expertise that these 

organizations provide, it cannot easily identify duplications in its 

grant programs without an overarching policy outlining roles and 

responsibilities for coordinating applications across grant programs 

and across the different organizations. 

State-level Barriers Impede Coordination 

FEMA encounters barriers at the state level that impede its ability 

to compare and coordinate grant applications and investments 

across preparedness programs. States do not have an overall grant 

strategy that identifies specific projects and their funding sources. 

Additionally, there is not one organization within the state that has 

visibility over all state entities that receive DHS financial 

assistance. 

Not All States Have Overall Grant Strategies 

The three states we visited did not have overall, comprehensive 

grant strategies. The states had various preparedness strategies or 

plans that address target capabilities and identify critical goals, 

objectives, and implementation steps. However, the plans did not 

Efficacy of DHS Grant Programs 


Page 12 

 

specifically address how the states are using funds from the 

multiple DHS grants to improve homeland security preparedness. 

A more comprehensive plan could provide states a tool to promote 

coordination across the different grant programs which are now 

planned and accounted for separately. 

State-level Visibility Over All Grant Programs Is Not Centralized 

FEMA cannot rely on the states to coordinate all preparedness 

grant applications because grants are awarded to multiple 

organizations within the state. At the three states we visited, none 

of the states had an organization with visibility across all 

preparedness grant programs. Some grants are awarded through 

state administrative agencies while others bypass the state 

administrative agency and go directly to recipients such as port 

authorities, local fire departments, and first responders. 

For grant programs where 

the state administrative 

agency is involved, the 

agency may not have 

programmatic 

responsibility over the 

program. In this case, the 

state administrative 

agency would not be 

reviewing grant projects 

from the same 

perspective as a subject 

matter expert or be able 

to readily identify 

duplication or redundancy. The prerogative of each state to 

determine its own organizational structure may or may not 

coincide with the corresponding federal grant program 

responsibility. 

Programmatic vs. Financial Responsibility 

Programmatic Responsibility: Responsibility to 

ensure that programs and projects are implemented 

consistent with the grantee’s approved plans and 

according to the rules and regulations of the 

awarding office. It also includes the ability to 

identify problems that may impede effectiveness of 

the federally funded programs or projects and 

serves to verify program implementation. 

Financial Responsibility: Responsibility to 

measure grantees’ compliance with federal 

policies and regulations. 

Source: FEMA 

For example, at two of the three states visited, subject matter 

experts outside of the state administrative agency prepared the 

investment justifications for the Interoperable Emergency 

Communications Grant Program. The state administrative agency 

primarily ensured compliance with grant guidance and 

administrative requirements, but did not have programmatic 

responsibility for the projects and funding requested. 

Efficacy of DHS Grant Programs 


Page 13 

Additionally, grant funding may be sent directly to an organization 

outside of the state administrative agency. For example, the Port 

Security Grant Program funds go directly to a fiduciary agent 

selected by the port. At two of the three states visited, the 

fiduciary agency was not the state administrative agency and 

therefore the state was not aware of projects being funded through 

this program. Without the state having visibility over all 

preparedness grants, FEMA cannot rely on states to identify 

duplication and redundancy across DHS grant programs. 

Grant Application Processes Can Become More Efficient 

FEMA’s grant application processes are not efficient because application 

requirements, review processes, and timelines vary among the grant 

programs. These numerous processes and requirements can be 

burdensome on federal and state resources because this creates redundant 

work for both federal and state personnel. Therefore, coordinating and 

streamlining these application processes may help ensure the most 

efficient use of limited federal and state resources. 

Inconsistent or Redundant Grant Application Requirements 

Preclude Efficient Planning 

FEMA issues separate annual guidance to outline the application 

processes and requirements for each grant program which creates 

burdensome requirements on both FEMA and grantees as the 

requirements differ across grant programs. Additionally, the 

multiple application processes have redundant requirements. 

Grant Requirements for Similar Grant Programs Differ 

Significantly 

Requirements in grant guidance vary across programs, regardless 

of the similarities of the grant program, making it difficult for 

states to have a streamlined planning process that is consistent 

across all grant programs. Differences include program priorities 

and investment justification templates that must be followed. 

Priorities. While considerable potential overlap exists in the 

activities supported by DHS preparedness grant programs, the 

priorities for these programs may differ. For example, the 

FY 2008 Urban Areas Security Initiative, Regional Catastrophic 

Preparedness Grant Program, and Emergency Management 

Performance Grant Program provide assistance to improve 

Efficacy of DHS Grant Programs 

Page 14 
preparedness planning processes. However, each program focuses 

on a different priority. 

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The Urban Areas Security Initiative provides funds to highrisk urban areas to build an enhanced and sustainable 

capability to prevent, protect against, respond to, and 

recover from acts of terrorism. 

The Regional Catastrophic Preparedness Grant Program, 

which supports improved and expanded regional 

collaboration for all hazard and catastrophic events, also 

funds high-risk urban areas but includes surrounding 

regions as well. Additionally, this program focuses on 

eight national planning scenarios identified by the federal 

government as the most urgent for planning purposes 

among all levels of government. 

