Department of Homeland Security
 

Kentucky’s Management of State Homeland Security 


Program and Urban Areas Security Initiative Grants 


Awarded Fiscal Years 2008-2010 


OIG-13-41 February 2013
 
 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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

FEB 27 2013 

MEMORANDUM FOR: David J. Kaufman 

Acting, Assistant Administrator 

Grant Programs Directorate 

Federal Emergency Management Agency 

hards 

nspector General for Audits 

FROM: Anne L. Ric

Assistant I

SUBJECT: Kentucky’s Management of State Homeland Security 

Program and Urban Areas Security Initiative Grants 

Awarded Fiscal Years 2008-2010 

Attached for your action is our final report, Kentucky’s Management of State Homeland 

Security Program and Urban Areas Security Initiative Grants Awarded Fiscal Years 2008-

2010. We incorporated formal comments from the Federal Emergency Management 

Agency’s Office of Policy, Program Analysis and International Affairs, which included 

input from the Kentucky Office of Homeland Security, in the final report. 

The report contains five recommendations aimed at improving Kentucky’s management 

of State Homeland Security Program and Urban Areas Security Initiative grants. Based 

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

recommendations 2 and 3 resolved and closed. Recommendations 1, 4, and 5 are 

considered open and unresolved. As prescribed by the Department of Homeland 

Security Directive 077-01, Follow-Up and Resolution for Office of Inspector General 

Report Recommendations, within 90 days of the date of this memorandum, please 

provide our office with a written response that includes your (1) agreement or 

disagreement, (2) corrective action plan, and (3) target completion date for each 

recommendation. Also, please include responsible parties and any other supporting 

documentation necessary to inform us about the current status of the recommendations. 

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. Until your response 

is received and evaluated, recommendations 1, 4, and 5 will remain open and unresolved. 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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 

www.oig.dhs.gov 2 OIG-13-41 
Executive Summary ............................................................................................................ 1
 

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

Results of Audit ................................................................................................................... 2
 

Kentucky State Homeland Security Strategy Needs Improvement ....................... 3
 

Recommendation ................................................................................................... 5
 

Management Comments and OIG Analysis ........................................................... 5
 

Inventory Management Needs Improvement ........................................................ 6
 

Recommendations ... ........................................................................................................7
 

Management Comments and OIG Analysis .. ...............................................................7
 

Performance Measures Have Not Been Developed .............................................. 8
 

Recommendations ................................................................................................. 9
 

Management Comments and OIG Analysis .................................................................9
 

Best Practices ..................................................................................................................10

Appendixes 

Appendix A: Objectives, Scope, and Methodology ........................................... 11 

Appendix B: Management Comments to the Draft Report .............................. 15 

Appendix C: Homeland Security Grant Program............................................... 18 

Appendix D: Kentucky Office of Homeland Security Subgrantee Application
 

Process .......................................................................................... 19 

Appendix E: Major Contributors to This Report ............................................... 20 

Appendix F: Report Distribution ....................................................................... 21 

 

 

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 

KCPP Kentucky Community Preparedness Program 

KOHS Kentucky Office of Homeland Security 

NIMS National Incident Management System 

OIG Office of Inspector General

SHSP State Homeland Security Program 

SMART specific, measurable, achievable, results-oriented, and timelimited

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 Commonwealth of Kentucky. 

The objectives of the audit were to determine whether the Commonwealth of Kentucky: 

(1) spent grant funds effectively and efficiently; (2) complied with applicable Federal 

laws and regulations and DHS guidelines governing the use of such funding; and 

(3) enhanced the ability of State grantees to prevent, prepare for, protect against, and 

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

included a review of three awards totaling approximately $32 million in State Homeland 

Security Program and Urban Areas Security Initiative grant funds awarded to Kentucky 

from fiscal years 2008 through 2010. 

In most instances, the Kentucky Office of Homeland Security administered its grant 

programs in compliance with requirements in Federal grant guidance and regulations. 

Grant funds were spent on allowable items and activities, and there were adequate 

controls over the approval of expenditures and reimbursement of funds. However, we 

identified three areas for program improvement: the State Homeland Security Strategy, 

inventory control procedures, and performance measurement of preparedness 

improvements. 

