Department of Homeland Security
 

Connecticut’s Management of Homeland 


Security Program Grants Awarded During 


Fiscal Years 2008 Through 2010 


OIG-13-43 February 2013
 
 

 

 

ds 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security

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

FEB 28 2013 

MEMORANDUM FOR: 	 David J. Kaufman 

Acting Assistant Administrator 

Grant Programs Directorate 

Federal Emergency Management Agency 

FROM: 	Anne L. Richar

Assistant Inspector General for Audits 

SUBJECT: 	 Connecticut’s Management of Homeland Security Program 

Grants Awarded During Fiscal Years 2008 Through 2010 

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

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

incorporated the formal comments from the Federal Emergency Management Agency 

and the State of Connecticut in the final report. 

The report contains two recommendations aimed at improving the State of Connecticut’s 

management of State Homeland Security Program and Urban Areas Security Initiative 

Grants. Your office concurred with the two 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 John E. McCoy II, Deputy 

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

Attachment 
 

 

Table of Contents 

 


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


 


 


 


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


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


The State of Connecticut’s Grant Management Practices ..................................... 2 


 


 


 


Subgrantee Monitoring ........................................................................................... 3 


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


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


Timeliness of Grant Fund Obligations..................................................................... 6 


Recommendation ................................................................................................... 9 


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


Appendixes 

 


Appendix A: Objectives, Scope, and Methodology ........................................... 10 


Appendix B: Management Comments to the Draft Report

Appendix C: State of Connecticut’s Management Comments for the 


.............................. 13 


Draft Report .................................................................................. 15 


 


 


Appendix D: Subgrantee SHSP and UASI Grant Obligations .............................. 17 


Appendix E: Regional Map of Connecticut........................................................ 21 


Appendix F: Homeland Security Grant Programs ............................................. 22 


Appendix G: Major Contributors to This Report ............................................... 23 


Appendix H: Report Distribution ....................................................................... 24 


 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

 


 


 


 


 


 


www.oig.dhs.gov OIG-13-43

 


 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Abbreviations

CFR Code of Federal Regulations 

DHS Department of Homeland Security 

DEMHS Division of Emergency Management and Homeland Security 

DESPP Department of Emergency Services and Public Protection 

FEMA Federal Emergency Management Agency 

FY fiscal year 

GPD Grant Programs Directorate 

HSGP Homeland Security Grant Program 

MOA memorandum of agreement 

OIG Office of Inspector General 

OMB Office of Management and Budget 

SAA State Administrative Agency 

SHSP State Homeland Security Program 

UASI Urban Areas Security Initiative 

www.oig.dhs.gov OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary

Public Law 110-53, ImplementingfRecommendationsfoffthef9/11fCommissionfActfoff

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 Connecticut. 

The objectives of the audit were to determine whether the State of Connecticut 

distributed and spent State Homeland Security Program and Urban Areas Security 

Initiative grant funds effectively and efficiently and in compliance with applicable 

Federal laws and regulations and complied with the Department’s guidelines governing 

the use of funding. We also addressed the extent to which funds awarded enhanced 

the State’s ability to prevent, prepare for, protect against, and respond to natural 

disasters, acts of terrorism, and other manmade disasters. The State received grant 

awards of approximately $43.9 million in State Homeland Security Program and Urban 

Areas Security Initiative grants for fiscal years 2008 through 2010. 

In most instances, the State administered grant program requirements effectively and 

efficiently and in compliance with grant guidance and regulations. The State’s strategic 

plans linked goals and objectives to national priorities and DHS mission areas. Adequate 

controls existed over the approval of expenditures and reimbursement of funds. 

However, the State can improve its subgrantee monitoring activities and timeliness of 

grant fund obligations. We made two recommendations to the Federal Emergency 

Management Agency (FEMA) that, if implemented, should strengthen program 

management, performance, and oversight. Both FEMA and the State of Connecticut 

concurred with our recommendations and are in the process of taking corrective 

actions. 

www.oig.dhs.gov 1 OIG-13-43 
 

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. (See appendix F 

for additional details regarding the HSGP.) 

