Department of Homeland Security
 

North Carolina’s Management of Homeland 


Security Program Grants Awarded During 


Fiscal Years 2008 Through 2010
 

OIG-13-74 April 2013
 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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

APR 16 2013 

 

MEMORANDUM FOR: David J. Kaufman 

Associate Administrator 

Policy, Program Analysis and International Affairs 

Federal Emergency Management Agency 

FROM: ards 

pector General for Audits 

Anne L. Rich

Assistant Ins

SUBJECT: North Carolina’s Management of Homeland Security 

Program Grants Awarded During Fiscal Years 2008 

Through 2010 

Attached for your action is our final report, North Carolina’s Management of Homeland 

Security Program Grants Awarded During Fiscal Years 2008 Through 2010. We 

incorporated the formal comments from the Associate Administrator for Policy, 

Program Analysis and International Affairs in the final report. 

The report contains eight recommendations to strengthen program management, 

performance, and oversight. Your office concurred with all eight recommendations. 

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

recommendations open and resolved. Once your office has fully implemented the 

recommendations, please submit a formal closeout letter to us within 30 days so that 

we may close the recommendations. The memorandum should be accompanied by 

evidence of completion of agreed-upon corrective actions and of the disposition of any 

monetary amounts. 

Consistent with our responsibility under the Inspector General Act, we are providing 

copies of our report to appropriate congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will post 

the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Mark Bell, Deputy Assistant 

Inspector General for Audits, at (202) 254-4100. 

Attachment
 

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


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


Results of Audit ................................................................................................................... 3 


State and UASI Homeland Security Strategies Need Improvement ....................... 3 


Recommendations .................................................................................................. 6 


Management Comments and OIG Analysis ........................................................... 6 


Improved Compliance with Grant Program Requirements Needed ...................... 7 


Recommendations ................................................................................................ 12 


Management Comments and OIG Analysis.......................................................... 12 


 

Performance Measures Have Not Been Developed ............................................. 15
 

Recommendation .................................................................................................. 16 


Management Comments and OIG Analysis.......................................................... 16 


Appendixes 

Appendix A: Objectives, Scope, and Methodology ........................................... 18 


Appendix B: Management Comments to the Draft Report .............................. 21 


Appendix C: Homeland Security Grant Program ............................................... 25 


Appendix D: North Carolina State Emergency Response Commission –
 

Participating State and Local Agencies ........................................ 26 
 

Appendix E: Major Contributors to This Report ................................................ 27 


Appendix F: Report Distribution ........................................................................ 28 


 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Abbreviations 

CFR Code of Federal Regulations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

FY fiscal year 

GPD Grant Programs Directorate 

HSGP Homeland Security Grant Program 

MOA memorandum of agreement 

NCEM North Carolina Division of Emergency Management 

OIG Office of Inspector General 

SHSP State Homeland Security Program 

UASI Urban Areas Security Initiative 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary 

Public Law 110-53, Implementing Recommendations of the 9/11 Commission Act of 

2007, requires the Department of Homeland Security (DHS) Office of Inspector General 

(OIG) to audit individual States’ management of State Homeland Security Program and 

Urban Areas Security Initiative grants. This report responds to the reporting 

requirement for the State of North Carolina, including the Charlotte Urban Area. 

The objectives of the audit were to determine whether the State of North Carolina 

distributed and spent State Homeland Security Program and Urban Area Security 

Initiative grant funds (1) effectively and efficiently, and (2) in compliance with applicable 

Federal laws and regulations, as well as with DHS guidelines governing the use of such 

funding. We also addressed the extent to which funds enhanced the State of North 

Carolina’s and the Charlotte Urban Area’s ability to prevent, prepare for, protect 

against, and respond to natural disasters, acts of terrorism, and other manmade 

disasters. The State of North Carolina received grant awards of approximately 

$61 million in State Homeland Security Program and Urban Areas Security Initiative 

grant funds for fiscal years 2008 through 2010. 

In most instances, the North Carolina Division of Emergency Management administered 

its grant programs in compliance with requirements in Federal grant guidance and 

regulations and DHS guidelines. Grant funds were spent on allowable items and 

activities, and there were adequate controls over the approval of expenditures and 

reimbursement of funds. 

However, the State needs to improve and update the State and Urban Areas Security 

Initiative Homeland Security Strategies, as well as the Charlotte Urban Area’s risk 

assessment; comply with grant program requirements; and enhance its performance 

measures. 

We made eight recommendations to the Federal Emergency Management Agency 

(FEMA), the State of North Carolina, and the Charlotte Urban Area, which if 

implemented, should strengthen program management, performance, and oversight. 

FEMA concurred with all eight recommendations. 

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Department of Homeland Security 

Background 

DHS provides Federal funding through the Homeland Security Grant Program (HSGP) to 

enhance the ability of State, territory, local, and tribal governments to prevent, protect, 

respond to, and recover from terrorist attacks and other disasters. FEMA administers 

the HSGP, which is an important part of the administration’s larger, coordinated effort 

to strengthen homeland security preparedness. Appendix C contains a detailed 

description of the grant programs that constitute the HSGP. 

The North Carolina Department of Crime Control and Public Safety was the State 

Administrative Agency responsible for State and Federal oversight of the HSGP. The 

North Carolina Division of Emergency Management (NCEM), a division of the State 

Administrative Agency, was the acting Administrating Agency. NCEM also develops the 

State Homeland Security Strategy (State strategy) and coordinates its day-to-day 

implementation. The Secretary of the Department of Public Safety, formerly known as 

Department of Crime Control and Public Safety, represents the State's law enforcement 

and emergency response community in the Governor's cabinet. In North Carolina, a 

program management team evaluates the Urban Areas Security Initiative (UASI) 

Homeland Security Strategy (UASI strategy) and updates it as needed. 