We made five recommendations to the Federal Emergency Management Agency 

(FEMA) and the Commonwealth of Kentucky for improvements which, if implemented, 

should strengthen program management, performance, and oversight. FEMA concurred 

with recommendations 1, 4, and 5, and the Kentucky Office of Homeland Security 

implemented recommendations 2 and 3. 

www.oig.dhs.gov 1 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

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

help State and local agencies enhance capabilities to prevent, deter, respond to, and 

recover from terrorist attacks, major disasters, and other emergencies. Appendix C 

contains details of the HSGP. 

The Kentucky Office of Homeland Security (KOHS) is designated as Kentucky’s State 

Administrative Agency, the entity responsible for administering the HSGP. KOHS carries 

out multiple missions mandated by DHS and the Kentucky General Assembly, including 

administering Federal grants. 

KOHS uses a competitive grant application process for State and local agencies to submit 

grant project proposals. When proposals are presented, a team of peers from across 

the Commonwealth reviews the grant applications in accordance with Kentucky’s State 

Homeland Security Strategy and submits results to the KOHS Executive Review Panel.

After the KOHS Executive Review Panel conducts its review, the grant applications are 

presented to the State Homeland Security Working Group for final award decisions. The 

projects then move forward to the Governor for final approval. Appendix D contains 

information on the KOHS subgrantee application process. 

The Commonwealth was awarded approximately $32 million in State Homeland Security 

Program (SHSP) and Urban Areas Security Initiative (UASI) grant funds over fiscal years 

(FYs) 2008, 2009, and 2010. Appendix A provides details of the objectives, scope, and 

methodology for this audit. 

During FYs 2008 through 2010, the Louisville UASI was awarded $1.4 million, 

$2.2 million, and $2.2 million, respectively. A FEMA official said that Kentucky did not 

score high enough on the UASI risk formula to receive funding in FYs 2011 or 2012. 

Results of Audit 

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

requirements in Federal grant guidance and regulations. For example, Kentucky has 

written procedures and protocols for administering its grant programs and implements 

internal controls for approving and reimbursing expenditures. KOHS also conducts 

mandatory grant application and compliance workshops annually for subgrantees that 

apply for and receive grant funding.

However, the Kentucky State Homeland Security Strategy was last updated in 2005, and 

strategic objectives have completion dates of 2005 to 2007. The outdated strategy does 

www.oig.dhs.gov 2 OIG-13-41 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

not consider the changing needs, capabilities, or risks at the local, regional, and State 

levels, and does not include 2007 National Preparedness Guidelines and priorities. 

Additionally, KOHS does not maintain an accurate and complete inventory of all 

equipment purchased with grant funding, and has not established formal performance 

measures to assess whether improvements were achieved as a result of receiving SHSP 

and UASI funds. 

Kentucky State Homeland Security Strategy Needs Improvement 

The Kentucky State Homeland Security Strategy (strategic plan) does not align 

with priorities in the FEMA National Preparedness Guidelines, revised in 2007. 

The strategic plan was last updated in 2005; contains objectives with completion 

dates of 2005–2007; and does not include Kentucky’s changing needs, 

capabilities, or risks at the local, regional, and State levels. Furthermore, 

according to the Department of Homeland Security State and Urban Area 

Homeland Security Strategy Guidance on Aligning Strategies with the National 

Preparedness Goal, dated July 22, 2005, objectives should be—

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

achieved and accomplished; 

•	 Measurable – quantifiable, provide a standard for comparison and 

identify a specific achievable result; 

•	 Achievable – not beyond the ability of a State, region, jurisdiction, or 

locality; 

•	 Results-oriented – identify a specific outcome; and 

•	 Time-limited – have a target date that identifies when the specific, 

measurable, achievable, results-oriented, and time-limited (SMART) 

objective will be achieved. 

In contrast, the UASI strategic plan has current goals and objectives and, in most 

cases, complies with FEMA grant guidelines. 