The governor of the State of Connecticut (State) designated the Connecticut Department 

of Emergency Services and Public Protection (DESPP) as the State Administrative Agency 

(SAA). Within the DESPP, the Division of Emergency Management and Homeland 

Security (DEMHS) administers grants. The SAA is responsible for managing the grant 

programs in accordance with established Federal guidelines and allocating funds to 

local, regional, and other State government agencies. The SAA subawarded the HSGP 

funds to two urban areas (Bridgeport and Hartford), five regions, and various State 

agencies. (See appendix E for a regional map of Connecticut.) 

The State received grant awards of approximately $45.5 million for the HSGP during 

fiscal years (FYs) 2008, 2009, and 2010. This included approximately $28.8 million in 

State Homeland Security Program (SHSP) funds and approximately $15.1 million in 

Urban Areas Security Initiative (UASI) grant funds. Appendix A provides details on the 

purpose, scope, and methodology for this audit. 

Results of Audit 

The State of Connecticut’s Grant Management Practices 

In most instances, the State did an effective job of administering grant program 

requirements in accordance with grant guidance and regulations. The State 

developed written procedures for program administration, linked its Homeland 

Security Strategic Plan goals and objectives to the national priorities and DHS 

mission areas, and allocated and spent funds based on national and State 

priorities. The State also had adequate controls over the approval of 

expenditures and reimbursement of funds. 

However, the following improvements will enhance Connecticut’s grant 

management practices: 

• Strengthen subgrantee monitoring. 

• Obligate grant funds timely. 

www.oig.dhs.gov 2 OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Subgrantee Monitoring 

The SAA did not conduct onsite monitoring visits to SHSP and UASI grant 

recipients for FYs 2008 and 2009 grant awards. Because of the State’s recent 

distribution of FY 2010 grant awards, sufficient monitoring data were not 

available for FY 2010 grant funds awards. In lieu of site visits for FYs 2008 and 

2009, the SAA performed a small percentage of desk monitoring for its SHSP and 

UASI subgrantees. As table 1 shows, the SAA performed desk monitoring 

for about 7 percent of its FY 2008 and 13 percent of FY 2009 UASI and SHSP 

subgrantees. 

Table 1. FYs 2008 Through 2010 Subgrantee Monitoring as of July 2012 

SHSP and UASI Subgrantees Monitored

FYs 2008 Through 2010

Program FY 2008 

Subgrantees 

FY 2009

Subgrantees FY 2010 Grant Awards 

SHSP and UASI 30 31 Monitoring Data 

Unavailable 

Subgrantees onsite monitored 0 0 Monitoring Data 

Unavailable 

Subgrantees desk monitored 2 4 Monitoring Data 

Unavailable 

Subgrantees monitored resulting 

from a cash advance or 

reimbursement request 

1 3 Monitoring Data 

Unavailable 

Percentage of subgrantees 

monitored 7% 13% Monitoring Data Unavailable 

Source: DHS OIG, compiled from SAA source documents. 

The Code of Federal Regulations, Office of Management and Budget (OMB), 

FEMA, and the SAA have specific guidance on grantee monitoring requirements. 

•	 Code of Federal Regulations (CFR) Title 44 §13.40, MonitoringfandfReportingf

ProgramfPerformance: Grantees are responsible for managing the day-today operations of grant- and subgrant-supported activities and ensuring that 

grant recipients comply with applicable Federal requirements and achieve 

program performance goals. This regulation also specifies that grantees’ 

monitoring programs must cover each program, function, or activity. 

•	 OMB Circular A-133, AuditsfoffStates,fLocalfGovernments,fandfNon-profitf

Organizations, Compliance Supplement, Part 3-M: Grantees are responsible 

for monitoring subgrantee use of Federal awards through reporting, site 

www.oig.dhs.gov 3 	 OIG-13-43 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

visits, regular contact, or other means. Grantee monitoring should provide 

reasonable assurance that the subgrantee administers Federal awards in 

compliance with laws and regulations, as well as the provisions of contracts 

or grant agreements. 

•	 FEMA, HomelandfSecurityfGrantfProgramfGuidancefandfApplicationfKit:

Grant recipients are responsible for monitoring award activities, including 

subawards, to provide reasonable assurance that the Federal award is 

administered in compliance with requirements. 

