FEMA Should Disallow 

$1.5 Million in Grant 

Funds Awarded to Hays 

County, Texas 

June 22, 2017 

OIG-17-77-D 
 

 

 

 

 

 

 

DHS OIG HIGHLIGHTS

 FEMA Should Disallow $1.5 Million in

 Grant Funds Awarded to Hays County, Texas
 

June 22, 2017 

Why We 

Did This Audit 

Hays County, Texas (County), 

received a $3.2 million Federal 

Emergency Management 

Agency (FEMA) grant award for 

damages resulting from severe 

storms and flooding in May and 

June 2015. We selected Hays 

County for audit because FEMA 

officials asked us whether the 

County’s (and other grant 

subrecipients’) use of a shared 

services agreement met Federal 

requirements. 

What We 

Recommend 

FEMA should disallow 

$1.5 million as ineligible costs 

for contracts that overly 

restricted competition and 

direct Texas to advise its grant 

subrecipients about the use of 

shared services agreements 

when spending Federal funds. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-IG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

The County did not fully comply with procurement 

standards for Federal grants in awarding contracts 

for disaster work. The County used the HoustonGalveston Area Council (HGAC) to procure two 

contracts totaling $1.5 million for debris removal and 

monitoring. However, HGAC required its prospective 

debris removers to have performed three debris 

removal projects of at least 1 million cubic yards of 

debris. In this instance, the County needed to remove 

a much smaller volume of debris — about 150,000 

cubic yards. Therefore, HGAC’s requirements 

prevented smaller companies from competing for the 

federally funded work. In soliciting bids for the two 

contracts, HGAC also did not take all the affirmative 

steps that Federal regulations require to provide 

opportunities for disadvantaged businesses when 

possible. 

Federal regulations encourage grant recipients to 

enter into state and local intergovernmental 

agreements to foster economy and efficiency. 

Nevertheless, the use of these shared services 

agreements does not relieve the grant recipient or 

subrecipient of its responsibility to comply with 

Federal procurement requirements. 

The County also awarded two smaller contracts 

totaling $367,191 without taking the federally 

required affirmative steps or including all required 

contract provisions. In response to our audit, 

however, the County revised its procurement policies 

to comply with Federal requirements, canceled one of 

the contracts, and plans to resolicit bids for more 

than $200,000 of disaster work. 

FEMA Response 

FEMA Region VI officials concurred with our findings 

and recommendations. Appendix C includes FEMA’s 

written response in its entirety. 

www.oig.dhs.gov OIG-17-77-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

MEMORANDUM FOR: George A. Robinson 

Regional Administrator, Region VI 

Federal Emergency Management Agency 

~?~_yz-- FROM: John E. McCoy II 

Acting Assistant Inspector General 

Office of Emergency Management Oversight 

SUBJECT: FEMA Should Recover $1.5 Million in Grant Funds 

Awarded to Hays County, Texas 

Audit Report Number OIG-17-77-D 

We audited Public Assistance grant funds awarded to Hays County, Texas 

(County). The Texas Division of Emergency Management (Texas), a Federal 

Emergency Management Agency (FEMA) grant recipient, awarded the 

County $3.2 million for damages resulting from severe storms, tornadoes, 

straight-line winds, and flooding that occurred May 4, through June 19, 2015. 

The award provided 75 percent Federal funding for eligible work. The County 

received $52,868 of insurance proceeds covering eligible damage. 

We audited six approved projects totaling $2.4 million, or 75 percent of the 

total award (see table 1 in appendix A) . We also audited four unobligated 

projects totaling $412,785. As of February 11, 2016, the cutoff date of our 

audit, the County had completed work on most projects, but had not submitted 

any of its costs to Texas for reimbursement. 

FEMA Region VI officials informed us that several grant subrecipients had used 

the services of the Houston-Galveston Area Council (HGAC) to procure 

contracts for work related to this Texas disaster. FEMA asked us whether using 

HGAC's services satisfied the requirements of procurement standards for 

Federal grants. Therefore, we selected the County for audit specifically because 

it procured contracts using HGAC's procurement services. However, the 

findings and opinions we express in this report are based only on our audit of 

Hays County. We did not audit HGAC or the procedures it used to procure 

contracts other than those the County used for this disaster. 

www.oig.dhs.gov OIG-17-77-D 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background
 

Hays County is located on the Edwards Plateau situated between Austin and 

San Antonio, Texas, and is part of the Austin-Round Rock metropolitan area. 