The Emergency Management Performance Grant Program 

also supports state and local all-hazards emergency 

management programs and encourages applicants to 

address national planning scenarios in their work plans, but 

is focused on evacuation planning, logistics and resource 

management, continuity of operations planning, and 

recovery planning. 

Since each preparedness planning program focuses on a different 

priority, states have to undertake three separate planning and grant 

application processes to request funding under each program. 

Investment Justification Templates. Grant programs have different 

investment justification templates as part of the application 

process. This requires applicants to prepare investment 

justifications or documents with unique information for each 

program regardless of the similarities of the proposed funding 

activities. These varied templates and program documents may 

provide consistency for panels reviewing proposed project 

proposals for the individual grant programs, but present an 

administrative burden for grant applicants who must prepare 

similar information in different formats. 

For example, the Buffer Zone Protection Program requires 

applicants to prepare two unique documents not required for other 

grant programs. First, individual jurisdictions responsible for the 

buffer zone are required to submit a Buffer Zone Plan to assist 

them in identifying preventive and protective measures necessary 

Efficacy of DHS Grant Programs 


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to protect a critical infrastructure and key resource site, mitigate 

vulnerabilities, or close capability gaps. Next, the jurisdictions 

complete a Vulnerability Reduction Purchasing Plan, a spending 

plan that includes the planning activities and equipment necessary 

to implement the Buffer Zone Plan. As these documents are 

unique and integral to the program, they may present an 

administrative burden to state grant administrators in fulfilling 

these specialized requirements. 

Grant Applications for Similar Programs Incorporate Redundant 

Requirements 

Grant applicants must perform redundant work to apply for DHS 

preparedness grants, which is burdensome and time consuming. 

The use of the website grants.gov has streamlined the application 

process, but it still requires applicants to prepare and submit 

redundant information if an applicant applies for multiple grants. 

FEMA’s grant application process required each State 

Administrative Agency, the designated applicant for 10 of the 

13 grant programs reviewed, to complete an online grant 

application seven times for the 10 grant programs. Submitting 

these similar documents multiple times may increase the State 

Administrative Agency’s opportunities for errors on these forms. 

The process for the seven grant programs included similar 

application, financial, and administrative compliance requirements, 

as listed in Table 3. 

Efficacy of DHS Grant Programs 


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Table 3. Grant Program Filing Requirements 

Application Requirements 

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Application for Federal Assistance (SF 424) 

Investment Justification or Plan 

Disclosure of Lobby Activities (SF LLL) 

Budget Information 

– Budget Information – Non-construction Programs (SF 424A) 

– Budget Information – Construction Programs (SF 424C) 

Standard Financial Requirements 

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Non-supplanting Certification 

Assurances 


–	 Assurances – Non-construction Programs (SF 424B) 


–	 Assurances – Construction Programs (SF 424D) 


Certification Regarding Debarment, Suspension, and Other Responsibility 

Matters and Drug-Free Workplace Requirement 

Administrative Compliance Requirements 

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Federal Civil Rights Laws and Regulations 

Services to Limited English Proficient Persons 

Integrating Individuals with Disabilities into Emergency Planning 

National Energy Conservation Policy and Energy Policy Acts 

Environmental and Historical Preservation 

FEMA also requires State Administrative Agencies to use two 

online systems to complete and file investment justifications for 

the Homeland Security Grant Program. First, the State 

Administrative Agency must complete the State Homeland 

Security Program and Urban Areas Security Initiative investment 

justifications through the department’s Grant Reporting Tool. 

Upon completion of the investment justifications, the State 

Administrative Agency must submit the official copy of its final 

investment justification through www.grants.gov with the grant 

application. While these online tools helped to streamline the 

application processes, they include an inefficient duplication of 

effort for both federal and state grant administrators. 

Review Panels Differ Across Grant Programs 

Grant programs have separate review processes to evaluate funding 

requests for each grant program, which requires FEMA to convene 

multiple review panels to evaluate applications and investment 

justifications. For all programs, FEMA verifies the applicant’s 

compliance with administrative and eligibility criteria identified in 

each grant program’s application kit. FEMA then sends the 

eligible applications through an investment justification review 

process to evaluate the merits of proposed investments against 

grant guidance criteria. However, FEMA uses various types of 

Efficacy of DHS Grant Programs 


Page 17 

�

�

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reviews to evaluate 

proposed investments. 

The type of review 

and participants of the 

review panel are 

based on the grant 

program. For the 13 

grant programs we 

reviewed, FEMA 

employed 6 different 

review processes, 

composed of different 

personnel such as 

federal, state, and 

local government 

personnel; emergency 

Best Practice 

In 2005, FEMA incorporated the application process 

of four complementary grant programs into the 

Homeland Security Grant Program: 

State Homeland Security Program

Urban Areas Security Initiative

Citizen Corps Program

Metropolitan Medical Response System

While the four grant programs retained their distinct 

and separate identities, the Homeland Security Grant 

Program provides a single application kit and program 

guidance to facilitate coordination and management of 

state and local homeland security funding. This also 

helps ensure that available funding is leveraged for 

maximum impact. 