•	 SAA,fSubrecipientfGrantfManagementfandfMonitoringfProcedures: The SAA 

is responsible for conducting onsite monitoring visits for 10 percent of all 

subrecipients each fiscal year and conducting office-based desk monitoring 

reviews for 25 percent of the HSGP subgrantees. 

In addition to the guidance listed above, FEMA noted deficiencies with the SAA’s 

limited subgrantee monitoring. During a financial monitoring visit in June 2010, 

FEMA determined that the SAA did not adequately monitor subrecipients and 

recommended that it develop and implement a subgrantee monitoring plan that 

included both routine desk reviews and onsite financial monitoring. 

SAA officials are aware of this matter and discussed the need for improved 

subgrantee monitoring. One SAA official expressed concern that the State does 

not have assurance that equipment procured with grant funds is maintained and 

functioning properly because of limited onsite monitoring. Another SAA official 

discussed the need for improved desk monitoring to include all subgrantees, not 

just those submitting cash advance or reimbursement requests. 

SAA officials said that their review of cash advance and cash reimbursement 

requests and quarterly progress and financial reports provides the SAA with a 

mechanism to monitor subgrantees for potential performance or financial issues. 

However, this type of review does not provide the SAA with the firsthand 

knowledge obtained through onsite monitoring visits or sufficient oversight of 

the SHSP and UASI subgrantee awards. As of July 2012, SAA personnel had not 

monitored about $12.5 million, or 61 percent, of FYs 2008 and 2009 UASI and 

SHSP grant subawards (see table 2). 

www.oig.dhs.gov 4 	 OIG-13-43 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 2. FYs 2008 Through 2010 Grant Subawards Monitored as of July 2012
 

SHSP and UASI Subgrantees Monitored

FYs 2008 Through 2010

Program FY 2008 Grant 

Subawards

FY 2009 Grant 

Subawards

FY 2010 Grant 

Subawards*

SHSP and UASI $9,439,924 $11,043,309 Monitoring Data 

Unavailable 

Grant funds monitored through 

onsite monitoring None None Monitoring Data Unavailable 

Grant funds desk monitored $2,872,595 $5,074,990 Monitoring Data 

Unavailable 

Unmonitored SHSP and UASI 

grant funds $6,567,329 $5,968,319 Monitoring Data 


 Unavailable

Source: DHS OIG, compiled from FEMA and SAA source documents. 

As a result of the limited monitoring, the SAA did not fully evaluate whether the 

State spent funds in compliance with grant requirements and associated Federal 

and State regulations. Implementing a monitoring plan for all subgrantees 

through periodic onsite visits and office-based desk monitoring would address 

this problem and provide the SAA with firsthand knowledge of the subgrantees’ 

use of SHSP and UASI grant funds. It would also ensure that the SAA monitors all 

subgrantees, not just those submitting cash reimbursement or cash advance 

requests. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate 

(GPD): 

Recommendation #1:

Require the Connecticut Department of Emergency Services and Public 

Protection’s Division of Emergency Management and Homeland Security to 

ensure that the monitoring plan complies with all Federal and State monitoring 

guidelines. The monitoring plan should include a subgrantee monitoring 

schedule with on-site and desk monitoring for all SHSP and UASI subgrantees. 

www.oig.dhs.gov 5 OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendation #1: FEMA and the State 

concurred with this recommendation. FEMA shall require the State of 

Connecticut’s DESPP DEMHS to develop and implement a subgrantee monitoring 

plan that meets the requirements of 44 CFR § 13.40, Monitoringfandfreportingf

programfperformance. The Director shall submit to the FEMA GPD a copy of the 

subgrantee monitoring plan and schedule of site visits no later than 90 days after 

the issuance of the OIG final report. Based on the response in appendix C, the 

State is currently in the process of reviewing all grant programs in a total 

program/process review. This review includes the establishment of a detailed 

monitoring plan that addresses on-site visits by DEMHS personnel to subgrantees. 

Additionally, the review will include office-based desk monitoring, as required, of 

subgrantees. The State’s intent is to ensure that funds expended are in full 

compliance with grant requirements and all Federal and State regulations. 