For fiscal years (FYs) 2008 through 2010, the State received awards totaling 

approximately $65 million in HSGP funds, including about $47 million for the State 

Homeland Security Program (SHSP) and about $14 million for the UASI. Appendix A 

contains details on the objectives, scope, and methodology for this audit. 

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Department of Homeland Security 

Results of Audit 

In most instances, NCEM administered its grant programs in compliance with 

requirements in Federal grant guidance, applicable regulations, and DHS guidelines. For 

example, the State developed procedures and processes to administer its grant 

programs, and it had internal controls to approve and reimburse subgrantees for 

expenditures. NCEM and the Charlotte Urban Area also developed State and UASI 

strategies that included goals and objectives aligned with the four mission areas and 

eight National Priorities established by DHS. In addition, NCEM used a comprehensive 

web-based grants management system to track, process, and report grant activity. 

However, the State needs to improve and update the State and UASI Homeland Security 

Strategies, as well as the Charlotte Urban Area’s risk assessment; comply with grant 

program requirements; and enhance its performance measures. 

FEMA and North Carolina did not provide sufficient guidance and oversight of SHSP and 

UASI grant programs. Therefore, the State’s ability to carry out the programs as 

prescribed was hindered, subgrantees had inadequate internal controls, and the State 

did not effectively measure its capabilities and emergency preparedness. 

State and UASI Homeland Security Strategies Need Improvement 

North Carolina’s State and UASI strategies for FYs 2008 through 2010 included 

goals and objectives that were aligned with DHS priorities. However, the 

objectives in the State and Charlotte Urban Area strategies did not meet all DHS 

requirements, and FEMA had not received or approved the most up-to-date 

State strategy. In addition, the Charlotte Urban Area did not update its risk 

assessment. 

State Homeland Security Strategy 

NCEM used a State strategy, which it developed in 2006 and updated in October 

2007 and which FEMA approved, as the basis for the grant program for FYs 2007 

through 2009. The goals and objectives of this State strategy aligned with DHS 

National Preparedness Guidelines, dated September 2007, including the Target 

Capabilities List, as well as Department of Homeland Security State and Urban 

Area Homeland Security Strategy Guidance on Aligning Strategies with the 

National Preparedness Goal, dated July 22, 2005. The primary focus of this State 

strategy was to prevent, protect, respond to, and recover from acts of terrorism. 

NCEM viewed it as an evolving document that it would continually update to suit 

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Department of Homeland Security 

changing risks and capabilities. NCEM updated the State strategy in 2010 and 

used it to guide the program through FY 2011. The updated strategy identified 

16 priorities in the State’s capabilities, and it better aligned with the National 

Preparedness Goal and Priorities, focusing on improving training and staff 

development to enhance planning initiatives, protecting infrastructure, ensuring 

equipment availability, and performing exercises to improve response 

capabilities. According to State officials, NCEM used feedback from various 

stakeholders to develop and enhance its regional capability and capacity to 

prevent, protect, respond to, and recover from catastrophic events. 

Both State strategies met DHS requirements by addressing the four DHS mission 

areas (prevent, protect, respond, and recover) and the eight National Priorities. 

However, the strategies’ goals and objectives were not specific, measurable, or 

results-oriented. 

According to Department of Homeland Security State and Urban Area Homeland 

Security Strategy Guidance on Aligning Strategies with the National Preparedness 

Goals, objectives should be— 

•	 Specific, detailed, particular, and focused – help to identify what is to be 

achieved and accomplished; 

•	 Measurable – be quantifiable, providing a standard for comparison, and 

identifying a specific achievable result; 

•	 Achievable – not beyond a State, region, jurisdiction, or locality; 

•	 Results-oriented – identify a specific outcome; and 

•	 Time-limited – have a target achievement date. 

FEMA did not provide sufficient guidance to ensure that the strategies met these 

requirements. The 2007–2009 State strategy included 13 goals and 46 objectives. 

Our analysis of this FEMA-approved strategy showed that some objectives were 

not specific, measurable, or results-oriented. Table 1 shows deficiencies in the 

State strategy’s objectives. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1. Deficiencies in North Carolina’s Homeland Security Strategy’s Objectives 

Goal Objective Deficiency 

1. Implement 

appropriate 

prophylaxis and 

vaccination 

strategies in a 

timely manner 

upon the onset of 

an event, with an 

emphasis on the 

prevention, 

treatment, and 

containment of the 

disease 

1. Develop and 

foster interagency 

cooperation and 

collaboration for the 

delivery of mass 

prophylaxis 

The objective is not: 

• Specific 

• Measurable 

• Results-oriented 

4. Develop an 3. Enhance the The objective is not: 

overarching capabilities of law • Specific 

statewide enforcement • Measurable 

preparedness and personnel to • Results-oriented 

participation recognize indicators 

program of potential terrorist 

planning activities 

11. Enhance 5. Develop a 3-year The objective is not: 

incident training and exercise • Specific 

management program that • Measurable 

preparedness involves State, 

regional, and local 

stakeholders 

• Results-oriented 

12. Prevent and 

eradicate threats to 

food and agriculture 

safety and protect 

public and animal 

health 

1. Develop and 

maintain plans, 

procedures, 

programs, and 

systems 

The objective is not: 

• Specific 

• Measurable 

• Results-oriented 

Source: DHS OIG Analysis of the State Homeland Security Strategy (2007–2009). 

Although all States are to submit their strategies to FEMA for approval, according 

to a FEMA official, as of August 2012, the agency had not received the 2010 State 

strategy from NCEM. 

Charlotte Urban Area Security Initiative Planning 

The Charlotte Urban Area UASI strategy’s goals were not specific or resultsoriented, and they did not include bases to measure performance. FEMA did not 

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provide sufficient guidance to ensure that the strategy met these requirements. 