The County has a population of about 195,000 and covers 680 square miles. 

From May 4, to June 19, 2015, the County received significant rainfall causing 

the rivers and creeks to overflow. The Blanco River, with a flood stage of 

13 feet,1 crested at over 40 feet, washing away more than 400 homes and 

2 main bridges (see figure 1). The President declared the major disaster on 

May 29, 2015. 

Figure 1: Fisher Bridge Washed Out, Hays County, Texas 

Source: Hays County, Texas 

On September 9, 1966, the State of Texas created the Houston-Galveston Area 

Council (HGAC) as a regional planning commission. HGAC, a political 

subdivision of the State of Texas, is a voluntary membership organization of 

local governments in a 13-county region surrounding Houston. According to its 

website, HGAC strives to make the government procurement process more 

efficient by providing competitively priced contracts for goods and services to 

help its members achieve their purchasing goals. The County used HGAC’s 

procurement services to procure two contracts, one to perform debris removal 

and the other to monitor the debris removal. 

1 Flood stage is when the surface of a body of water has risen sufficiently to cause 

inconvenience or a threat to life or property. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

The County did not always comply with Federal procurement standards. 

Specifically, the County used a shared services agreement with HGAC to 

procure two contracts totaling $1.5 million that did not fully meet Federal 

requirements. When advertising for the debris removal contract, HGAC 

unreasonably restricted competition by not allowing smaller contractors to 

compete for the work. For both debris-related contracts, HGAC’s procurement 

practices also did not take the specific steps that Federal regulations require to 

provide opportunities for small and minority businesses, women’s business 

enterprises, and labor surplus area firms to bid on federally funded work when 

possible. 

The County also awarded two smaller contracts totaling $367,1912 without 

taking the federally required affirmative steps or including all required contract 

provisions. In response to our audit, however, the County revised its 

procurement policies to comply with Federal requirements. The County also 

canceled one of the contracts and plans to resolicit bids for more than 

$200,000 of disaster work. 

Federal regulations encourage grant recipients to use shared services to foster 

economy and efficiency. Nevertheless, the use of these shared services does not 

relieve the grant recipient or subrecipient of its responsibility to comply with 

Federal procurement requirements. Therefore, FEMA should disallow as 

ineligible $1,473,045 for the two contracts that Hays County awarded using 

HGAC’s procurement services. 

Because grant recipients are responsible for ensuring that their grant 

subrecipients comply with Federal regulations, FEMA should also direct Texas 

to — 

(1) continue monitoring the County’s grant subaward activities to ensure it 

complies with all Federal grant requirements and 

(2) inform its grant subrecipients that using a shared services agreement 

does not relieve them of the responsibility to comply with Federal 

procurement requirements. 

2 The total estimated costs of $367,191 are included under Project 992 for $165,961 and 

unobligated Project 692 for $201,230. 

www.oig.dhs.gov 3 OIG-17-77-D 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Finding A: Procurement Practices 

The County awarded four disaster-related contracts totaling $1.8 million that 

did not fully meet Federal procurement standards: 

x two contracts, totaling $1,473,045, using procurement services HGAC 

provided and 

x two contracts, totaling $367,191, without HGAC’s assistance. 

HGAC’s Procurement of the County’s Debris-related Contracts 

The County awarded two contracts, totaling $1,473,045, using procurement 

services provided by HGAC’s Disaster Debris Clearance and Removal Services 

program. One contract was for debris removal ($916,046) and the other for 

monitoring debris removal ($556,999). HGAC made the following claims on its 

website: 

x HGAC “has handled all the procurement issues”; 

x “The program provides End Users with a procurement process based on 

the latest FEMA policies to limit the entities exposure to potential nonreimbursement following a presidential disaster declaration”; and 

x “The Program can save you time and money associated with the 

procurement process and can help maximize eligible FEMA 

reimbursement.” 