Kentucky’s strategic plan was drafted in 2005, prior to the issuance of the 

National Preparedness Guidelines of September 2007. FEMA has not required 

States to update their strategic plans since 2005. Although Kentucky’s strategic 

plan is in compliance, it is not updated to align with the revised guidelines. These 

guidelines add one national priority to the original seven in the Department of 

Homeland Security State and Urban Area Homeland Security Strategy Guidance 

on Aligning Strategies with the National Preparedness Goal. Kentucky’s strategic 

plan does not include the new priority to “Strengthen Planning and Citizen 

Preparedness Capabilities” or the revised all-hazards approach to national 

www.oig.dhs.gov 3	 OIG-13-41 
 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

preparedness. Therefore, the strategic plan does not reflect the provisions 

required by the September 2007 National Preparedness Guidelines. Table 1 lists 

three outdated objectives from Kentucky’s 2005 strategic plan. 

Table 1. Outdated Objectives in Kentucky’s 2005 State Homeland Security Strategy 

Objectives in Kentucky’s 2005 State Homeland Security Strategy 

Objective Completion Date 

To have all of the Kentucky first responders be National Incident 

Management System (NIMS) compliant by the end of the calendar 

year 2006. 

• By August, KOHS would like to secure a position on the National 

Level NIMS Standards Working Group to develop national 

standards for NIMS.

• Before October 1, KOHS’s plan will ensure that Kentucky has met 

all 2006 Federal compliance requirements for NIMS.

End of Calendar Year 2006

To mobilize local law enforcement and community officials in a 

formalized process of identifying and correcting security 

vulnerabilities that could be exploited. 

• Kentucky uses the Kentucky Community Preparedness Program 

(KCPP) to identify and correct security vulnerabilities in small and 

medium-sized communities.

• Under the program, members of KCPP work with local law 

enforcement and elected officials to do risk assessments of 

communities.

• To date, 63 communities have been assessed and 27 more 

communities are scheduled for assessments by June 30, 2006.

• KOHS hopes to reach all 120 counties by the end of calendar year 

2007. 

End of Calendar Year 2007

To partner with the Commonwealth Office of Technology to improve 

the Security Awareness of state and local “end users” to provide 

information on cyber threats and how to protect our state network 

from malicious attacks. 

• October is National Cyber Security Awareness Month.

• Kentucky used this exposure in the fall of 2005 to hold an 

Awareness Seminar to improve security awareness for state and 

local end users and to provide information on cyber threats and 

how to protect our state network from malicious attacks.

Hold additional awareness 

seminars in 2006 

Source: KOHS document provided by FEMA 

KOHS does not formally evaluate the changing needs, capabilities, or risks at the 

local, regional, and State levels to assist in updating the strategic plan. KOHS 

officials believe that they meet the needs of subgrantees based on local agency 

self- assessments. KOHS cannot ensure that it is addressing the most critical 

statewide needs to prevent, deter, respond to, and recover from terrorist 

www.oig.dhs.gov 4 OIG-13-41 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

attacks, major disasters, and other emergencies. KOHS officials said that they 

expected to update their strategic plan by the end of 2012. An interview with 

FEMA in February 2013 indicated that KOHS is in the process of updating its 

strategic plan, and expects to submit it to FEMA for review no later than 6 

months after OIG issues the final report. 

Recommendation 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate:

Recommendation #1: 

Issue guidance to Homeland Security Grant Program recipients to update 

strategic plans periodically and to include SMART goals that align with current 

National Preparedness Guidelines. 

Management Comments and OIG Analysis 

Management Comments: FEMA concurred with the intent of recommendation 

1. According to FEMA, its actions satisfy the recommendation’s intent. The 

National Preparedness Directorate, the FEMA entity responsible for the 

homeland security strategy and its guidance, plans to release updated guidance 

on strategic planning by January 2013. FEMA’s Grant Programs Directorate 

(GPD) will require the KOHS Executive Director to revise Kentucky’s State 

Homeland Security Strategy to comply with the revised guidelines developed by 

the National Preparedness Directorate. 

Subsequent to its earlier response, we met with FEMA officials and they

provided an update to recommendation #1. FEMA’s GPD officials stated that 

KOHS is in the process of updating its current Homeland Security strategy. GPD 

representatives also stated that NPD has not released updated guidance on 

strategic planning, and expects NPD to issue the updated guidance during the 

summer of 2013. FEMA will provide a corrective action plan to address the 

recommendation after the publication of the final report. 

OIG Analysis: FEMA’s proposed actions are responsive to the recommendation. 