In addition, the Charlotte Urban Area did not conduct annual risk assessments to 

ensure that it allocated resources to fund its most critical preparedness needs. 

The risk assessment is used to identify, categorize, and prioritize capability 

needs. According to the 2007 DHS National Preparedness Guidelines, a riskbased approach to preparedness is necessary to develop emergency operations 

plans. Although it conducted a risk assessment for FYs 2006 and 2007, the 

Charlotte Urban Area did not update its assessment during FY 2008 through 

FY 2010 to reevaluate threats, risks, and vulnerabilities. Instead, it relied on the 

State’s regional assessment to determine its investments. 

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate: 

Recommendation #1: 

Assist NCEM and the City of Charlotte UASI to develop a Homeland Security 

Strategy that includes specific, measurable, achievable, results-oriented, and 

time-limited objectives. 

Recommendation #2: 

Require the City of Charlotte UASI to conduct risk assessments to determine 

areas of vulnerability for major disasters caused by either terrorism or natural 

events. 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #1 

FEMA concurred with this recommendation. The Assistant Administrator of the 

Grant Programs Directorate (GPD) shall require NCEM and the Charlotte Urban 

Area to update their respective Homeland Security Strategies to ensure that they 

include measurable target levels of performance; objectives that are specific, 

measurable, achievable, results-oriented, and time-limited; and an appropriate 

evaluation. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 1. This 

recommendation is open and resolved pending evaluation of revised Homeland 

Security Strategies from NCEM and the Charlotte Urban Area. According to 

FEMA, corrective actions will be implemented upon completion, submission, and 

review of strategy revisions. Revisions to the strategies must be submitted to 

FEMA no later than 6 months after issuance of OIG’s final report. 

FEMA’s Response to Recommendation #2 

FEMA concurred with this recommendation. FEMA's National Preparedness 

Directorate developed processes to measure core capabilities in accordance with 

the National Preparedness Goal pursuant to Presidential Policy Directive/ PPD-8: 

National Preparedness. The Charlotte Urban Area completed the Threat and 

Hazard Identification and Risk Assessment and submitted it to FEMA. The 

assessment will be used to create a baseline and targets for FY 2013 and beyond. 

FEMA's National Preparedness Directorate also redesigned the State 

Preparedness Report to help States demonstrate and track preparedness 

improvement over time. 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 2. This 

recommendation is open and resolved pending FEMA’s evaluation of the 

Charlotte Urban Area’s Threat and Hazard Identification and Risk Assessment. 

Improved Compliance With Grant Program Requirements Needed 

NCEM’s implementation of the SHSP and UASI did not always comply with 

established guidelines and procedures. Specifically, NCEM did not always 

obligate grants in a timely manner. In addition, it did not ensure that subgrantees 

comply with inventory management requirements for grant-funded equipment, 

submit timely cost reports, and maintain award letters in grant files as required. 

These deficiencies were a result of NCEM not following established procedures, 

conflicting procedures, and in some cases, no procedures. 

Grant Obligation 

In most cases, NCEM did not obligate SHSP funds within 45 days as stipulated in 

FEMA program guidance. According to NCEM officials, the lengthy process for 

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Department of Homeland Security 

obligating funds caused the delays. Consequently, subgrantees had less time to 

spend the grant funds and react to problems they may have experienced at the 

end of the grant award period. Therefore, the State Administrative Agency 

might have had to request extensions to the grant agreement period. 

FEMA Homeland Security Grant Program Guidance requires the State 

Administrative Agency to obligate HSGP funds within 45 days of FEMA’s award 

date. This obligation includes the following requirements: 

•	 There must be some action to establish a firm commitment on the part of 

the awarding entity. 

•	 The action must be unconditional (i.e., no contingencies for availability of 

funds) on the part of the awarding entity. 

•	 There must be documentary evidence of the commitment. 

•	 The award terms must be communicated to the official grantee. 

NCEM established a process to distribute money to local jurisdictions using 

memorandums of agreement (MOAs). According to the Fiscal Manager, 

executed MOAs establish the State’s firm commitment and communicate the 

award terms to the subgrantees. This documentary evidence must exist before 

an account can be established for the subgrantee. However, an NCEM official 

explained that it was difficult to obtain all signatures necessary to execute 

MOAs, and thus, this part of the process can be lengthy. In addition, if there 

were personnel changes involving MOA signatures before NCEM obtained all 

signatures, the process had to be started again. 

Our review of 27 SHSP grants to subgrantees during FYs 2008 and 2009 showed 

25 instances in which NCEM did not promptly obligate grant funds to subgrantees. 

Table 2 shows grants that took the longest time to obligate in this time period. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2. Longest Number of Days to Obligate Subgrantee Awards – FYs 2008–2009 

Subgrantee MOA # 

State 

Agreement 

Date 

Obligation 

Date 

Number of Days 

State Took To 

Obligate 

Asheville Police Department 08-1112 8/25/2008 1/22/2010 515 

Buncombe County 

Emergency Management 

08-1107 8/25/2008 11/5/2009 437 

Forsyth Emergency 

Management Services 

08-1083 8/25/2008 5/5/2009 253 

09-1002 8/21/2009 11/30/2009 101 

Rockingham County 

08-1080 8/25/2008 3/30/2009 217 

09-1004 8/21/2009 4/21/2010 243 

NC State Highway Patrol 09-1047 8/21/2009 12/29/2009 130 

Asheville Fire Department 09-1020 8/21/2009 2/18/2010 181 

Source: DHS OIG analysis. 

According to NCEM, the office has improved its timeliness in obligating funds to 

the subgrantees. 

Inventory Management Controls 

Subgrantees did not always ensure that there were adequate internal controls to 

safeguard equipment and comply with requirements for grant-funded property. 

Specifically, subgrantees did not maintain inventory records that included 

required information, did not always have inventory records, and did not always 

mark equipment as required. 