Source: FEMA 

responders; and 
 

members of national associations, as shown in Table 4.
 


Table 4. Grant Program Review Methodologies 

1. FEMA Review – FEMA headquarters components and/or regional offices review 

investments and make award determinations. (Emergency Management Performance 

Grant Program) 

2. DHS Review – DHS components outside FEMA, such as the Office of 

Infrastructure Protection review proposed investments. (Buffer Zone Protection 

Program Grant) 

3. Peer Review – A panel of state and local representatives from across the Nation, 

such as subject matter experts with experience in fire and emergency response, review 

and score proposed investments. (Homeland Security Grant Program, Assistance to 

Firefighters Grants) 

4. Federal Review – A panel of subject matter experts from across DHS, including 

components within FEMA and outside FEMA such as the DHS Office of Emergency 

Communications, review proposed investments. (Interoperable Emergency 

Communications Grant Program) 

5. National Review – A panel of subject matter experts from across DHS, including 

FEMA, non-DHS federal components, or national associations, review proposed 

investments. (Port Security Grant Program) 

6. Subject Matter Expert Review – National subject matter experts with experience 

in law enforcement and emergency response review and score proposed investments. 

(Commercial Equipment Direct Assistance Program) 

These numerous panels create additional work for FEMA to 

request review panel members from federal, state, and local 

organizations, depending on the grant program. FEMA must also 

train the numerous panels, provide review materials, oversee the 

panels, and compile panel results. Consolidating panels where 

grant programs have similar purposes or activities would provide a 

more efficient use of federal, state, and local resources. 

Efficacy of DHS Grant Programs 

Page 18 
Existing Grant Application Timelines Are Not Arranged 

Optimally 

Grant timelines do not promote the most efficient application 

preparation and review because they are not arranged in the most 

optimal sequence. In many cases, the timelines are legislatively 

established and do not allow states the opportunity to logically 

develop investment justifications that address overarching needs or 

define target capabilities while simultaneously focusing on more 

narrowly focused programs. For the 13 FY 2008 grant programs 

we reviewed, application timelines varied from March 1 to July 28, 

2008. Although the scopes of these programs may overlap, we did 

not identify a consistent pattern in the current sequence that would 

allow states to develop investment justifications for similar 

programs or related projects in a logical and efficient order. 

For example, law enforcement organizations that provide transit 

security may receive funding through the Transit Security Grant 

Program. These same organizations may also receive funding for 

law enforcement terrorism prevention–oriented planning, training, 

exercise, and equipment activities through both the State 

Homeland Security Program and the Urban Areas Security 

Initiative. While we have not defined the most optimal sequence 

for grant programs, an organized sequence would increase 

efficiency at the federal level by allowing grant reviewers to use 

the outcome from various panels as they review their investments 

and also by reducing the time that states may spend developing 

investment justifications. This would also provide a better review 

at the state level to ensure that redundant projects are not 

duplicated across grant programs. 

Conclusion 

DHS preparedness grants are critical to help the country prepare for, 

respond to, and recover from disasters. Barriers at the legislative, 

departmental, and state levels preclude the agency from coordinating grant 

applications to avoid potential duplication and redundancy. Without this 

coordination, FEMA risks funding duplicative or redundant projects and 

cannot readily ascertain whether limited federal funds are awarded to grant 

recipients’ most urgent homeland security and emergency management 

needs and priorities. 

The numerous grant application and review processes can be burdensome 

on federal and state resources because of the redundant work imposed on 

Efficacy of DHS Grant Programs 

Page 19 
both federal and state personnel. As a result, limited federal and state 

resources are being expended inefficiently. 

We recognize that legislated requirements can complicate the application 

and review of federal assistance programs. However, FEMA must 

identify alternate ways to improve its grant application and review 

processes operating within currently legislated requirements or work with 

Congress to modify the processes to ensure the most efficient and 

effective use of limited federal resources. 

Recommendations 

We recommend that the Administrator, Federal Emergency 

Management Agency: 

Recommendation #1: Identify preparedness grant programs that 

may overlap or duplicate other programs and ensure the 

application and review processes for these programs are 

coordinated to mitigate potential duplication and redundancy. 

Recommendation #2: Document specific agency roles and 

responsibilities for cross-program coordination of grant application 

and review processes and ensure internal DHS coordination is in 

place. This may include establishing memorandums of agreement 

if roles are outside the Federal Emergency Management Agency. 

Recommendation #3: Work with Congress and state grant 

administrators to identify opportunities and implement actions to 

streamline and standardize multiple preparedness grant program 

application processes. 

Management Comments and OIG Analysis 

The Director of FEMA’s Office of Policy and Program Analysis 

provided written comments on a draft of this report. FEMA 

concurred with our recommendations, but commented that the 

manner in which each program is implemented is driven by the 

Congress. As long as Congress authorizes and appropriates 

programs for singular purposes to specific constituencies, FEMA 

will carry out the programs as mandated. 