However, the problems we identified do affect eligibility for Federal grant funds. 

HGAC’s requirements for debris removal contractors overly restricted 

competition; and, in soliciting bids for both contracts, HGAC did not take all 

the affirmative steps that Federal regulations require to provide opportunities 

for disadvantaged businesses when possible. 

Restricting Competition — HGAC’s restrictions prevented otherwise qualified 

contractors from participating in the County’s debris removal contract. 

According to 2 Code of Federal Regulations (CFR) 200.319(a), all procurement 

transactions “must be conducted in a manner providing full and open 

competition.... Some of the situations considered to be restrictive of 

competition include but are not limited to: (1) Placing unreasonable 

requirements on firms in order for them to qualify to do business; [and] 

(2) Requiring unnecessary experience and excessive bonding.” 

HGAC required its prospective debris removers to have performed three debris 

removal projects requiring the removal of at least 1 million cubic yards of 

debris. For this disaster, though, the County needed to remove a much smaller 

volume of debris — about 150,000 cubic yards. Therefore, HGAC’s 

requirements prevented smaller companies from competing for the federally 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

funded work. It is important to note that HGAC’s requirements would not be 

overly restrictive if its procurement services for debris removal were available 

only to customers requiring the removal of large volumes of debris. However, 

HGAC’s procurement service is available to any governmental entity nationwide 

needing debris removal, regardless of project size. To comply with Federal 

regulation, HGAC needs to restrict its contractors to only large debris removal 

projects or provide its customers with a lower-volume option. 

HGAC officials said they based their contractor experience requirements on a 

2011 assessment of regional storm debris during recent storms (Katrina, Rita, 

and Ike). But past requirements from these catastrophic storms have no 

bearing on whether current requirements are reasonable and do not 

unreasonably restrict competition. Regardless, smaller contractors had no 

opportunity to compete for these contracts. HGAC officials agreed to include 

language on its webpage stating that these debris removal contracts may not 

be appropriate for all situations and require customers to contact HGAC to 

discuss whether the contract is appropriate. 

Affirmative Steps — According to 2 CFR 200.321(a), non-Federal entities 

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

minority businesses, women's business enterprises, and labor surplus area 

firms when possible. Further 2 CFR 200.321(b) states that the affirmative steps 

must include: 

(1) Placing qualified small and minority businesses and women’s business 

enterprises on solicitation lists; 

(2) Assuring that small and minority businesses, and women’s business 

enterprises are solicited whenever they are potential sources; 

(3) Dividing total requirements, when economically feasible, into smaller 

tasks or quantities to permit maximum participation by small and 

minority businesses and women’s business enterprises; 

(4) Establishing delivery schedules, where the requirement permits, which 

encourage participation by small and minority businesses and women’s 

business enterprises; 

(5) Using the services and assistance, as appropriate, of such organizations 

as the Small Business Administration and the Minority Business 

Development Agency of the Department of Commerce; and 

(6) Requiring the prime contractor, if subcontracts are to be let, to take the 

affirmative steps listed in paragraphs (1) through (5). 

HGAC did not take all of these required affirmative steps; and, as discussed 

above, HGAC’s requirements were overly restrictive for small businesses. 

HGAC officials said, for the debris monitoring procurement, they did advertise 

in minority publications and maintain a solicitation list that includes 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

contractors in the industry, disadvantaged businesses identified by contractors, 

and contacts made at trade conferences attended. HGAC’s solicitation did 

require its general contractors to use their best faith efforts to help HGAC meet 

the State of Texas’ goals to include historically underutilized businesses.3 

Nevertheless, these requirements are not the same as those specifically listed 

at 2 CFR 200.319. Specifically, HGAC’s procurement services did not include 

assurance that small and minority businesses, and women’s business 

enterprises are solicited whenever they are potential sources. Additionally, the 

procurement did not include the use of the services and assistance, as 

appropriate, of such organizations as the Small Business Administration, and 

the Minority Business Development Agency of the Department of Commerce 

and did not require its prime contractor to take these affirmative steps. 

Therefore, FEMA has no assurance that HGAC will take the required 

affirmative steps in its future disaster procurement services. 