Inventory Records 

Not all local subgrantees maintained inventory records with required 

information. Of the 13 subgrantee sites we visited, 4 subgrantees’ inventory 

records did not contain all required information such as serial numbers, 

acquisition dates, or location of property. Consequently, local subgrantees’ 

inventory records did not comply with the Code of Federal Regulations (CFR) 

44 CFR § 13.32(d), Management requirements, which includes the following 

minimum requirements for grant recipients managing grant-funded equipment: 

Property records must be maintained that include a description of the 

property, a serial number or other identification number, the source of 

property, who holds title, the acquisition date, cost of the property, 

percentage of Federal participation in the cost of the property, the 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

location, use and condition of the property, and any ultimate disposition 

data including the date of disposal and sale price of the property. 

Table 3 shows inventory record compliance issues noted during our audit. 

Table 3. State of North Carolina SHSP and UASI Inventory Record Compliance Issues 

Subgrantee Compliance Issue 

44 CFR 13.32(d)(1) 

Value of Items Tested 

Buncombe County 

Emergency Management 

Inventory list did not include the 

source of the property. 

$124,288 

Greensboro No inventory list was provided. $171,982 

Greenville Inventory list did not include the 

location of the property. 

$66,154 

Rockingham County No inventory list was provided. $105,546 

NC State Highway Patrol Inventory list did not include the 

acquisition date and the use and 

condition of the property. 

$1,546,300 

Thomasville Urban Search 

and Rescue # 5 

No inventory list was provided. $39,187 

Charlotte Urban Area Inventory list did not include the 

acquisition date and the use and 

condition of the property. 

$3,459,347 

Total $5,512,804 

Source: DHS OIG analysis. 

In addition, 3 of 13 subgrantees did not maintain inventory records, which may 

have been a result of conflicting guidance. According to the CFR, grant recipients 

must take a physical inventory of grant-funded property and reconcile the results 

with property records at least once every 2 years. However, according to the 

NCEM MOAs, subgrantees are to provide an inventory list to the NCEM 

Homeland Security Branch only upon project completion. Not having proper 

inventory records weakens NCEM’s ability to manage and account for grantfunded equipment, and could lead to fraud, waste, and abuse. 

Marking Equipment 

Of the 13 subgrantees reviewed, 4 from Thomasville, Greenville, Greensboro, 

and the Charlotte Urban Area did not always properly mark equipment that they 

purchased with HSGP funds. According to the FY 2008 Grant Award Agreement 

between FEMA and North Carolina and the NCEM MOAs for FY 2009 and 

FY 2010, when practicable, grantees must prominently mark any equipment 

purchased with grant funding with “Purchased with funds provided by the U.S. 

Department of Homeland Security.” Officials said that they were not aware of 

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Department of Homeland Security 

this requirement in the FY 2009 and FY 2010 MOAs. In addition, Charlotte Urban 

Area officials said that they were awaiting guidance from NCEM. If subgrantees 

do not properly mark equipment, it may not be possible to identify equipment 

purchased with grant funds during required physical inventories. 

Cost Reports 

The Charlotte Urban Area did not submit an FY 2008 cost report for $2.6 million 

in expenditures incurred between April 2009 and December 2011 until April 

2012. Although subgrantees are to submit cost reports requesting 

reimbursement for expenditures as they incur costs, Charlotte incurred costs for 

more than 2 years before submitting its report. As a result, NCEM may not have 

been able to conduct a thorough review of Charlotte’s expenses over this time 

period. Further, overcharges could have gone undetected. According to NCEM 

officials, they discussed this issue with the Charlotte Urban Area, but it 

continued to hold cost reports for several months before submission. 

According to the FY 2008 Homeland Security Grant Program Guidance and 

Application Kit, FEMA will not pay funds in a lump sum, but rather will disburse 

them over time as project costs are incurred. However, for FYs 2009 and 2010, 

FEMA did not include this disbursement requirement in the grant program 

guidance. 

Grant Award Letters 

Subgrantees did not always maintain grant award letters in grant files as 

required. Some subgrantees were not aware of this requirement because not all 

MOAs included information on file documentation. Further, the NCEM 

Homeland Security Branch Grant Management Standard Operating Guide, 

updated March 2010, includes required subgrantee file documentation 

information in three places, but the grant award letter is mentioned in only one 

location. The guide should be clear and consistent throughout when mentioning 

subgrantee file documentation. The grant award letter should be mentioned in 

all three places not just one location. During site visits, four local jurisdictions 

could not provide us with the signed award letters. Two locations had MOAs 

that did not include information on the grant award letter requirement, but the 

other two MOAs included the requirement. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, require the North Carolina Division of Emergency Management to: 

Recommendation #3: 

Improve the efficiency of its process to obligate subgrantee awards within the 

required time period. 

Recommendation #4: 

Ensure that subgrantees comply with inventory requirements in the Code of 

Federal Regulations. 

Recommendation #5: 

Ensure that, where practicable, subgrantees and the Charlotte Urban Area mark 

purchases made with Department of Homeland Security funds with “Purchased 

with funds provided by the U.S. Department of Homeland Security.” 

Recommendation #6: 

Ensure that the Charlotte Urban Area submits cost reports as expenditures are 

incurred. 

We recommend that the North Carolina Division of Emergency Management: 

Recommendation #7: 

Ensure that its standard operating procedures and memorandums of agreement 

with subgrantees include clear guidance on required grant file documentation. 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #3 

FEMA concurred with this recommendation. The Assistant Administrator of GPD 

shall require NCEM to assess and streamline, when possible, processes and 

procedures for obligating funds to subgrantees. 

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Department of Homeland Security 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 3. This 

recommendation is open and resolved pending evaluation of the results of 

NCEM’s assessment and the steps it may take to expedite the obligation of funds 

to subgrantees. NCEM shall report the results of its assessment and these 

potential steps to FEMA no later than 90 days after issuance of OIG’s final report. 