However, the recommendation will remain open and unresolved until final 

implementation of the proposed corrective actions. 

www.oig.dhs.gov 5 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Inventory Management Needs Improvement
 

KOHS does not comply with Federal requirements for maintaining inventory 

records or performing required biennial physical inventories. KOHS’ grant 

guidance includes Federal inventory requirements. However, according to KOHS, 

it has not had the personnel resources to fully implement and enforce the policy. 

Rather, it relies on its subgrantees to maintain inventory records and conducts 

its independent verification at the grant project closeout. As a result, KOHS does 

not have reasonable assurance that inventory is effectively managed. Code of 

Federal Regulations (CFR) Title 44 §13.32(d), Management requirements, sets 

forth procedures for managing equipment (including equipment replacement), 

whether acquired in whole or in part with grant funds, until disposition takes 

place. According to the CFR, grant recipients will, at a minimum, meet the

following requirements: 

•	 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 

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

data, including the date of disposal and sale price of the property. 44 CFR 

§13.32(d)(1). 

•	 A physical inventory of the property must be taken and the results 

reconciled with the property records at least once every 2 years. 44 CFR 

§13.32(d)(2). 

•	 A control system must be developed to ensure adequate safeguards to 

prevent loss, damage, or theft of the property. Any loss, damage, or 

theft shall be investigated. 44 CFR §13.32(d)(3). 

KOHS performs a physical inventory of equipment for each project during the 

grant closeout process. Subgrantees develop and maintain inventory records, 

but 17 of the 20 records we reviewed did not fully comply with the statutory 

property management requirement of 44 CFR §13.32(d). 

Once the closeout process is complete, KOHS conducts no additional inventories 

to meet the biennial inventory requirement. Without the required physical 

control and accountability over items purchased with SHSP and UASI funds, 

KOHS does not have reasonable assurance that the property procured with grant 

funding is used for authorized purposes and adequately safeguarded to prevent 

loss, damage, or theft. 

www.oig.dhs.gov 6	 OIG-13-41 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

After OIG fieldwork was completed, KOHS revised its inventory policies and 

procedures to establish stronger inventory controls to meet Federal 

requirements. To fulfill grant requirements, it conducted appropriate inventory 

management procedures to bring the Commonwealth into compliance.

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, require the Executive Director, Kentucky Office of Homeland 

Security, to: 

Recommendation #2: 

Develop and implement procedures to ensure that inventory records comply 

with 44 CFR §13.3 and §13.32 (d), including biennial inventory reviews of 

equipment purchased with SHSP and UASI funds.

Management Comments and OIG Analysis 

Management Comments: FEMA did not concur with recommendation 2. FEMA 

stated that KOHS developed and implemented procedures to ensure that 

inventory records comply with 44 CFR §13.3 and §13.32 (d). A copy of these 

procedures was provided to OIG on July 19, 2012. 

OIG Analysis: Although FEMA did not concur with the recommendation, KOHS 

took actions that satisfy the intent of the recommendations. We reviewed KOHS 

inventory procedures and actions taken to meet the recommendation. The 

recommendation is now resolved and closed. 

Recommendation #3: 

Compile and provide the Office of Inspector General with reconciled fiscal year 

2008 through 2010 SHSP and UASI inventory records that meet Federal 

requirements. 

Management Comments: FEMA did not concur with recommendation 3. 

According to FEMA, at the end of the project, KOHS submitted copies of 

reconciled records of SHSP and UASI inventory for FYs 2008 through 2010 to OIG. 

OIG Analysis: Although FEMA did not concur with the recommendation, KOHS 

took actions that satisfy the intent of the recommendations. We reviewed KOHS 

www.oig.dhs.gov 7 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

inventory records and actions taken to meet the recommendation and Federal 

requirements. The recommendation is now resolved and closed. 

Performance Measures Have Not Been Developed 

KOHS could not demonstrate specific improvements and measurable 

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

It does not have a basis for measuring improvements in its preparedness and 

response capabilities. KOHS does not have measurable goals and objectives 

consistent with Federal requirements in its strategic plan. KOHS officials said 

that they use State Preparedness Reports as a tool to measure capabilities-based 

improvements achieved with grant funds. 

According to 44 CFR §13.40, Monitoring and reporting program performance, 

grantees must monitor grant and subgrant-supported activities to ensure that 

performance goals are achieved. In addition, according to Department of 

Homeland Security State and Urban Area Homeland Security Strategy Guidance 

on Aligning Strategies with the National Preparedness Goal, July 2005, an

objective “sets a tangible and measurable target level of performance over time 

against which actual achievement can be compared, including a goal expressed 

as a quantitative standard, value, or rate.” Therefore, an objective should be 

SMART. 