The Federal requirements are not optional, and HGAC’s procurement 

procedures would need to fully comply with Federal regulation to be eligible for 

FEMA funding. HGAC officials said they would update their website to include 

a statement that it does not guarantee compliance with Federal procurement 

requirements. HGAC officials also said they would fully comply with Federal 

requirements when they re-solicit the contracts. Although HGAC did not follow 

all required steps, about a third of businesses HGAC solicited for these 

contracts were historically disadvantaged businesses. However, the experience 

requirements in HGAC’s solicitation would likely have discouraged or excluded 

most small businesses. 

Texas officials said the County concluded normal procurement rules did not 

apply because of the “emergency/exigent period at the time the contract was 

awarded” and “that HGAC was merely a vehicle to access repository of vendors 

quickly.” We disagree. Although FEMA classifies debris removal as “emergency 

work,” the need for debris removal does not constitute exigent circumstances 

unless the debris poses an immediate threat to life and property. For example, 

pushing debris from blocked roadways to allow emergency vehicles to pass is 

exigent work, but normal debris removal is not. The County took proactive 

measures by using its employees and equipment to push debris from 

roadways. The remaining debris work posed no immediate threat and, 

therefore, did not warrant the County’s circumvention of Federal procurement 

standards. 

Because HGAC’s experience requirements were overly restrictive and it did not 

take the required affirmative steps, we recommend that FEMA disallow as 

3 The State of Texas created the Historically Underutilized Business (HUB) Program to promote 

full and equal procurement opportunities for small, minority- and women-owned businesses. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

ineligible $1,473,045 for the two contracts that the County awarded using 

HGAC’s procurement services for debris removal and monitoring. 

The County’s Procurement of Two Contracts Totaling $367,191 

The County awarded two contracts totaling $367,191, without fully complying 

with Federal requirements. Specifically, the County did not (1) take all of the 

required affirmative steps to assure the use of disadvantaged businesses when 

possible; or (2) include all required provisions in its contracts. 

Affirmative Steps — The County did place qualified small and minority 

businesses and women’s business enterprises on solicitation lists for the two 

contracts it awarded without HGAC’s assistance. County officials said they 

have a master database with vendor information that includes specific 

information regarding historically underutilized businesses. They also said that 

they search the State Comptroller and Texas Unified Certification program sites 

for vendors that meet the criteria. These procedures satisfy some, but not all of 

the required affirmative steps. 

Contract Provisions — The two contracts also did not include all required 

contract provisions. According to 2 CFR 326 and Appendix II to Part 200, 

contracts and subcontracts must include specific provisions. These provisions 

document the rights and responsibilities of the parties and help minimize the 

risk of contract misinterpretations and disputes. For example, the contracts 

did not include required provisions related to Equal Employment Opportunity, 

compliance with contract work and safety standards, or the right to examine 

contractor’s records. 

Because of our audit, the County (1) revised its procurement policies to comply 

with Federal requirements, (2) canceled one of the contracts, and (3) plans to 

resolicit bids for more than $200,000 of disaster work. In addition, although 

the County did not take all of the required steps, its efforts to provide 

opportunities for disadvantaged businesses were substantial. Therefore, we are 

not questioning the $367,191 for these two contracts the County procured. 

Finding B: Grant Management 

As we discuss in this report, the County did not fully comply with procurement 

standards for Federal grants. Federal regulations encourage grant recipients to 

enter into state and local intergovernmental agreements to foster greater 

economy and efficiency and promote cost-effective use of shared services across 

the Federal Government (2 CFR 200.318(e)). Nonetheless, contracts procured 

through shared services must comply with all Federal requirements to ensure 

the eligibility of disaster-related costs. Therefore, the use of these shared 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

services agreements does not relieve the grant recipient or grant subrecipient of 

its responsibility to follow Federal procurement requirements. 