FEMA’s Response to Recommendation #4 

FEMA concurred with this recommendation. The Assistant Administrator of GPD 

shall require NCEM to submit written policies and procedures addressing the 

requirements in 44 CFR 13.32(d) and any internal guidelines, as well as 

documentation detailing how NCEM will correct the deficiencies outlined in the 

final audit report and more effectively communicate requirements to 

subgrantees. 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 4. This 

recommendation is open and resolved pending evaluation of written policies and 

procedures addressing the requirements in 44 CFR 13.32(d) and any internal 

guidelines, as well as documentation detailing how NCEM will correct the 

deficiencies and more effectively communicate requirements to subgrantees. 

FEMA stated that within 90 days of issuance of OIG’s final report, NCEM shall 

submit to FEMA the written policies and procedures, as well as any internal 

guidelines and documentation detailing how it will correct the deficiencies. 

FEMA’s Response to Recommendation #5 

FEMA concurred with this recommendation and submitted a consolidated 

response to recommendations 5, 6, and 7. The Assistant Administrator of GPD 

shall require NCEM to update its Homeland Security Branch Management 

Standard Operating Guide to comply with all Federal and State requirements, 

including— 

•	 Guidance outlining appropriate documentation to include in a grant file; 

•	 Guidance regarding terms and conditions for each subaward agreement; 

•	 Standard operating procedures for equipment use and management, 

including the marking of equipment; and 

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Department of Homeland Security 

• Reporting requirements. 

The Assistant Administrator shall also require NCEM to develop a communications 

plan for the updated standard operating guide that includes subgrantee grant 

management training or workshops. 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 5. This 

recommendation is open and resolved pending evaluation of the updated 

Homeland Security Branch Management Standard Operating Guide and its 

compliance with all Federal and State requirements, as well as a communications 

plan that includes training or workshops to be implemented. FEMA stated that 

within 90 days of issuance of OIG’s final report, FEMA will require NCEM to 

update its guide and develop a communications plan. 

FEMA’s Response to Recommendation #6 

FEMA concurred with this recommendation and submitted a consolidated 

response for recommendations 5, 6, and 7 (see above). 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 6. This 

recommendation is open and resolved pending evaluation of the updated 

Homeland Security Branch Management Standard Operating Guide and its 

compliance with all Federal and State requirements, as well as a communications 

plan that includes training or workshops to be implemented. FEMA stated that 

within 90 days of issuance of OIG’s final report, FEMA will require NCEM to 

update its guide and develop a communications plan. 

FEMA’s Response to Recommendation #7 

FEMA concurred with this recommendation and submitted a consolidated 

response for recommendations 5, 6, and 7 (see above). 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 7. This 

recommendation is open and resolved pending evaluation of the updated 

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Department of Homeland Security 

Homeland Security Branch Management Standard Operating Guide and its 

compliance with all Federal and State requirements, as well as a communications 

plan that includes training or workshops to be implemented. FEMA stated that 

within 90 days of issuance of OIG’s final report, FEMA will require NCEM to 

update its guide and develop a communications plan. 

Performance Measures Have Not Been Developed 

The State of North Carolina did not develop performance measures to evaluate 

its ability to respond to an emergency caused by a natural disaster or terrorism, 

and it could not demonstrate specific improvements and measurable 

accomplishments of SHSP- and UASI-funded projects for FYs 2008 through 2010. 

According to the Department of Homeland Security State and Urban Area 

Homeland Security Strategy Guidance on Aligning Strategies with the National 

Preparedness Goal, “an objective sets a tangible and measurable target level of 

performance over time against which an actual achievement can be compared, 

including a goal expressed as a quantitative standard, value, or rate.” However, 

the goals and objectives in NCEM’s State strategy did not include bases for 

measuring improvements in its preparedness and response capabilities. 

According to the State, it measured its performance through— 

•	 Surveys of the progress in accomplishing implemented objectives; 

•	 Biannual Strategy Implementation Reports on the status of grant-funded 

projects; and 

•	 The annual State Preparedness Report, which assessed project completion. 

NCEM asserted that it measured its progress toward achieving its goals and 

objectives through Biannual Strategy Implementation Reports and State 

Preparedness Reports. Although the information in the State Preparedness 

Reports was linked with the State strategy’s goals and objectives, we could not 

verify how the State obtained the information in these reports. Further, these 

surveys and reports included information on the financial status and completion 

of projects, but did not measure whether the State had met its strategic goals 

and objectives and improved its disaster preparedness and response. 

In addition, the Charlotte Urban Area did not have a process to track and 

measure improvements in preparedness. Officials said that, as needed, they 

conducted informal self-assessments comparing their capabilities with the 

capabilities in the FEMA National Incident Management System. The National 

www.oig.dhs.gov 15	 OIG-13-74 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Incident Management System provides a framework for all jurisdictions to work 

together to manage domestic incidents, and States and urban areas are asked to 

show how their strategic goals and objectives support implementation of this 

system. Although Charlotte Urban Area officials said that they conducted selfassessments to evaluate progress, they did not document these efforts. 

Without the ability to measure progress toward meeting goals and objectives, as 

well as a system to collect objective, results-oriented data, NCEM and the 

Charlotte Urban Area did not have a basis to determine how their grant 

expenditures enhanced preparedness and response capabilities. According to 

NCEM and the Charlotte Urban Area, they did not receive guidance from FEMA 

on how to measure these improvements. 