KOHS officials said that they did not assess grant performance and improvements 

in preparedness using a performance reporting program. Rather, they consider 

the State Preparedness Reports to be an acceptable measurement of 

improvements in preparedness. 

Our review of Kentucky’s State Preparedness Reports for FYs 2008 through 2010 

showed that they estimate preparedness as a percentage based on the type of 

activity, such as planning or communications, but use inconsistent data from 

year to year. The reports answer basic questions on limitations and the level of 

improvement based on total Federal funding, but do not contain SMART 

performance measurements. Therefore, the State Preparedness Reports do not 

measure the extent of Kentucky’s performance improvements in preparedness 

as a result of the Commonwealth receiving HSGP funds. 

KOHS cannot evaluate its preparedness levels and response capabilities or 

effectively determine progress toward its goals and objectives. Instead of using 

a current strategic plan with performance measurements, KOHS officials said 

that they use a risk-based approach for making funding decisions.

www.oig.dhs.gov 8 OIG-13-41 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate:

Recommendation #4: 

Provide performance measurement guidance to Homeland Security Grant 

Program recipients and direct the Kentucky Office of Homeland Security to 

develop a comprehensive performance measurement system to capture the 

program’s overall performance and progress toward enhancing preparedness as 

a result of the SHSP and UASI grant programs. 

Recommendation #5: 

Direct the Kentucky Office of Homeland Security to implement and manage 

specific milestones for achieving progress toward target capability assessment 

goals at the State, local, and regional levels. 

Management Comments and OIG Analysis 

Management Comments: FEMA concurs with the intent of recommendations 4 

and 5. According to FEMA, its National Preparedness Directorate is currently 

developing processes to measure core capabilities in accordance with the

National Preparedness Goal, pursuant to Presidential Policy Directive-8. KOHS 

will complete the Threat and Hazard Identification and Risk Assessment and 

submit it to FEMA by December 31, 2012. This assessment will be used to create 

a baseline and targets for FY 2013 and beyond. FEMA has also redesigned the 

State Preparedness Report that will help States demonstrate and track 

preparedness improvement over time. 

Subsequent to its original response, representatives at FEMA stated that KOHS 

completed and submitted the Threat and Hazard Identification and Risk 

Assessment as part of its Annual State Preparedness Report to FEMA on 

December 21, 2012. 

OIG Analysis: The actions proposed and confirmed by FEMA are responsive to 

the recommendations. However, the recommendations will remain open and 

unresolved until documentation that final implementation of the proposed 

corrective actions occurred is provided. 

www.oig.dhs.gov 9 OIG-13-41 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Best Practices 

KOHS hosts two mandatory grant workshops at various locations throughout 

Kentucky: a grant application workshop for agencies interested in submitting 

projects for funding, and a grant compliance workshop for agencies awarded 

grant funding. These workshops include a review of Federal and State grant 

requirements, grant responsibilities if awarded, grant application and writing 

tips, and other available resources. The workshops are held periodically and 

provide local agencies the opportunity to receive required training while 

minimizing travel expenses. 

The grant application workshops review FEMA’s focus and grant requirements 

for the specific grant year, including annual DHS grant guidance and toolkit 

information. Also included is KOHS’ focus on funding, and how to successfully 

complete the application to ensure that all required information is submitted. 

KOHS’ follow-on question-and-answer sessions provide immediate information 

to local agencies, so they leave the workshops better prepared to complete and 

submit their project applications. 

The grant compliance workshops are held for all subgrantees receiving grant 

funding and cover grant management and administration requirements. 