According to 2 CFR 200.331(d), the grant recipient (pass-through entity) must 

monitor the activities of the subrecipient as necessary to ensure that it uses 

the subaward for authorized purposes, in compliance with Federal statues, 

regulations, and the terms and conditions of the subaward. Federal regulations 

also require the grant recipient to follow up and ensure that the subrecipient 

takes timely and appropriate action on all deficiencies pertaining to the Federal 

award (2 CFR 200.331(d)(2)). Therefore, Texas, as FEMA’s grant recipient, 

should continue to monitor the County’s grant subaward activities to help 

ensure compliance with Federal regulations. Texas should also inform grant 

subrecipients that using a shared services agreement does not relieve them of 

the responsibility to comply with Federal procurement requirements. 

Recommendations 

We recommend that the Regional Administrator, FEMA Region VI: 

Recommendation 1: Disallow as ineligible $1,473,045 ($1,104,784 Federal 

share) for contracts that did not fully comply with Federal procurement 

standards and overly restricted competition, unless FEMA decides to grant an 

exception to Federal requirements as 2 CFR 200.102(a) allows and determines 

that the costs are reasonable (finding A). 

Recommendation 2: Direct Texas to continue monitoring the County’s grant 

subaward activities to ensure it complies with all Federal grant requirements 

(finding B). 

Recommendation 3: Direct Texas to inform its grant subrecipients that using 

a shared services agreement does not relieve them of the responsibility to 

comply with Federal procurement requirements (finding B). 

Discussion with Management and Audit Follow-up 

We discussed the results of our audit with FEMA, Texas, and County officials 

during our audit. We considered their comments in developing our final report 

and incorporated their comments as appropriate. We also provided a draft 

report in advance to these officials and discussed it at exit conferences with 

FEMA officials on February 21, 2017; with County officials on February 23, 

2017; and with Texas officials on February 27, 2017. FEMA officials agreed 

with our findings and recommendations, while Texas and County officials 

generally disagreed. 

www.oig.dhs.gov 8 OIG-17-77-D 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA officials provided a written response on March 14, 2017, agreeing with 

our findings and recommendations (see appendix C). FEMA’s response and 

related actions were sufficient to resolve and close recommendations 2 and 3, 

but were not sufficient to resolve or close recommendation 1. Regarding 

recommendation 1, FEMA stated the following: 

Should Hays County (Applicant) submit claims to FEMA for 

reimbursement for disaster-related work completed via improperly 

procured contracts, FEMA will review all documentation submitted 

with the Applicant’s claim(s) to determine what costs, if any, are 

eligible for FEMA reimbursement, and whether they are reasonable. 

While we agree with FEMA’s planned actions, we cannot consider 

recommendation 1 as resolved because FEMA did not provide a target 

completion date for its planned actions. Further, we cannot close the 

recommendation until we verify that FEMA has completed the actions. 

Within 90 days of the date of this memorandum, please provide our office with 

a written response that includes your target completion date for 

recommendation 1. Also, please include contact information for responsible 

parties and any other supporting documentation necessary to inform us about 

the current status of the recommendation. Please email a signed PDF copy of 

all responses and closeout requests to emo.auditliaison@oig.dhs.gov. Until your 

response is received and evaluated, the recommendation will be considered 

open and unresolved. 

The Office of Emergency Management Oversight major contributors to this 

report were Tonda L. Hadley, Director; Christopher Dodd, Director (retired); 

Kathleen Hughes, Audit Manager; Rebecca Hetzler, Senior Auditor; 

William Lough, Senior Auditor; and James Mitchell, Independent Reference 

Reviewer. 

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

Paul Wood, Acting Deputy Assistant Inspector General, at (202) 254-4100 or 

Tonda L. Hadley, Director, Central Regional Office - South, at (214) 436-5200. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objective, Scope, and Methodology 

We audited Public Assistance grant funds awarded to Hays County, Texas, 

Public Assistance Identification Number 209-99209-00. Our audit objective 

was to determine whether the County accounted for and expended FEMA 

Public Assistance grant funds according to Federal regulations and FEMA 

guidelines for FEMA Disaster Number 4223-DR-TX. Texas awarded the 

County $3.2 million for damages resulting from severe storms, tornadoes, 

straight-line winds, and flooding that occurred May 4 through June 19, 2015. 