Recommendation 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, require the North Carolina Division of Emergency Management and 

the Charlotte Urban Area to: 

Recommendation #8: 

Establish performance measures to determine whether goals and objectives in 

their respective strategies have been met and whether they have improved their 

capabilities in disaster response and preparedness. 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #8 

FEMA concurred with this recommendation. FEMA's National Preparedness 

Directorate developed processes to measure core capabilities in accordance with 

the National Preparedness Goal pursuant to Presidential Policy Directive/ PPD-8: 

National Preparedness. The State completed the Threat and Hazard Identification 

and Risk Assessment and submitted it to FEMA. The assessment will be used to 

create a baseline and targets for FY 2013 and beyond. FEMA's National 

Preparedness Directorate also redesigned the State Preparedness Report to help 

States demonstrate and track preparedness improvement over time. 

www.oig.dhs.gov 16 OIG-13-74 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Analysis 

We consider FEMA’s actions responsive to the intent of recommendation 8. This 

recommendation is open and resolved pending evaluation of the State's 

compliance with these requirements. 

www.oig.dhs.gov 17 OIG-13-74 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

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

established by the Homeland Security Act of 2002 (Public Law 107-296) by amendment 

to the Inspector General Act of 1978. 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. 

The audit objective was to determine whether the State of North Carolina distributed 

and spent SHSP and UASI grant funds effectively and efficiently and in compliance with 

laws, regulations, and guidance. In addition, the audit goal was to determine the extent 

to which the State measured improvements in its ability to prevent, prepare for, protect 

against, and respond to natural disasters, acts of terrorism, and other manmade disasters. 

The HSGP and its five interrelated grant programs fund a range of preparedness 

activities, including planning, organization, equipment, training, exercises, and 

management and administration. We reviewed only SHSP and UASI funding of 

equipment and programs for compliance. Appendix C contains additional information 

on these grant programs. 

The scope of the audit included the following: 

North Carolina Homeland Security Grant Program Awards 

FYs 2008 Through 2010 

Program FY 2008 FY 2009 FY 2010 Total 

State Homeland 

Security Program $16,280,000 $15,739,000 $15,419,662 $47,438,662 

Urban Areas 

Security Initiative $4,821,000 $4,580,000 $4,583,712 $13,984,712 

Subtotal $21,101,000 $20,319,000 $20,003,374 $61,423,374 

Source: GPD, FEMA. 

The audit methodology included interviews with FEMA and State Administrative Agency 

representatives, the urban area that received grants, and various subgrantee locations. 

To achieve our audit objective, we analyzed data, reviewed documentation, and 

interviewed the key local officials directly involved in the management and 

administration of North Carolina’s HSGP. We conducted site visits and held discussions 

with appropriate officials from selected State agencies, the Charlotte Urban Area, and 

www.oig.dhs.gov 18 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

local jurisdictions to determine if program grant funds were expended in accordance 

with grant requirements and NCEM-established priorities. 

In addition to NCEM, we met with officials from the following organizations: 

Urban Areas Security Initiative 

• Charlotte Urban Area 

State Agencies 

• State Bureau of Investigation 

• State Highway Patrol 

Counties/City 

• Buncombe County Emergency Services 

• Rockingham County Emergency Management 

Local Jurisdictions and First Responders 

• Regional Response Team-5, City of Greensboro Fire Department 

• Forsyth Emergency Medical Services 

• Thomasville Urban Search and Rescue Team #5 

• Regional Response Team-6, City of Asheville Fire Department 

• City of Asheville Police Department 

• New Bern Police Department 

• Pitt Memorial Hospital Foundation (currently Vidant Medical Center) 

• City of Greenville Urban Search and Rescue Team #10 

We interviewed responsible officials, reviewed documentation supporting NCEM and 

subgrantee management of the awarded grant funds (including expenditures for 

equipment, training, and exercises), and physically inspected judgmentally selected 

equipment procured with the grant funds. 

We reviewed a judgmental sample of the grant obligations representing approximately 

58 percent of the grant agreements for FYs 2008 through 2010 to determine whether 

the expenditures were supported and allowable under the grants. We judgmentally 

chose specific equipment items to observe at the local sites where they reside. 

We conducted this performance audit between April and September 2012, 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 

www.oig.dhs.gov 19 OIG-13-74 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

obtained provides a reasonable basis for our findings and conclusions based upon our 

audit objectives. 

www.oig.dhs.gov 20 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

II.S. ~I'''rTm'·. 1 orllomel,,,,,' S.",,,,.jr,· Wll5hiogton. DC 20~72 

FEMA 

MEMORANDUM FOR: Anne L. Ric hards 

Assistant Inspector Gene ral for Audits 

Office of Inspector General 

David J. Kaufman ~ I~ ) 

Assoc iate Administrator fOI"\ ~ 

Policy. Program Analysis and Intemational Affairs 

SUBJECT, FEMA Response to OIG Draft Report: "Nor(17 Carolina 's (IlC) 

!'v/(magemelll (if Home/and SeclIr;IY Progl'{1IJ1 Grams Awarded 

During Fiscal Years 1008 Through lOlO·' - For Official Usc Only 

- 0 10 Project No. 12-113-AUD-FEMA 

Thnnk yo u for the opportun ity to comment on O IG Draft Report: ","'101'117 Carolina IS (NC) 

Managemenr of HOllie/and Security Program Grams Aw{wded During Fi.~cal rears 2{)08 

Tfll"ollgh 2010" - Fa/" OjJicial ~e Only - 0 10 Project No. 12-1 IS-AUD-FEMA. The findings 

in the: report will be uSl:d to l:llham::t: tht:: program 's U\'cmll crrectiveness. The foll owing are our 

responses to the recommendations lor imp lementation: 

OIG Recommendation 1: We recommend the Assistant Administrator, Grant Programs 

Directo rate, assist the NC Oivisioll of Ellll:rgem:y Management (NCEM) and the Charlotte 

Urban Area to develop a Homeland Security Strategy that includes spec ifi c, measurable, 

ach ievable, results-oriented, and time-limited obj ectives. 