OIG analysis: We consider FEMA’s actions responsive to the intent of 

recommendation 1, which is open and resolved. This recommendation will 

remain open pending confirmation of the submission of the subgrantee 

monitoring plan to FEMA GPD by the State of Connecticut, which includes on-site 

and desk monitoring. 

Timeliness of Grant Fund Obligations 

The SAA did not obligate grant funds timely. For FYs 2008 through 2010, the 

State did not meet the required 45-day obligation for SHSP and UASI grant funds. 

OMB Circular A-133 Compliance Supplement and FEMA’s FYs 2008, 2009, and 

2010 HSGP guidance requires the SAA to obligate 80 percent of funds awarded 

under SHSP and UASI grant programs to local units of government within 45 days 

of receipt of the funds. In addition, FEMA strongly encourages the timely 

obligation of funds from local units of government to other subgrantees. FEMA’s 

grant guidance states, “four requirements must be met to obligate grant funds: 

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

the awarding entity. 

•	 The action must be unconditional on the part of the awarding entity 

(i.e., no contingencies for availability of SAA funds). 

•	 There must be documentary evidence of the commitment. 

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

www.oig.dhs.gov 6 	 OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The SAA did not meet the grant requirements because of its lengthy approval 

and obligation process. The process begins when DEMHS issues grant application 

packages to subgrantees after it receives the grant award from FEMA in August 

or September. The applicants submit their completed applications, along with all 

attachments and signatures, to the SAA. To work around the need for county 

government structure within the State, DEHMS divided the State into five 

regions. Each region must also submit memorandums of agreement (MOAs)— 

between the region and each municipality within the region—to the SAA with its 

completed application package. (See appendix E for the DEHMS regional map.) 

This process can take days or months to complete. According to SAA and 

regional officials, the MOA process is an ongoing problem. Some regions obtain 

the necessary timely MOAs, while others cannot do so because of the 

procedures of the individual municipalities. Some municipalities meet monthly, 

while others may meet once or twice per year. These differences create a 

problem for the regions because they cannot submit their completed application 

without the signed MOAs from all municipalities. 

The SAA receives the grant award from FEMA and sends initial grant award 

letters to subgrantees for their review and approval. As with the MOA process, 

the subgrantees must follow their respective review and award processes. Once 

the award letters are reviewed and approved, the subgrantees send their signed 

award letters back to the SAA for final signature. The SAA prohibits subgrantees 

from expending any grant funds until they receive an executed grant award 

(agreement signed by all parties) from the SAA. 

The SAA fully obligated grant funds, on average, about 712 days after the 45-day 

requirement in FY 2008; about 636 days in FY 2009; and about 138 days in 

FY 2010. For example, although the State received grant awards from FEMA on 

September 3, 2008, the Capitol Region Council of Governments did not receive a 

fully executed award until March 2, 2012. To determine the number of days past 

the 45-day requirement, we calculated the number of days between the 46th 

day after FEMA’s award date and the day that the SAA signed the award letter. 

Table 3 provides detailed information regarding each grant award by fiscal year. 

www.oig.dhs.gov 7 OIG-13-43 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 3. Grant Obligations, FYs 2008 Through 2010
 

Grant Award 

Year 

Award Number FEMA 

Award 

Days to Obligate Avg. days past 45-day 

requirement 

2008 2008-GE-T8-0004 9/3/08 279 to 1,276 days 712 days 

2009 2009-SS-T9-0087 8/21/09 203 to 1,026 days 636 days 

2010 2010-SS-T0-0020 8/18/11* 74 to 302 days 138 days 

*FEMA issued a grant adjustment notice on August 18, 2011, to reobligate the FY 2010 grant 

award because of a vendor number issue. FEMA’s initial award date was September 17, 2010. 

We used FEMA’s grant adjustment notification date for analysis purposes. 

Source: DHS OIG, compiled from FEMA and SAA source documents. 

For FY 2010, the SAA could not access the grant in FEMA’s system and did not 

make subawards until the grant was reobligated in August 2011. Additionally, 

the SAA subgrantees cannot expend grant funds until the SAA receives a fully 

executed grant award and establishes a cost center in the State’s accounting 

system. SAA officials acknowledged that they missed the 45-day requirement, 

but do not believe that they could ever meet it because of their processes and 

the complexities of the “home rule State.” 