Additional information is provided to the subgrantees about grant areas such as 

procurement, reimbursements, inventory, reporting, and monitoring. The 

responsibilities of the grant are discussed, and a question-and-answer session at 

the end provides subgrantees the opportunity to ask questions before their 

grant begins. To further assist subgrantees with record keeping and maintaining 

required documentation, KOHS provides a file folder identical to the one used by 

KOHS grant managers. The folder includes sections for the legal agreement; 

original application; single audit; budget documents including written 

procurement codes, reimbursements, reports, and correspondence; and State 

and Federal grant requirements for incorporating the NIMS. 

www.oig.dhs.gov 10 OIG-13-41 
 

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 objective of the audit was to determine whether the Commonwealth of Kentucky 

distributed and spent SHSP and UASI grant funds effectively and efficiently and in 

compliance with laws, regulations, and guidance. In addition, we determined the extent 

to which the Commonwealth measures improvements in its ability to prevent, prepare 

for, protect against, and respond to natural disasters, acts of terrorism, and other 

manmade disasters. 

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

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

management and administration costs. However, only SHSP and UASI funding, 

equipment, and programs supported by the grant funding were reviewed for compliance. 

Table 2 describes the scope of the audit. Additional information on these grant 

programs is in appendix C. 

Table 2. Kentucky Homeland Security Grant Program Awards 

Kentucky Homeland Security Grant Program Awards

FYs 2008 through 2010 

Program FY 2008 FY 2009 FY 2010 

State Homeland 

Security Program $9,590,000 $8,593,500 $8,007,374

Urban Areas 

Security Initiative $1,421,500 $2,201,800 $2,205,723

Subtotal $11,011,500 $10,795,300 $10,213,097

Total

$26,190,874

$5,829,023

$32,019,897 

Source: FEMA 

The audit methodology included interviews with FEMA representatives as well as 

fieldwork at KOHS, the Area Development Districts, and various subgrantee locations. To 

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

www.oig.dhs.gov 11 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

interviewed key local officials directly involved in the management and administration 

of the Kentucky Homeland Security Grant Program. We conducted site visits and held 

discussions with appropriate officials from KOHS, Area Development Districts, and local 

jurisdictions to determine whether program grant funds were expended in accordance 

with grant requirements and Kentucky’s established priorities. As of March 13, 2012, 

KOHS reported that it had expended $23,561,293. In addition to KOHS, we met with 

officials from the following organizations:

Urban Areas Security Initiative 

• Louisville UASI 

Area Development Districts 

• Bluegrass Area Development District 

o Boyle County Emergency Management Services

o Boyle County Fire Department

o Boyle County Sheriff’s Office 

o Burgin Fire Department

o Clark County Fire Department 

o Clark County Sheriff’s Office 

o Danville Police Department 

o Lancaster Fire Department 

o Lancaster Police Department

o Mercer County Fire Department

o Versailles Fire Department 

o Winchester Fire Department

o Winchester Sheriff’s Office 

• Buffalo Trace Area Development District 

o Fleming County Sheriff’s Office 

o Flemingsburg Police Department 

o Garrison Volunteer Fire Department 

o Kinniconick Volunteer Fire Department 

o Sardis Volunteer Fire Department

o Tilton Volunteer Fire Department 

o Vanceburg Police Department 

o Washington/Maysville Volunteer Fire Department 

Local Jurisdictions and First Responders 

• Lexington Fayette Urban County Government 

o Lexington Fire Department 

o Lexington Police Department 

www.oig.dhs.gov 12 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

• Carter County 

o Carter County Emergency Management Services

• Lawrence County 

o Cherryville Fire Department 

o Lowmansville Fire Department

• Greenup County

o Greenup County 911 Center

• Graves County 

o Mayfield Fire Department 

o Graves County Sheriff’s Office 

• Marshall County

o Marshall County Emergency Management Services

o Marshall County Sheriff’s Office 

o Mayfield/Graves County Ambulance Service 

o Mercy Regional Ambulance Service 

o Murray-Calloway County Ambulance Service 

• McCracken County 

o McCracken County Attorney

o McCracken County Sheriff’s Office 

• Boyd County Sheriff’s Office

• Boyd County Public Safety 

• Jeffersontown 

o Jeffersontown Police Department 

• Flatwoods City 

o Flatwoods Police Department 

• Benton City

o Benton City Fire Department

• City of Mayfield 

o Mayfield Police Department 

www.oig.dhs.gov 13 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

• Paducah City

o Paducah City Fire Department

o Paducah City Police Department 

• Jefferson County

o Jefferson County Sheriff’s Office 

• Harvey-Brewers Fire Department 

• Possum Trot Fire Department

We interviewed responsible officials, reviewed documentation supporting KOHS and 

subgrantee management of the awarded grant funds (including expenditures for 

equipment, training and exercises, and management and administration), and physically 

inspected equipment procured with the grant funds. 