F"EMA Response: Concur. The Assistant Administrator of the Grant Programs Directorate 

(GPO) shall req uire the NC Division of Emergc ncy Managemcnt (NCEM) and the Charlotte 

lJrhan Area to update the ir respecti ve Homeland Securit y Strategies, ensuring the strategies 

include measurable target le\'c1s of perfomlancc, as well as obj ectives that arc speci fi c. 

measurab le, ac hievable, resuhs.-ori ented, and time- limited, and an appropriate evaluation. 

NCEM and the Charlotte Urban Area shall submit the rcviscd Homeland Sccurity Strategies to 

GPO ror review no later than six months after issuance nfthe O IG fina l report . 

FEMA rt::4uesLs this reeummcmlation be resolved and open pending the completion, submission, 

and review of the strategy revisions. 

OIG Reeommenduti on 2: We recommend the Assistant Administrator, Grant Programs 

Directorate require the Charlotte Urban Arca to cOllduct risk assessments to llt;:lenninl: an.::as of 

vulnerability for major disasters caused by either terrorism or nalural events. 

ww .. ·.fcm •. l:lJy 

www.oig.dhs.gov 21 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA Response: Concur. FEMA's National Preparedness Directorate (NPD) developed 

processes to measure core capabilities in accordance with the National Preparedness Goal 

pursuant to Presidential Policy Directive 8 (PPO-8). The Charlotte Urban Area completed the 

Threat and Hazard Identification and Risk Assessment (THIRA) and submitted it to FEMA. The 

THlRA will be used to create a baseline and targets for Fiscal Year 2013 and beyond. FEMA 

NPD also redesigned the 'State Preparedness Report (SPR) that will help states demonstrate and 

track preparedness improvement over time. Given the State's compliance with these 

requirements, we believe their actions satisfied the intent of the recommendation. See 

attachmen1 "A" North Carolina's SPR. 

FEMA requests that the recommendation be resolved and closed. 

DIG Recommendation 3: We recommend the Assistant Administrator. Grant Programs 

Directorate require the NC Division of Emergency Management to improve the efficiency of its 

processes to obligate subgrantee awards within the required time period. 

FEMA Response: Concur. The Assistant Administrator of the Grant Programs Directorate 

shall require NCEM to assess and streamline (where possible) processes and procedures for 

obligating funds to subgrantees. NCEM shaH report to GPD the results of this assessment and 

potential steps to be taken to expedite the obligation of funds 10 the subgrantees no later than 90 

days after the issuance of the 010 final report. 

FEMA requests this recommendation be resolved and open pending the completion of the 

corrective action. 

OIG Re(!ommendation 4: We recommend the Assistant Administrator, Grant Programs 

Directorate require the NC Division of Emergency Management to ensure that subgrantees 

comply with inventory requirements in the Code of Federal Regulations. 

FEMA Response: Concur. Within 90 days of issuance of the final report, the Assistant 

Administrator of the Grant Programs Directorate shall require NCEM to submit written policies 

and procedures addressing the requirement provisions of 44 CFR 13.32(d) as well as any internal 

guidelines along with documentation detailing how NCEM will correct the deficiencies outlined 

in the final audit report and communicate requirements with subgrantees more effectively. 

FEMA requests this recommendation be considered resolved and open pending the corrective 

actions stated above. 

OIG Recommendation 5: We recommend the Assistant Administrator, Grant Programs 

Directorate require the NC Division of Emergency Management to ensure that, where 

practicable, subgrantees and the Charlotte Urban Area mark purchases made with DHS funds 

"Purchased with funds provided by the US Department of Homeland Security". 

FEMA Response: Concur. (See consolidated response/or recommendation 5, 6, and 7 be/ow) 

2 

www.oig.dhs.gov 22 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Recommend2tion 6: We recommend the Assistant Administrator, Grant Programs 

Directorate require the NC Division of Emergency Management l:o ensure that the Charlone 

Urban Area submits cost reports as expenditures are incurred. 

FEMA Response: Concur. (See consolidated response/or recommendation 5, 6, and 7 below) 

OIG Recommcndati.on 7: We recommend the Assistant Administrator, Grant Programs 

Directorate require the NC Division of Emergency Management to ensure that its standard 

operating procedures and memorandums of agreement with subgrantees include clear guidance 

on required grant file docwnentation. 

FEMA Response to Recommendations 5, 6, and 7: Concur. Within 90 days of issuance of the 

final report, the AssislarJt Administnttor of the Gnml Programs Directorate shall require NCEM 

to update its Homeland Security Branch Management Standard Operating Guide to be compliant 

with all Federal and State requirements to include, but not limited 10: 

a) Guidance outlining the appropriate documentation to include in a grant file 

b) Guidance regarding terms and conditions for each subaward agreement 

c) Standard operating procedures for the use and management of equipment, including the 

marking of equipment 

d) Reporting requirements 

The Assistant Administrator shall also require NCEM to develop a communications plan for the 

revised Standard Operating Guide, to include subgrantcc grant management trainings or 

workshops.. 

FEMA requests this recommendation be considered resolved and open pending the corrective 

actions stated above. 

OIG Recommendation 8: Require the NC Division of Emergency Management and the 

Charlotte Urban Area to establish perfonnance measures to determine whether goals and 

objectives in their respective strategies have been met and whether they have improved their 

capabilities in disaster response and preparedness. See attachment ""A" North Carolina's SPR. 

FEMA Response: Concur. The FEMA NPD developed processes to measure core capabilities 

in accordance ""i.th the National Preparedness Goal pursuant to PPD-8, The State completed the 

THlRA and submitted it to FEMA. The THIRA will be used to create a baseline and targets for 

Fiscal Year 2013 and beyond. FEMA NPD also redesigned the SPR that will help states 

demonstrate and track preparedness improvement over time. Given the State's compliance with 

these requirements, we believe their actions satisfied the intent of the recommendation. See 

attaclunent "'A"North Carolina's SPR. 