FEMA’s response also incorporated technical comments from the 

DHS Office of Infrastructure Protection, which shares 

responsibility with FEMA for the Buffer Zone Protection Program. 

We considered these comments when preparing the final report 

Efficacy of DHS Grant Programs 

Page 20 
and, where appropriate, modified the report. We have incorporated 

a copy of the comments in their entirety in Appendix B. 

Management Comments to Recommendation #1. FEMA 

concurred with the recommendation, and has already undertaken 

an effort to review existing grant programs and identify ways to 

minimize report and application burdens. Additionally, FEMA is 

working with the department to consolidate grant programs where 

activities are allowable under multiple grant programs. FEMA 

recognizes that legislation may hinder its ability to eliminate grant 

program overlaps, specifically when annual appropriation law 

provides separate and distinct purposes, funding, and 

administrative limitations. 

OIG Analysis: This recommendation is resolved, but will remain 

open until we have reviewed the results of the DHS and FEMA 

analyses on consolidating overlapping grant programs and 

minimizing application burdens. 

Management Comments to Recommendation #2. FEMA 

concurred with the recommendation and, along with the Office of 

Infrastructure Protection, has developed a draft memorandum of 

agreement identifying specific roles and responsibilities for 

coordination of the Buffer Zone Protection Program. FEMA is in 

the process of establishing memorandums of agreement with other 

components. Additionally, FEMA acknowledged that it must use 

multiple disparate systems to manage grant funds. It believes that 

future implementation of the Non Disaster Grants System may 

mitigate some issues identified in our report. 

OIG Analysis: This recommendation is resolved, but will remain 

open until FEMA finalizes and implements its memorandums of 

agreement with the different components. 

Management Comments to Recommendation #3. FEMA 

concurred with the recommendation, and stated it has robust 

interaction with Congress, the Office of Management and Budget, 

and numerous stakeholder communities. FEMA is also 

establishing a Preparedness Task Force, comprised of state, tribal, 

local, and private sector experts. The Task Force will be charged 

with evaluating FEMA’s preparedness efforts, including the 

structure and requirements of its grant programs. FEMA expects 

the task force will provide its recommendations for improving 

these and other activities by the end of FY 2010. 

Efficacy of DHS Grant Programs 


Page 21 

OIG Analysis: This recommendation is resolved, but will remain 

open until the task force completes its review and FEMA analyzes 

its recommendations. 

Efficacy of DHS Grant Programs 


Page 22 

Appendix A 

Purpose, Scope, and Methodology 

The purpose of our audit was to determine whether FEMA and 

other components of the department have identified and taken 

steps to mitigate duplication or redundancy within the department's 

various grant programs that impede the ability of recipients to 

apply grant funds toward their most urgent homeland security and 

emergency management needs and priorities. 

We met with DHS Grant Policy and Oversight and FEMA officials 

responsible for management and oversight of DHS preparedness 

grants: Grant Programs Directorate, National Preparedness 

Directorate, and U.S. Fire Administration. We also conducted 

interviews with officials from FEMA Region III, Transportation 

Security Administration, and U.S. Coast Guard. 

We evaluated internal controls that were pertinent to the audit 

objective. Specifically, we discussed FEMA and DHS financial 

and programmatic responsibilities, including reviewing, 

negotiating, awarding, and managing FEMA’s preparedness grant 

portfolio; providing subject matter expertise in response to regional 

office and stakeholder inquiries; developing grant guidance and 

formulating risk methodology to support grant allocations; and 

conducting investment analysis. 

During our review, we reviewed recent Government Accountability 

Office and OIG reports and testimony to identify prior findings and 

recommendations. We researched and reviewed pertinent 

legislation and FY 2006 through FY 2009 grant guidance, with a 

focus on FY 2008 DHS grant program guidance. 

We identified a universe of 43 DHS preparedness grant programs 

and developed a relationship matrix to identify allowable funding 

activity outputs (e.g., planning, interoperable communication, 

equipment) associated with each program. We selected two 

funding outputs, planning and interoperable communications, and 

further reviewed the guidance for the 13 grant programs that 

funded one or both of those outputs to determine whether 

complementary or duplicative relationships exist among the 

multiple grant programs. 

We visited three states to understand the processes used to 

coordinate grant program activities at the state level to mitigate 

duplication among different DHS grant programs with similar 

funding activities. We selected the states based on their high level 

of FY 2008 funding: 

Efficacy of DHS Grant Programs 

Page 23 
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Appendix A 

Purpose, Scope, and Methodology 

Commonwealth of Pennsylvania: $126 million 

State of Washington: $92 million 

Commonwealth of Virginia: $69 million 

At the three states, we reviewed investment justifications and 

project proposals submitted in response to DHS preparedness 

grants. We met with homeland security coordinators, grant 

administrators, peer reviewers, and subject matter experts to gain 

an understanding of roles, responsibilities, and state application 

requirements. We also interviewed other relevant personnel to 

gain an understanding of the processes used to coordinate grant 

program activities at the state level. 