The SAA’s lengthy obligation process resulted in a large percentage of SHSP and 

UASI grant funds remaining unused within the 3-year performance period, 

requiring the SAA to request grant extensions from FEMA or risk losing the 

funds. Table 4 illustrates the percentage of grant awards as of June 13, 2012, 

that the SAA had not drawn down for grants awarded during FYs 2008–2010. 

Table 4. Connecticut Homeland Security Grant Program Drawdowns as of 

July 2012 

Grant 

Year 

Date of 

FEMA Award 

Total Grant 

Award 

Total 

Drawdowns 

Undrawn 

Balance 

Percentage 

Undrawn 

2008 9/3/08 $14,875,427 $10,857,972 $4,017,455 27% 

2009 8/21/09 $15,630,488 $3,062,223 $12,568,265 80% 

2010 8/18/11* $14,954,871 $401,698 $14,553,173 97% 

*FEMA issued a grant adjustment notice on August 18, 2011, to reobligate the FY 2010 grant 

award because of a vendor number issue. FEMA’s initial award date was September 17, 2010. 

We used FEMA’s grant adjustment notification date for analysis purposes. 

Source: DHS OIG, compiled from FEMA and SAA source documents. 

Updating the obligation process would make it more efficient and less timeconsuming for the SAA to obligate grant awards to subgrantees. It would also 

help the SAA draw down funds in a more timely manner. 

www.oig.dhs.gov 8 OIG-13-43 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation: 

We recommend that the Assistant Administrator, Grant Programs Directorate: 

Recommendation #2:

Require the Connecticut Department of Emergency Services and Public 

Protection’s Division of Emergency Management and Homeland Security to 

review and update its obligation and approval process to identify ways to 

shorten the time needed to meet grant requirements. 

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendation #2: FEMA and the State 

concurred with this recommendation. FEMA shall require the Director of 

Connecticut’s DESPP DEMHS to assess and streamline (where possible) processes 

and procedures for obligating funds to subgrantees. The Director shall report to 

GPD the results of this assessment and potential steps to be taken to expedite 

the obligation of funds to subgrantees no later than 90 days after the issuance of 

this report. 

As previously noted, the State is currently reviewing all grant programs in a total 

program/process review. In its response, included as appendix C, the State 

noted that timeliness in the obligation of funds is a top priority. The State 

acknowledges that the approval process needs to be efficient, streamlined, and 

less time consuming. Although the State noted that it has made progress in the 

timely obligation of funds, it also noted that the standard of 45 days established 

by OMB and FEMA to obligate funds under SHSP and UASI grant programs are 

ideally designed for States with county governments. Furthermore, the State 

noted that Connecticut is one of only two States that do not have county 

governments. As a result, the State deals directly with 170 separate 

municipalities and two Tribal Nations, which directly affects its ability to attain 

the standard. 

OIG analysis: We consider FEMA’s actions responsive to the intent of 

recommendation 2, which is open and resolved. This recommendation will 

remain open pending confirmation of the report to GPD of the results of the 

assessment and potential steps to be taken to expedite the obligation of funds to 

the subgrantees. 

www.oig.dhs.gov 9 OIG-13-43 
 

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 HomelandfSecurityfActfoff2002 (Public Law 107-296) by amendment 

to the InspectorfGeneralfActfoff1978. 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 purpose of this audit was to determine whether the State of Connecticut distributed 

and spent SHSP and UASI grant funds strategically, effectively, and in compliance with 

laws, regulations, and guidance. We also addressed the extent to which the funds 

awarded enhanced the State’s ability to prevent, prepare for, protect against, and 

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

identified problems and solutions that will assist FEMA and the State in improving the 

Nation’s ability to prevent and respond to all hazards on a local and statewide level. 

Together, the entire HSGP and its five interrelated grant programs (see table 5) fund a 

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

training, exercises, and management and administration costs. However, for compliance, 

we reviewed only SHSP and UASI funding, and equipment and programs supported by 

the grant funding. Appendix F provides additional information on these grant programs. 