FEMA requests that the recommendation be resolved and closed. 

J 

www.oig.dhs.gov 23 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Again, we thank you for the work that you and your team did to infonn us of measures we can 

take to enhance the program's overall effectiveness. We look forward to OIG's final report for 

"North Carolina's (NC) Management of Homeland Security Program Grants Awarded During 

Fiscal Years 2008 Through 2010" -For Official Use Only - OIG Project No. 12-IlS-AUDFEMA. Please direct any questions regarding this response to Gary McKeon, FEMA' 5 Chief 

Audit Liaison, at 202-646-1308. 

4 

www.oig.dhs.gov 24 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Homeland Security Grant Program 

The Homeland Security Grant Program provides Federal funding to help State and local 

agencies enhance their capabilities to prevent, deter, respond to, and recover from 

terrorist attacks, major disasters, and other emergencies. The Homeland Security Grant 

Program encompasses several interrelated Federal grant programs that together fund a 

range of preparedness activities, including planning, organization, equipment purchase, 

training, and exercises, as well as management and administration costs. Programs 

include the following: 

State Homeland Security Program provides financial assistance directly to each of the 

States and territories to prevent, respond to, and recover from acts of terrorism and 

other catastrophic events. The program supports the implementation of the State 

Homeland Security Strategy to address the identified planning, equipment, training, and 

exercise needs. 

Urban Areas Security Initiative provides financial assistance to address the unique 

planning, equipment, training, and exercise needs of high-risk urban areas, and to assist 

in building an enhanced and sustainable capacity to prevent, respond to, and recover 

from threats or acts of terrorism and other disasters. Allowable costs for the urban 

areas are consistent with the State Homeland Security Program. Funding is expended 

based on the Urban Area Homeland Security Strategies. 

In addition, the Homeland Security Grant Program includes other interrelated grant 

programs with similar purposes. Depending on the fiscal year, these include the 

following: 

• Metropolitan Medical Response System 

• Citizen Corps Program 

• Operation Stonegarden 

 

www.oig.dhs.gov 25 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

North Carolina State Emergency Response Commission— 

Participating State and Local Agencies 

The North Carolina State Administrative Agency is the Department of Crime Control and 

Public Safety. The NCEM component of the Department of Crime Control and Public 

Safety handles day-to-day implementation of DHS grants. The State Emergency 

Response Commission (Commission), chaired by the Homeland Security Advisor, 

oversees homeland security programs in the State and the creation and implementation 

of the State Homeland Security Strategy. The Commission holds quarterly meetings, at 

which the following North Carolina agencies are represented: Division of Crime Control 

and Public Safety, Department of Health and Human Services, Department of 

Environment and Natural Resources, Department of Agriculture and Consumer Services, 

Department of Transportation, Department of Justice, State Fire Marshal's Office, Office 

of Info Tech Services, and the School of Public Health at the University of North Carolina 

system. The Commission monitors progress toward meeting the goals and objectives 

and reviews all grant-funded projects and contracts. 

North Carolina comprises 101 jurisdictions, which includes one group of the Eastern 

Band of Cherokee Indians. There are three branches for emergency response functions, 

and 15 area coordinators work closely with their assigned counties to promote 

continuity. Additionally, the State has 9 Regional Response Teams and 11 Urban Search 

and Rescue teams. The following State and local agencies participate: 

Core Members: Support Members: 

�

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�

�

�

�

�

�

�

�

Public Health �

�

�

�

�

�

Division of Social Services 

Municipal Police Agriculture Extension Agent 

Sheriff’s Department Mental Health 

Municipal Fire Department Nongovernmental Organizations 

Rural Fire Department and Volunteer Organizations 

Emergency Medical Services Interoperable Communications 

Hospitals Community Colleges 

Emergency Management 

Rescue 

Public Works 

www.oig.dhs.gov 26 OIG-13-74 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Major Contributors to This Report 

Alexander Best, Director 

Inez Jordan, Audit Manager 

Jose Benitez-Rexach, Auditor-In-Charge 

Pamela Brown, Auditor 

Scott Crissey, Program Analyst 

Juan Santana, Auditor 

Roger Thoet, Auditor 

Ignacio Yanes, Program Analyst 

Kelly Herberger, Communications Analyst 

Katrina Bynes, Referencer 

www.oig.dhs.gov 27 OIG-13-74 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief 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 

Acting Chief Privacy Officer 

Federal Emergency Management Agency 

Administrator 

Assistant Administrator, Grant Programs Directorate 

Federal Emergency Management Agency Audit Liaison 

Grants 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 

www.oig.dhs.gov 28 OIG-13-74 
 

ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this document, please call us at (202) 254-4100, fax your 

request to (202) 254-4305, or e-mail your request to our Office of Inspector General 

(OIG) Office of Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

For additional information, visit our website at: www.oig.dhs.gov, or follow us on Twitter 

at: @dhsoig. 

OIG HOTLINE 

To expedite the reporting of alleged fraud, waste, abuse or mismanagement, or any 

other kinds of criminal or noncriminal misconduct relative to Department of Homeland 

Security (DHS) programs and operations, please visit our website at www.oig.dhs.gov 

and click on the red tab titled "Hotline" to report. You will be directed to complete and 

submit an automated DHS OIG Investigative Referral Submission Form. Submission 

through our website ensures that your complaint will be promptly received and 

reviewed by DHS OIG. 

Should you be unable to access our website, you may submit your complaint in writing 

to: DHS Office of Inspector General, Attention: Office of Investigations Hotline, 245 

Murray Drive, SW, Building 410/Mail Stop 2600, Washington, DC, 20528; or you may 

call 1 (800) 323-8603; or fax it directly to us at (202) 254-4297. 

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