We conducted our audit from March to September 2009 at FEMA 

headquarters in Washington, DC; FEMA Region III in 

Philadelphia, PA; Transportation Security Administration in 

Arlington, VA; and state administrative agencies, fiduciary agents, 

and other state offices in Richmond, VA; Harrisburg, PA; and 

Camp Murray and Tacoma, WA. We performed our work 

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 on our audit 

objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our 

audit objectives. 

Efficacy of DHS Grant Programs 


Page 24 

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MEMORANDUM FOR: Anne L. Riclmrds

Assistant Inspector General for Audits

Oflice of Inspector GeneHiI

FROM: David 1. Kaufman c::::;: . ~~ J'U....

Director

Oflke of Policy and Program Analysis

SUBJECT: Comments on OIG Drdft Report, Efficacy ofDNS Gralll Programs

Thank you for the opportunity to review and comment on the Office of Inspector General's

(DIG's) subject draft audit report. As the Federal Emergency Management Agency (FEMA)

works toward refining its programs, the DIG's independent :malysis of program pcrfonnanee

greatly benefits our ability to continuously improve our activities. Technical comments have

becn provided under separate cover.

In general, it appears there is an assumption that all the preparedness grants have a similar

purpose. They may have a similar goal. enhancing preparedness, but the purpose of each grant

program is directed toward different SL'{;torS within the States (i.e. transit agencies, non-profit

entities, fire departments) and their Homeland Security/emergency management efforts.

The degree to which each grant program and the manner in which it is implemented is driven by

Conb'fcssional direction docs not appear to be completely understood nor evident in the draft

report. Starting with the instruction and mandates ofthe annual Appropriations Bill and

continuing through the drafting and ultimate release ofGrant Guidance, the work ofthe Grant

Programs Directorate is to carry out the direction of the Congress. Extensive vetting of program

guidance is conducted with FEMA and Department of Homeland Security (DHS) partners, the

Office of Management and Budget (OM B), and Congress. Additionally, we engage in

slgntlieant ellorts WIth eonslltuent groups to obtam fecdback and recommendations on

implementation of programs. Each program h(15 nuance5 thllt must be addressed throug.hout the

process.

As long as Congress authorizes and appropriates programs for singular purposes to specific

constituencies, FEMA is required to carry out thosc programs as mandated.

Appendix B 

Management Comments to the Draft Report 

Efficacy of DHS Grant Programs 
 

Page 25
 

Page 2

The following includes comments that were provided by the DHS Office of Infrastructure

Protection (IP), which shares responsibility with FEMA for the execution ofthe Buffer Zone

Protection Program, and is organized by the draft report's titled sections:

• Table I: Grant Program's Allowable Funding AClivilies

This table misrepresents the allowable funding activities ofthe Buffer ZOne Protection

Program (BZPP) and other grant programs by focusing on only two aspects (planning

and interoperable communications) that are common among the grants. The table is not

an accurate depiction ofthe allowable funding activities ofthe BZPP or other grant

programs. This provides an incomplete picture ofthe efficacy ofthe DHS Grant

Programs, which is the purpose ofthe repon. Ifthe table included all ofthe allowable

funding activities for each grant program, it would illustrate the many key differences

among the grant programs, reflecting the specific role of each. For example, the BZPP

allows local jurisdictions to purchase equipment for the purposes ofprotcction and

prevention, not only planning and interoperable communications.

• Applications are Reviewed Withoul Considering Other Grant Programs

FEMA and IP have taken steps to avoid duplication between the BZPP and other grant

programs. The BZPP requires that the State or local jurisdiction identify in the Buffer

ZOne Plan (BZP) and Vulnerability Reduction Purchasing Plan (VRPP) other funding

sources that are being leveraged to address recommended enhancements; how the

requested purchases support the achievement of goals and objectives from StatelUrban

Area homeland security strategies; how the equipment requests support the National

Priorities, specifically the implementation ofthe National Infrastructure Protection Plan

and Statewide critical infrastructure protection programs; and the DHS Target

Capabilities the proposed purchases support. To ensure grant programs are not funding

the same activities or purchases, the responsible jurisdiction is also required to

coordinate with any Urban Area Working Group, Regional Transit Security Working

Group, or Area Maritime Security Committee in their area. Additionally, the BZPP

funds are targeted to the first responders responsible for the protection ofthese specific

Critical Infrastructure and Key Resource (CIKR) assets, typically a local law

enforcement agency or department. No other grant programs specifically target the

unique vulnerabilities ofindividual CIKR assets and the CIKR protection resource needs

offirst responders responsible for protecting them.

• Figure 2: Use ofMultiple Grant Programsfor Similar Equipmem Requests

While all four ofthe grant programs cited in Figure 2 allow grant funds to be used to

purchase equipment from FEMA's Authorized Equipment List, the categories of

equipment authorized for purchase through each program differ. Without this

information, this Figure cannot provide a complete picture ofthe efficacy ofthe DHS

Grant Programs, which is the purpose ofthe report. BZPP purchases are limited to those

needed by State and local first responders to mitigate the vulnerabilities and equipment

and resource gaps identified during the development ofBZPs and reflected in VRPPs,

which identify the specific equipment needed by first responders to effectively protect

Appendix B 

Management Comments to the Draft Report 

Efficacy of DHS Grant Programs 
 

Page 26
 

Page 3

CIKR assets. This differs from allowable communications purchases made under other

larger grant programs, such as the State Homeland Security Grant Program, which can be

used to purchase Statewide interoperability systems.