Table 5. State of Connecticut Homeland Security Grant Program Awards for FYs 2008 

Through 2010 

State of Connecticut’s Homeland Security Grant Program Awards

FYs 2008 Through FY 2010 

Funded Activity 

Grant Program Amounts

2008 2009 2010 Totals

SHSP $10,380,000 $9,545,500 $8,894,442 $28,819,942 

UASI $3,964,000 $5,554,400 $5,564,404 $15,082,804 

Subtotals $14,344,000 $15,099,900 $14,458,846 $43,902,746 

Citizens Corps Program $210,206 $209,367 $178,606 $598,179 

Metropolitan Medical 

Response System $321,221 $321,221 $317,419 $959,861 

Total $14,875,427 $15,630,488 $14,954,871 $45,460,786 

Source: DHS OIG, compiled from FEMA source documents. 

The audit methodology included interviews with FEMA representatives as well as work 

at the SAA, the five regions, and various subgrantee locations. To achieve our audit 

objective, we analyzed data, reviewed documentation, and interviewed key State and 

www.oig.dhs.gov 10 OIG-13-43 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

local officials directly involved in State HSGP management and administration. 

In addition to the SAA, we visited the following 12 subgrantee organizations: 

UASI Recipients 

• Region 1 – City of Bridgeport and its fiduciary (City of Stamford) 

• Region 3 – City of Hartford 

Regional Offices 

• Region 1 – City of Bridgeport 

• Region 2 – Connecticut River Estuary Regional Planning Agency 

• Region 3 – City of Hartford 

• Region 4 – Windham Region Council of Governments 

• Region 5 – Council of Governments of Central Naugatuck Valley 

State Agencies 

• State Capitol Police Department 

• Department of Emergency Services and Public Protection 

Local Jurisdictions and First Responders 

• Capital Region Council of Governments 

• Eastern Connecticut State University 

• University of Connecticut 

To determine the effectiveness of the State’s grant program and compliance with 

requirements, we conducted site visits and held discussions with appropriate officials 

from selected subgrantees, urban areas, and local jurisdictions. We reviewed 

documentation supporting State and subgrantee management of grant funds, including 

expenditures for equipment, training, and exercises. We tested property and payment 

transactions, inspected some of the equipment procured with the grant funds, and 

analyzed the procurement process. In addition, we met with representatives of first 

responder organizations such as fire and police departments to discuss the grant 

process and the benefits the grant funds have brought to their organization and 

communities. These key management processes included the following: 

• Threat, capability, and needs assessment 

• State strategic plans 

www.oig.dhs.gov 11 OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

• Training and exercise 

• Grant application preparation and submission 

• Grant funds allocation 

• Grant expenditure and reporting 

• Grant monitoring 

We reviewed documentation related to 72 grants awarded to subgrantees from 

FYs 2008 to 2010. We relied on the grant award documents provided by the State and 

tested these documents for completeness. We also reviewed a judgmental sample of 

the grant expenditures, representing approximately 13 percent of the dollar value 

awarded for the FYs 2008–2010 grants, to determine whether the expenditures were 

supported and allowable under the grants. We judgmentally chose specific equipment 

items to observe at local sites. We did not test for completeness for FY 2010, since that 

year’s subgrants were in the award process. 

We relied on computer-processed data provided by the State for information regarding 

its drawdowns from FYs 2008–2010 grant awards. We did not perform any internal 

control testing of this information, as it was not the basis for our report findings and 

recommendations. We judgmentally selected a sample of 24 purchases and verified the 

accuracy of the information obtained from the computer system. 

We conducted this performance audit between March and July 2012 pursuant to the 

InspectorfGeneralfActfoff1978, 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 12 OIG-13-43 
OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report

U.S. l>cparlmcnC Qr Ilomdand SC(lIricy 

W3Shinscon. DC 72 

JAN 1 7 1013 

MEMORANDUM FOR: Annc L. Richards 

Assistant Inspector General for Audits 

Offi ce of Inspector General 

FROM: David J. Kaurman ;t; ~ Associate Administrafor f;-

Policy, Program Analysis and International AfTairs 

SUBJECT: Response to OIG Draft Report: Response to Draft Report Connecticul 

Mal1agemem o/SHSP and UASI Crilllls Awarded During Fiscal Years 

2008 Through 20 J 0 

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

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

recognize the need to continue to improve the process, including addressing the recommendations 

raised in this report. Our responses to the recommendations are as follows: 

Recommendation #1: We recommcnd that the Assistant Administrator, Grant Programs Directorate 

requjre the Connecticut Department of Emergency Services and Public Protection's Division of 

Emergency Management and Homeland Security to ensure that the monitoring plan complies with 

all Federal and State monitoring guidelines. The monitoring plan should include a subgrantee 

monitoring schedule with onsite and desk monitoring for all SHSP and UASI subgrantces. 