The team reviewed a judgmental sample of the grants expenditures representing 

approximately 31.8 percent of the SHSP dollar value and 100 percent of the UASI dollar 

value expended for FYs 2008 through 2010 grants to determine whether the expenditures 

were supported and allowable under the terms of the grants. The team judgmentally

chose specific equipment items to observe at the local sites where it resides. 

We conducted this performance audit between April and June 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

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 14 OIG-13-41 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

Ii.S. DepanmCnI of lIomelllntl Security 

Washing:o!1. DC 20472 

OCT 2 4 1012 

MEMORANDUM rOR: Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General 

rROM: <f1'- David J. Kaufman vl(ccl~ ~ t Associate Administrator 

Policy, Program An(llysis and Int emational A fr.'lir~ 

SUBJECT: Response to 010 Draft Report, The Commonweaflh of KenlucJ.:y '.\' 

lvJal1agement o/Slme Homeland Security j}rogram and Urban Areas 

Security Initiative Grams Awarded During Fiscal Years 1008 through 

2010 

Thank you for the opportunity to comment on the draft repon. The findings in the report will be used 

to strengthen the effectiveness and efficiency of how we execute and measure our programs. We 

recognize the need to continue to impro ve the process. including addressing the recommendations 

raised in this repon. Our responses to the recommendations arc as follows: 

Recommendation #1 ' We recommend tha t tile FEMA Assistant Administrator, Grant Programs 

nirectorate issue guidance to Homeland Security Grant Program recipients to update strategic plans 

periodically and to include specifi c, measurable, achievable, results-oriented, and time-limited 

(S.\I1ARI') goals that align with current National Preparedness Guidelines. 

FEMA Response: FEMA concurs with the intent of this recommendation. lbe National 

Preparedness Directorate (NPD), the Federal Emergency Management Agency (FEMA) entity 

responsible for the homeland security strategy (HSS) and its guidance, plans to release updated 

guidance on strategic planning by January 2013 . FEMA's Grant Programs Directorate (OPD) will 

require the Kentucky Office of Homeland Security Director to revise Kentucky'S HSS to comply 

with revised guidelines developed by NPD. 

FEMA believes this satisfies the intent of the recommendation and requests that this 

recommcndation be resolved and open pending revision of Kentueky's Homeland Security Strategy. 

Recommendation #2; We recommend that the FEMA Assistant Administrato r, Grant Programs 

www.oig.dhs.gov 15 OIG-13-41
O

 

FFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Directorate. require the Executive Director, Kentucky Office of Homeland Security, to develop and 

implement procedures to ensure that inventory records comply with 44 CFR §13.3 and §13.32 (d), 

including biennial inventory reviews of equipment purchased with SHSP and U ASI funds. 

FEMA Response: FEMA does not concur with Recommendation #2. The Kentucky Office of 

Homeland Security developed and implemented procedures to ensure inventory records comply with 

44 CPR §13.3 and §13.32 (d). A copy of these procedures is provided with this resIXlnse 

(Attachment I) and was provided to the Office oflnspector General (OIG) on July 19.2012. 

FEMA believes this satisfies the intent of the recommendation and requests that this 

recommendation be resoJved and closed. 

Recommendation #3: We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, require the Executive Director. Kentucky Office of Homeland Security. to compile and 

provide the Office ofInspector General with reconciled fiscal year 2008 through 2010 SHSP and 

VASI inventory records to meet Federal requirements. 

FEMA Response: FEMA does not concur with Recommendation #3. The Kentucky Office of 

Homeland Security complied and provided the Office of Inspector General (OIG) with reconciled 

fiscal year 2008 through 2010 SHSP and UASI inventory records to meet Federal requirements on 

July 25, 2012 forFYs 2008 and 2009 and on August 17. 2012 for FY 2010. A copy ofreconciled 

records is provided with this response as Attachments 2-6. 

FEMA believes this satisfies the intent of the recommendation and requests that this 

recommendation be resolved and closed, 

Recommendation #4: We recommend that the FEMA Assistant Administrator. Grant Programs 

Directorate provide perfonnance measurement guidance to Homeland Security Grant Program 

recipients and direct the Kentucky Office of Homeland Security to develop a comprehensive 

perfonnance measurement system to caprure the program's overall performance and progress toward 

enhancing preparedness as a result of the SHSP and UASI grant programs. 