• Separate Program Office Responsibilities Hamper Coordination

IP disagrees strongly with the draft report's statements on page 12 that, " ...the Buffer

Zone Protection Program is not coordinated with other programs...the Office of

Infrastructure Protection approves the requested equipment without coordinating with

FEMA for duplication with other grant programs." The coordination and collaboration

between FEMA and IP is a strong and crucial component ofthis program. The

coordination ofthe BZPP between IP and FEMA is described in a draft Memorandum of

Agreement (MOA) currently under review. With regard to grant duplication, as

previously discussed, in an effort to specifically combat duplication the BZPP requires

that the State or local jurisdiction identify in the BZP and VRPP other funding sources

that are being leveraged to address recommended enhancements; how the requested

purchases support the achievement ofgoals and objectives from StatelUrban Area

homeland security strategies; how the equipment requests support the National Priorities,

specifically the implementation ofthe National Infrastructure Protection Plan and

Statewide critical infrastructure protection programs; and the DHS Target Capabilities

the proposed purchases support. To ensure grant programs are not funding the same

activities or purchases the responsible jurisdiction is also required to coordinate with any

Urban Area Working Group, Regional Transit Security Working Group, or Area

Maritime Security Committee in their area.

• Investment Justification Templates

Most grants use a standard Investment Justification (IJ) Template which is a four page

document requiring the applicant to justify the award. For example, the IJ for the State

Homeland Security Program is little more than a checklist ofprevious funding with a

briefstrategy narrative (2,500 characters max).

The BZPP application requires applicants to create a Buffer Zone Plan (BZP), which is

much more than a typical grant application. The BZP is a strategic document developed

by local law enforcement and jurisdictions with the support ofDHS that assists State and

local law enforcement and other first responders in developing site-specific preventive

and protective measures that make it more difficult to successfully target and attack

critical infrastructure sites. It requires an on-site visit ofthe facility by local law

enforcement, collaborative planning meetings between local law enforcement and the

facility owner/operator, and may include specialized evaluations (e.g., vulnerability

assessments, blast modeling, assault planning) by DHS/IP CIKR protection subject

matter experts. Development ofthe BZP is an integral part ofthe BZPP, as its

development promotes and enhances coordination and collaboration between CIKR

facility owners/operators and the first responders responsible for protecting or responding

to the site, ensures that funds are applied directly to actual gaps in site prevention and

Appendix B 

Management Comments to the Draft Report 

Efficacy of DHS Grant Programs 
 

Page 27
 

Page 4

protection capabilities offirst responders, and serves as a formal planning docwnent for

both the facility and first responders.

While understanding that the BZP and VRPP process may be more involved and time

intensive than a standard IJ, the collaborative security planning that goes into the

development ofthe two docwnents is perhaps the most important aspect ofthe Program,

and provides DHS with the best visibility into the effect ofthe grants by ensuring they

address gaps identified during the BZP development process. The BZPs for each facility

are based on detailed assessments ofthe facility and a gap analysis ofthe local law

enforcement's capabilities. This assessment information leads the local law enforcement

to identify specific equipment or planning needed to fill those prevention and protection

capability gaps. No other grant programs have a comparable means of accurately

identifying and specifically targeting the unique vulnerabilities ofindividual CIKR assets

and the CIKR protection resource needs offirst responders responsible for protecting

them.

With respect to the draft report's three recommendations, FEMA concurs with all ofthe

recommendations. Specific comments on the recommendations are provided in our responses

below:

Recommendation 1: Identify preparedness grant programs that may overlap or duplicate other

programs and ensure the application and review processes for these programs are coordinated to

mitigate potential duplication and redundancy.

Response: FEMA concurs with this recommendation. FEMA has already undertaken an effort

to review existing grant programs and to look at ways to minimize report and application

burdens. In addition, FEMA is working closely with the Department to consolidate grant

programs where activities are allowable under multiple grants. However, some grant programs

are identified by name in annual Appropriations Acts, and FEMA has understood that Congress

attaches separate and distinct purposes for each, separate funding streams, and administrative

limitations (i.e. cost-share requirements, one year money vs. no year money, etc).

Also, the review process and timelines are driven by Congressional mandates for many ofthe

programs. Further, some programs are co-managed with other DHS components, such as

Customs and Border Protection, Transportation Security Administration, Office ofInfrastructure

Protection, and the United States Coast Guard, requiring FEMA to work closely with those

agencies to coordinate these processes. FEMA coordinates with these partners to conduct the

most efficient field and national reviews of applications, taking into account the different

structures in place in these agencies.

