FEMA Should Implement 

Consistent Joint Field 

Office Guidance 

September 27, 2016 

OIG-16-139-D 
 

 

 

 

 

DHS OIG HIGHLIGHTS
 

FEMA Should Implement Consistent

Joint Field Office Guidance
 

September 27, 2016 

Why We 

Did This 

Audit 

Time is of the essence in 

establishing a Joint Field Office 

(JFO) as the nexus of disaster 

response and recovery efforts. 

FEMA needs to implement 

consistent JFO selection 

guidance so its disaster 

response is effective, efficient 

and economical. This audit was 

conducted as a follow up to our 

prior report on the JFO 

Selection in New Jersey and as 

part of our 2015 disaster 

deployment efforts in Texas and 

South Carolina. 

What We 

Recommend 

The FEMA Associate 

Administrator, Response and 

Recovery (1) implement 

consistent JFO guidance; and 

(2) require FEMA regional 

officials to work with General 

Service Administration and 

requisite State officials to 

specify possible JFO locations to 

ensure timeliness response for 

future disasters. 

For Further 

Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

Since 2012, we have observed and reported on systemic 

challenges in FEMA’s JFO selection process. These 

challenges occurred, in part, because FEMA has not 

sufficiently implemented our prior audit recommendation to 

collaborate with the General Services Administration in 

selecting potential JFO sites prior to a forecasted disaster. 

In 2015, we identified regional implementation differences in 

the JFO selection process. During our 2015 Texas flood 

disaster Emergency Management Oversight Team (EMOT) 

deployment, we determined that FEMA Region VI did not 

implement a disaster pre-planning protocol that resulted in a 

more than $380,000 increase in JFO administrative costs 

and delayed the JFO opening by 17 days. The delayed JFO 

opening negatively impacted FEMA’s ability to rapidly equip 

and deploy disaster response personnel. In contrast, during 

our 2015 South Carolina EMOT deployment, we determined 

that FEMA Region IV JFO selection was efficient and 

effective. 

FEMA Response 

FEMA concurred with our recommendations. 

www.oig.dhs.gov OIG-16-139-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

September 27, 2016 

MEMORANDUM FOR: Elizabeth Zimmerman 

Associate Administrator, Response and Recovery 

Federal Emergency Management Agency 

~'M·~ FROM: Thomas M. Salmon 

Assistant Inspector General (OIG) 

Emergency Management Oversight 

SUBJECT: FEMA Should Implement Consistent Joint Field Office 

Selection Guidance 

For your action is our final report, FEMA Should Implement Consistent Joint 

Field Office Selection Guidance. We incorporated the formal comments provided 

by your office. 

The report contains two recommendations aimed at improving FEMA's disaster 

response. Your office concurred with both recommendations. Based on the 

information provided in your response to the draft report, we consider 

recommendations 1 and 2 resolved and open. Once your office has fully 

implemented the recommendations, please submit a formal closeout letter to 

us within 30 days so that we may close the recommendations. The 

memorandum should be accompanied by evidence of completion of agreedupon corrective actions. Please send your response or closure request to 

OIGEMOFollowup@oig.dhs.gov). 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

post the report on our website for public dissemination. 

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

Paul Wood, Director, National Capital Regional Office at (202) 254-4283. 

Attachment 

www.oig.dhs.gov OIG-16- 139-D 
 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

A Joint Field Office (JFO) is a temporary Federal coordination center for 

field-level incident management activities related to disaster response and 

recovery. For large events, it is important the JFO be located close to the 

impacted area for efficient and effective delivery of the mission and for 

coordination with State and local officials. 

When FEMA issues a mission assignment1, to acquire a JFO lease, it must 

ensure that it complies with 42 United States Code (USC) §§ 5170a, 5192 

and 44 Code of Federal Regulations (CFR) §§ 206.2(a)(17), 206.3 which 

direct Federal agencies to utilize their authorities and resources granted 

under Federal law in support of State, local, tribal, and territorial 

government assistance. 

FEMA issued two directives, FEMA Directive 125-2 and FEMA Directive 143-1 

to provide FEMA Regional managers the latitude to make pre-disaster 

declaration decisions. FEMA Directive 125-2 authorizes FEMA to issue a 

Federal Operational Support Mission Assignment prior to a disaster to prepare 

for Federal assistance when a declaration is reasonably likely and imminent. 