Recommendation #5: We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate direct the Kentucky Office of Homeland Security to implement and manage specific 

milestones for achieving progress toward target capability assessment goals at the State. local,·and 

regional levels. 

FEMA Response for Recommendations #4 and #5: FEMA concurs with the intent of 

Recommendations #4 and #5. The FEMA NPD is currently developing processes to measure core 

capabilities in accordance with the National Preparedness Goal pursuant to PPD-8. The Kentucky 

Office of Homeland Security will complete the Threat and Hazard Identification and Risk 

Assessment (THIRA) and submit it to FEMA by December 31. 2012. The THIRA will be used to 

create a baseline and targets for Fiscal Year 2013 and beyond. FEMA bas also redesigued the State 

Preparedness Report that will help states demonstrate and traek preparedness improvement over 

time. 

FEMA requests that recommendations 4 and 5 be considered resolved and open pending completion 

of the stated corrective action. 

www.oig.dhs.gov 16 OIG-13-41
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Again. we thank you for the opportunity to provide comments concerning this report. Please contact 

Gina Norton, Audit Liaison at 202-646-4287 regarding further questions or concerns. 

6 Attachments (documentation to support FEMA's non-concurrence of Recommendations 2 and 3): 

Attachment 1 - Kentucky Office of Homeland Security (KOHS) Grants and Finance Policies and 

Procedures Manual 

Attachment 2 - SOW for an Online Inventory Management System 

Attachment 3 - Subrecipient Inventory Form 

Attachment 4 - KOHS Subrecipient Inventory for 2008 SHSP 

Attachment 5 - KOHS Subrecipient Inventory for 2009 SHSP 

Attachment 6 - KOHS Subrecipient Inventory for 2010 SHSP 

www.oig.dhs.gov 17 OIG-13-41
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Homeland Security Grant Program 

According to the FY 2010 Homeland Security Grant Program Guidance and Application 

Kit and FY 2010 Preparedness Grant Programs Overview, HSGP 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 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— 

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

States and U.S. 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. 

In addition, HSGP includes other interrelated grant programs with similar purposes. 

Depending on the fiscal year, these include— 

• Metropolitan Medical Response System Program 

• Citizen Corps Program 

• Operation Stonegarden

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Kentucky Office of Homeland Security Subgrantee Application 

Process 

According to the KOHS’ Grants and Finance Policy and Procedures, KOHS issues a news 

release announcing grant funds availability and how to apply, including updated DHS 

guidance. KOHS provides statewide regional grant application workshops for all grant 

applicants and individual technical assistance upon request. These workshops include a 

review of Federal and State grant requirements, grant responsibilities if awarded, grant 

application and writing tips, and other resources available. 

Applications are received at KOHS and organized according to Kentucky initiatives, 

including, but not limited to mobile data terminals, radios, towers/repeaters, 911 

centers, and equipment. The technical review teams consist of independent subject 

matter experts ranging from fire to emergency management services and law 

enforcement to public health reviewers. All reviewers receive training for consistent 

application scoring. Each reviewer scores the project, and the review teams discuss the 

scores. The final scores are provided to KOHS and entered into the grants database. 

KOHS executive staff performs a functional review, which includes consideration of 

other available grant resources and provides preliminary funding proposals based on 

the reviewers’ scores, statewide needs, and the KOHS Strategic Plan. Executive staff 

coordinates with the Justice Cabinet, Emergency Management, and Public Health for 

other available grants and grant awards. 

The Executive Director reviews the recommendations and makes changes based on 

special needs and risk. The projects then move forward to the Governor for final 

approval. 

www.oig.dhs.gov 19 OIG-13-41 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Major Contributors to This Report 

Alexander Best, Director 

Cecilia Carroll, Audit Manager

Michael Staver, Auditor-in-Charge 

John Kohler, Program Analyst 

Erica Stern, Program Analyst

James Diaz, Program Analyst

Kevin Dolloson, Communications Analyst 

Katrina Bynes, Referencer 

www.oig.dhs.gov 20 OIG-13-41 
 

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 

FEMA 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 21 OIG-13-41 
 

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.