In some cases, legislation may hinder our ability to eliminate overlap among some programs. For

example, ferry systems are eligible to apply in both the Port and Transit Security Grant

Programs, although Grant Programs Directorate (GPD) mandates that applicants can only apply

Appendix B 

Management Comments to the Draft Report 

Efficacy of DHS Grant Programs 
 

Page 28
 

Page 5

in one or the other program, legislation requires FEMA to make the systems eligible for either

program.

In reference to the statement that the level ofdetail in grant applications/investment justifications

is insufficient, we hear the exact opposite from stakeholders regarding the level of detail in grant

applications and lJ submission requirements. Stakeholders tell us that the guidance needs to be

streamlined and the application/lJ submission process simplified.

Although States may not have a written grants strategy, nor are they required to do so, they do

have established methods to oversee the use of grant funds. The States and urban areas are also

required to have a Homeland Security Strategy and the expenditure ofgrant funds should support

the goals and objectives identified in the Strategy. Additionally, our monitoring provides the

opportunity to verify these State developed mechanisms are in place.

Recommendation 2: Document specific agency roles and responsibilities for cross-program

coordination of grant application and review processes and ensure internal DHS coordination is

in place. This may include establishing memorandums of agreement ifroles are outside the

Federal Emergency Management Agency.

Response: FEMA concurs with this recommendation. We believe the future implementation of

the Non Disaster (ND)-Grants system may mitigate some ofthe issues noted. For example, a

grantee's identifying information will not have to be entered into the system for subsequent

applications as the system will pre-populate certain fields ofthe application.

As noted in IP's comments on the Report, IP and FEMA have established specific roles and

responsibilities for coordination ofthe BZPP in a draft MOA that is still in the review process.

FEMA is also in the process of establishing MOAs with other components.

Currently, we must use (and require our grantees to use) a number of disparate systems from our

legacy organizations [Office ofJustice Programs for grants management system, FEMA

financial system, and a separate system for Assistance to Firefighters Grants (AFG)] to manage

billions ofdollars ofgrant funds and thousands of grant awards. Consequently, there is some

duplication and inefficiency. The Department, along with FEMA, is working on a Departmentwide grants management system that should mitigate some ofthe systems issues.

Finally, given the different requirements and specialization across FEMA's portfolio of grant

programs, we cannot use the same peer review panel for all grant programs. The panelists are

allowed to participate by their parent agency (whether it be Federal, State, or local) and they do

not have the ability to devote weeks and months to these processes. In addition, not all panelists

are qualified to review all applications. For example, an excellent panelist for AFG awards

might be a total misfit reviewing an application for a non-profit security grant.

Appendix B 

Management Comments to the Draft Report 

Efficacy of DHS Grant Programs 
 

Page 29
 

Page 6

Recommendation 3: Work with Congress and state grant administrators to identify

opportunities and implement actions to streamline and standardize multiple preparedness grant

program application processes.

Response: FEMA concurs with this recommendation. FEMA has robust interaction with

Congress, OMB, and numerous stakeholder communities. We routinely engage stakeholders in

soliciting their feedback and recommendations and incorporate those into our program guidance

and procedures as we deem they are beneficial to the overall program goals and in line with

Congressional and Departmental goals.

FEMA is currently standing up a Preparedness Task Force to be comprised of State, Tribal, local

and private sector experts who will be charged with evaluating the Agency's preparedness

efforts, including the structure and requirements ofits grant programs. We expect Task Force

recommendations on improving these and other activities by the end ofthe current fiscal year.

Thank you again for the opportunity to comment on this draft report and we look forward to

working with you on other issues as we both strive to improve FEMA.

Appendix B 

Management Comments to the Draft Report 

Efficacy of DHS Grant Programs 
 

Page 30
 

Appendix C 

Description of Grant Programs 

Homeland Security Grant Program 

The Homeland Security Grant Program includes four programs 

that fund activities to strengthen the Nation against risks associated 

with potential terrorist attacks. Funding priorities focus on three 

objectives: (1) measuring progress in achieving the National 

Preparedness Guidelines; (2) strengthening improvised explosive 

device attack deterrence, prevention, and protection capabilities; 

and (3) strengthening preparedness planning. Funding activities 

include preparedness planning, equipment acquisition (including 

interoperable communications), training, exercises, management, 

and administration. 

The four programs listed below are awarded under the Homeland 

Security Grant Program: 

State Homeland Security Program: Supports terrorism 

and catastrophic event preparedness by building and 

sustaining capabilities at the state and local levels through 

planning, organization, equipment, training, and exercise 

activities. This program helps states implement state 

homeland security strategies, the National Preparedness 

Guidelines, the National Incident Management System, and 

the National Response Framework. 

Urban Areas Security Initiative: Directly supports the 

national priority on expanding regional collaboration. This 

program addresses unique multidisciplinary planning, 

operations, equipment, training, and exercise needs of highrisk, high-density urban areas. 

Metropolitan Medical Response System: Assists 

designated metropolitan areas to sustain and further 

enhance regionally integrated all-hazards mass casualty 

preparedness and response capabilities. Funding is 

provided to designated localities to assist in maintaining 

and updating plans, delivering training, purchasing 

equipment and pharmaceuticals, and conducting exercises. 