The audit covered the period May 4, 2015, through February 11, 2016, the 

cutoff date of our audit. The award provided 75 percent funding for four large 

and four small projects.4 We audited six projects obligated for $2.4 million that 

included $1.8 million for four contracts, each with a value greater than the 

simplified acquisition threshold.5 We also reviewed the County’s force account 

labor and force account material costs.6 In addition, we reviewed four projects 

not obligated by FEMA at the cutoff date of our audit totaling $412,785. 

Table 1 describes the projects we audited and costs we questioned. 

Table 1: Projects Audited 

Project 

Number 

Category 

of Work* 

Award 

Amount 

Cost 

Overrun/ 

(Underrun) 

Total 

Expended 

Questioned 

Costs 

427 A $ 1,330,658 $ 142,387 $ 1,473,045 $ 1,473,045 

992 A 655,155 58,717 713,872 0 

736 B 312,007 (35,673) 276,334 0 

402 C 78,317 9,974 88,291 0 

83 C 21,848 3,074 24,922 0 

277 B 11,306 (5,983) 5,323 0 

Subtotal $2,409,291 $172,496 $2,581,787 $1,473,045 

Unobligated 412,785 0 412,785 0 

Totals $2,822,076 $172,496 $2,994,572 $1,473,045 

Source: Project worksheets and Office of Inspector General (OIG) analysis 

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

emergency protective measures (Category B), and permanent work (Categories 

C through G). 

4 Federal regulations in effect at the time of the disaster set the large project threshold at 

$121,600 [Notice of Adjustment of Disaster Grant Amounts, 79 Federal Register 

(October 20, 2014)]. 

5 The simplified acquisition threshold was $150,000 and is the limit where an entity may make 

purchases using simple purchasing methods (2 CFR 200.88). 

6 “Force Account” means labor or equipment provided by the grantee or subgrantee, rather 

than by a contractor (Public Assistance Guide, FEMA 322, June 2007, p. 42). 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A (continued) 

To accomplish our objectives, we interviewed FEMA, Texas, HGAC, and Hays 

County officials, and assessed the adequacy of the procedures the County used 

to account for and expend Federal grant funds and to procure and monitor 

contracts for disaster work. We also assessed HGAC’s procurement practices 

the County used to solicit and award the two contracts for debris-related work. 

We judgmentally selected and reviewed project costs (generally based on dollar 

values) and procurement transactions; reviewed applicable Federal regulations 

and FEMA guidelines; and performed other procedures considered necessary to 

accomplish our objective.7 We did not perform a detailed assessment of the 

County’s internal controls over its grant activities because it was not necessary 

to accomplish our audit objective. 

We conducted this performance audit between February 2016 and 

February 2017, pursuant to the Inspector General Act of 1978, as amended, 

and according to generally accepted government auditing standards. Those 

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

appropriate evidence to provide a reasonable basis for our findings and 

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

obtained provides a reasonable basis for our findings and conclusions based 

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

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

disaster. 

7 We reviewed documentation showing the cancellation of a contract that occurred after our 

audit cutoff date. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Potential Monetary Benefits 

Table 2: Summary of Potential Monetary Benefits 

Type of Potential Monetary Benefit Amounts Federal Share 

Questioned Costs – Ineligible $ 1,473,045 $ 1,104,784 

Questioned Costs – Unsupported 0 0 

Funds Put to Better Use 0 0 

Totals $1,473,045 $1,104,784 

Source: OIG analysis of findings in this report 

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Department of Homeland Security 

Appendix C 

FEMA Region VI Response to Draft Report 

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Department of Homeland Security 

Appendix C (continued)
 

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Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Chief of Staff 

Chief Financial Officer 

Under Secretary for Management 

Chief Privacy Officer 

Audit Liaison, DHS 

Federal Emergency Management Agency 

Administrator 

Chief of Staff 

Chief Financial Officer 

Chief Counsel 

Chief Procurement Officer 

Director, Risk Management and Compliance 

Audit Liaison, FEMA Region VI 

Audit Liaison, FEMA (Job Code G-16-019) 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

External 

Division Chief, Texas Division of Emergency Management 

Deputy Assistant Director Response, Texas Division of Emergency Management 

Texas State Auditor’s Office 

Hays County Judge 

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