FEMA Directive 143-1 establishes policy and procedures for the acquisition of 

leases that support FEMA response efforts to Federal disaster declarations. 

Results of Audit 

Since 2012, we have observed and reported on FEMA’s systemic challenges in 

its JFO selection process. These challenges occurred, in part, because FEMA 

has not sufficiently implemented our prior audit recommendation to 

collaborate with the General Services Administration (GSA) in selecting 

potential JFO sites prior to a forecasted disaster. 

In 2015, we identified regional implementation differences in the JFO selection 

process. During our 2015 Texas flood disaster Emergency Management 

Oversight Team (EMOT) deployment, we determined that FEMA Region VI did 

not implement a pre-disaster planning protocol that resulted in more than 

$380,000 increase in JFO administrative costs and delayed the JFO opening by 

17 days. The delayed JFO opening negatively impacted FEMA’s ability to 

rapidly equip and deploy disaster response personnel. In contrast, during our 

1 A mission assignment is a work order issued by FEMA that, with or without reimbursement, 

directs another Federal agency to utilize its authorities and the resources granted to it under 

Federal law in support of State, local, tribal, and territorial government assistance. 

www.oig.dhs.gov 2 OIG-16-139-D 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

2015 South Carolina EMOT deployment, we determined that the FEMA Region 

IV JFO selection was efficient and effective. 

Prior Audits Show JFO Selection Guidance Inconsistently Implemented 

In August 2015, we issued an audit, FEMA’s Process for Selecting Joint Field 

Offices Needs Improvement, OIG-15-128-D, in which we recommended FEMA 

“[c]ollaborate with GSA to select a potential JFO location when a disaster is 

forecasted, as was Hurricane Sandy in New Jersey.” However, based on our 

recent EMOT deployments, we are unable to determine whether FEMA’s 

corrective actions were sufficiently implemented. For example, in 2016, we 

reported that FEMA faced challenges in its Texas JFO lease acquisition 

process. Conversely, our audit report—FEMA’s Initial Response to the Severe 

Storms and Flooding in South Carolina, OIG-16-53-D, noted that FEMA’s JFO 

selection was efficient and effective. Our assessments of these FEMA JFO 

selections demonstrate systemic challenges in implementing JFO selection 

guidance and ineffective implementation of pre-planning guidance. 

Ineffective Implementation of JFO Pre-Planning Guidance (DR 4223 TX) 

For example, in 2015, FEMA moved into its Texas Joint Field Office 17 

days after the Presidential disaster declaration. This time period was far in 

excess of the optimal 72-hour window outlined in the Joint Field Office 

Activation and Operations guidance. As a result, JFO administrative cost 

increased by more than $380,000 and FEMA’s ability to rapidly equip and 

deploy negatively affected disaster response personnel. 

Based on our analysis of FEMA’s guidance and interviews with FEMA and 

GSA officials, a key reason for the 17-day Texas JFO opening delay 

occurred because FEMA Region VI did not develop and implement an 

effective and efficient pre-disaster plan to acquire a lease. This lack of 

planning demonstrates that FEMA has not fully implemented guidance to 

provide for pre-disaster planning including procurement of a JFO lease 

when conditions are reasonably likely and imminent, but does not specify 

how FEMA officials should effectively execute that guidance. 

For instance, FEMA Directive 143-1 authorizes the FEMA Regional 

Administrator to search for a JFO, prior to a disaster declaration, under 

two conditions:— 

1. A JFO must be necessary. 

2. A JFO must support an efficient and timely response. 

In addition, according to FEMA Directive 125-2, “Disaster Relief Fund 

(DRF) Pre-Disaster Declaration (Surge) funding, authorizes FEMA to issue 

www.oig.dhs.gov 3 OIG-16-139-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

a Federal Operational Support Mission Assignment prior to a disaster to 

prepare for Federal assistance when a declaration is reasonably likely and 

imminent. GSA officials confirmed that they can deploy ahead of a 

presidential disaster declaration and assist a FEMA-led survey team to 

conduct a market survey of the commercial real estate market in 

anticipation of a JFO site lease. FEMA officials noted that they normally 

proceed with caution if a JFO lease is needed prior to a disaster, because 

they do not want to set up a false expectation of Federal assistance to a 

State. 

Although FEMA deployed an Incident Management Assistant Team to Texas on 

May 12, 2015, to assist in Texas’ initial incident response. We were unable to 

determine whether FEMA conducted enough pre-disaster planning to 

implement an effective response and recovery effort. Given the advanced 

warning of a large-scale disaster and the legitimate and immediate need for a 

JFO, we determined FEMA guidance does not provide for a sufficient and 

prompt JFO setup. 