Citizen Corps Program: Supports Citizen Corps councils 

with efforts to engage citizens in personal preparedness, 

exercises, ongoing volunteer programs, and surge capacity 

response; and to better prepare citizens to be fully aware, 

trained, and practiced on how to prevent, protect, mitigate, 

prepare for, and respond to all threats and hazards. This 

Efficacy of DHS Grant Programs 

Page 31 
Appendix C 

Description of Grant Programs 

program provides funding for planning, organizational, 

equipment, training, exercise, and personnel needs. 

Assistance to Firefighters Grant Program 

Provides resources directly to fire departments and emergency 

medical services organizations to obtain critically needed 

equipment, protective gear, emergency vehicles, training, and other 

resources to protect the public and emergency personnel from fire 

and related hazards. This program supports the following 

priorities: enhancing national capabilities, risk-based funding, and 

interoperability. 

Buffer Zone Protection Program 

Supports the development and implementation of Buffer Zone 

Plans for prevention and protection activities outside the perimeter 

of critical infrastructure and key resource sites. The program 

provides funding to states and territories for first responder 

equipment and planning to build security and risk-management 

capabilities to secure critical infrastructure from potential terrorist 

attacks. 

Commercial Equipment Direct Assistance Program 

Enhances regional response capabilities, mutual aid, and 

interoperable communications by providing technology and 

equipment, together with training and technical assistance required 

to operate that equipment, to public safety agencies in smaller 

jurisdictions and certain metropolitan areas to prevent, deter, and 

respond to terrorist attacks as identified in state homeland security 

strategies. 

Emergency Management Performance Grant Program 

Assists state and local governments in efforts to sustain and 

enhance the effectiveness of their all-hazards emergency 

management programs. This program provides funding to states 

and territories for emergency management planning, equipment, 

training, and exercise activities. 

Emergency Operations Center Grant Program 

Intended to improve emergency management and preparedness 

capabilities by supporting sustainable, secure, and interoperable 

emergency operations centers. This program provides funding for 

the construction or renovation of principal state, local, and tribal 

emergency operations centers. 

Efficacy of DHS Grant Programs 


Page 32 

Appendix C 

Description of Grant Programs 

Interoperable Emergency Communications Grant Program 

Provides planning, training, and exercise funding to states, 

territories, and local and tribal governments to carry out initiatives 

to improve interoperable emergency communication capabilities 

and support the implementation of statewide communication 

interoperability plans. 

Port Security Grant Program 

Provides funding to eligible ports for domain awareness including 

port access control identification, training, and exercises; and 

capabilities to prevent, detect, respond to, and recover from attacks 

involving improvised explosive devices and other nonconventional 

weapons. Program funding priorities focus on the highest risk port 

systems and regional security cooperation. 

Regional Catastrophic Preparedness Grant Program 

Supports the eight most urgent national planning scenarios as 

defined in the National Preparedness Guidelines. The program’s 

goal is an integrated planning system that provides for regional allhazards planning for catastrophic events and the development of 

necessary plans, protocols, and procedures to manage such an 

event. This program focuses on high-risk urban areas and 

surrounding regions where the impact will have the most 

significant effect on our Nation’s collective security and resilience. 

Funding priorities include developing enhanced regional plans and 

addressing shortcomings in jurisdiction plans to support the 

management of a catastrophic incident, creating regional planning 

processes, and linking operational and capabilities-based planning 

for resource allocation. 

Transit Security Grant Program 

Creates a risk-based effort for the protection of critical transit 

infrastructure from terrorism, major disasters, and other 

emergencies. Funding is provided to owners and operators of the 

Nation’s critical transit infrastructure, including rail, intracity bus, 

ferry systems, and Amtrak. Funding priorities include highest risk 

systems in the largest metropolitan areas, project quality and 

effectiveness, and regional security collaboration. Allowable 

expenses include planning, operational costs, equipment, training, 

and exercises. 

Efficacy of DHS Grant Programs 


Page 33 

Appendix D 

Major Contributors to This Report 

Michael Siviy, Director, Grants Management Division 

Christine Haynes, Audit Manager 

Kalimuddin Ahmad, Auditor 

Barry Cleveland, Program Analyst 

Kevin Donahue, Auditor 

David Lu, Program Analyst 

Sue Vernier, Auditor 

James Bess, Referencer 

Efficacy of DHS Grant Programs 
 

Page 34
 

Efficacy of DHS Grant Programs 
 

Page 35
 


Appendix E 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Under Secretary for Management 

Under Secretary for National Protection and Programs Directorate 

Assistant Secretary for Infrastructure Protection 

Chief Procurement Officer 

Federal Emergency Management Agency 

Administrator, Federal Emergency Management Agency 

Assistant Administrator, Grant Programs Directorate 

Federal Emergency Management Agency Audit Liaison 

Grant Programs Directorate Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

OIG HOTLINE 

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

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

The OIG seeks to protect the identity of each writer and caller.