Conclusion 

During our EMOT deployments, we observed that FEMA does not implement its 

JFO selection guidance in a consistent manner. If FEMA develops a disaster 

pre-planning protocol that includes potential strategies for JFO leasing, FEMA 

can respond in a more timely manner and ensure its disaster response is 

effective, efficient, and economical. 

Recommendations 

We recommend that the Federal Emergency Management Agency, 

Associate Administrator, Response and Recovery: 

Recommendation 1: Develop and implement consistent and specific JFO 

procedural guidance to facilitate a timely and successful joint Federalstate response and recovery operation. 

Recommendation 2: Require FEMA regional officials to develop a JFO 

selection strategy that includes working annually with General Services 

Administration and State governments to specify an acceptable selection of 

Primary Metropolitan Statistical Areas where a JFO could be located and 

determining the conditions needed for a timely opening of a JFO. 

www.oig.dhs.gov 4 OIG-16-139-D 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis
 

We discussed the results of this audit with FEMA officials during our 

audit and included their comments in this report, as appropriate. We 

provided a draft report to FEMA officials and held an exit conference on 

July 21, 2016. FEMA officials generally agreed with our findings. On 

August 26, 2016, FEMA provided its Management Response to our draft 

report. FEMA concurred with both recommendations and anticipates 

these recommendations will be resolved by June 30, 2017. 

The Office of Emergency Management Oversight’s major contributors to 

this report are Thomas Salmon, Assistant Inspector General, Emergency 

Management Oversight; Paul Wood, Director, National Capital Regional 

Office; Nigel R. Gardner, Audit Manager; D. Kaye McTighe, Emergency 

Management Oversight Operations Director; Judy Martinez, Emergency 

Management Oversight Team Coordinator; Dwight McClendon, Auditor; 

and Patricia Epperly, Program Analyst. 

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

contact Paul Wood, Director, National Capital Region Office 

(202) 254‐4283. 

Objective, Scope, and Methodology 

Our initial audit objective was to identify the opportunities and challenges with 

FEMA’s Joint Field Office lease acquisition process in Texas and to determine 

the most important areas on which FEMA should focus its efforts. We reviewed 

whether the JFO acquisition followed Federal guidelines and identified common 

themes between Emergency Management Oversight Team (EMOT) deployments 

conducted in Texas and South Carolina. As a result of our review of these 

deployments and to follow up on our JFO Section Process report in New Jersey, 

we adjusted the audit objective to identify FEMA’s systemic challenges in 

implementing a consistent JFO selection process. 

We interviewed Texas Department of Public Safety, Texas Division of 

Emergency Management; FEMA JFO officials and GSA Lease Contracting 

Officers. We observed operations at FEMA’s Initial Operation Facilities and 

JFO in Austin, Texas. We reviewed Federal guidance and lease contracts. 

We also notified our Office of Investigations to determine whether the 

contractors were debarred or whether there were any indications of other 

issues related to those contractors that would indicate fraud, waste, or 

abuse. Currently, there are no ongoing investigations of contractors 

associated with this audit. 

www.oig.dhs.gov 5 OIG-16-139-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We conducted this audit between June 2015 and August 2016 pursuant 

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

generally accepted government auditing standards. Those standards 

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

appropriate evidence to provide a reasonable basis for our findings and 

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

obtained provides a reasonable basis for our findings and conclusions 

based upon our audit objective. We did not assess the adequacy of FEMA’s 

internal controls applicable to disaster response because it was not 

necessary to accomplish our audit objective. 

www.oig.dhs.gov 6 OIG-16-139-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

FEMA Comments to the Draft Report 

www.oig.dhs.gov 7 OIG-16-139-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

www.oig.dhs.gov 8 OIG-16-139-D 
 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chiefs of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Federal Emergency Management Agency 

Administrator 

Chief of Staff 

Associate Administrator, Response and Recovery 

Chief Financial Officer 

Deputy Chief Financial Officer 

Associate Administrator for Policy, Program Analysis and International 

Affairs 

Director, Risk Management and Compliance 

FEMA GAO/OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

www.oig.dhs.gov 9 OIG-16-139-D 
 

 

 

 

 

 

ADDITIONAL INFORMATION AND COPIES 

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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 

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"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