FEMA Response: FEMA concurs with this recommendation. The Assistant Administrator, Grant 

Programs Directorate shall require the Director o f Connecticut Department of Emergency Services 

and Public Protection'S Division of Emergcncy Management and Homeland Security to develop and 

implement a subgrantec monitoring plan that meets the requirements of 44 CFR § 13.40 Monitoring 

and reporting program performance. The Director shall submit to GPD a copy of the subgrantce 

monitoring plan and schedule of site visits no later than 90 days after the issuance of the OIG final 

report. 

FEMA requests this recommendation be resolved and open pending the submittal of the Connecticut 

subgrantee monitoring plan and schedule to GPD. Estimated Completion Date (ECD): June 28, 

2013. 

Recommendation #2 : We recommend that the Assistant Administrator, Grant Programs 

Directorate require the Director o f Connecticut Department of Emergency Services and Public 

www.oig.dhs.gov 13 OIG-13-43 
OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Protection's Division of Emergency Management and Homeland Security to review and update its 

obligation and approval process to identify ways to shorten the time needed to meet grant 

requirements. 

FEMA RespoDse: FEMA concurs with this recommendation. The Assistant Administrator of the 

Grants Programs Directorate shall require the Director of Connecticut Department of Emergency 

Services and Public Protection's Division of Emergency Management and Homeland Security to 

assess and streamline (where possible) processes and procedures for obligating funds to subgrantees. 

The Director shall report to GPO the results of this assessment and potential steps to be taken to 

expedite the obligation of funds to the subgrantees no later than 90 days after the issuance of the 

OlG final report. 

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

action. ECD: June 28. 2013. 

Thank you for the work that you and your tearn did to better infonn us throughout this audit. We 

look forward to the final report. Please direct any questions regarding this response to Gary 

McKeon, FEMA's Chief Audit Liaison, at 202-646-1308 

 

www.oig.dhs.gov 14 OIG-13-43 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

State of Connecticut’s Management Comments for the Draft 

Report

www.oig.dhs.gov 15 OIG-13-43 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

- 2-

Management and Budget (OMB) and the Federal Emerge,\cy Management Agency 

(FEMA) to obligate tunds awarded under ttle State Homeland Security Program (SHSP) 

and Urban Area Secur~y Initiative (UASI) grant programs is ideally designed for states 

that have county govemment. Connecticllt is one of only two states that do nol have 

county government As such, the State of Connecticut must dlreclly deal with 170 

separate municipalities and two Tribal Nat/ons. While this is addressed in the draft 

audit, considerations should be made in the futLore for the unique form and type of 

government that exists in Connecticut as it directly affects the abil~y of the State of 

Connecticut to attain the standard. 

Please let me know if you have any questions or If you require any additional 

informalion. I can be reached at 860.256.0810 or via e-mail at willi.m .• hAa@ct. gov. 

Sincerely, 

~d~ Witliam P. Shea 

DeplIty Commissioner 

Deparlment of Emergency Services and Public Protection 

Division of Emergency Management and Homeland Securily 

cc: 

Reuben F. Bradford, Commissionsr DESPP 

William J. Hackstt, Emergency Management Director, DEMHS 

Brenda M. Bergeron, Chief of Staff, DEMHS 

RoseMarie Peshka, Fiscal Manager, DESPP 

Megan Sopelak, Fiscal Manager, DESPP 

25 Sigol/mey Streol, tiro, floor, Hartford, CT 06106 

Pilon,,: 860.256.0800 / FaK: 860.256,0815 

An Affirmative Action/Equal Opportullity Employor 

 

www.oig.dhs.gov 16 OIG-13-43 
 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Subgrantee SHSP and UASI Grant Obligations 

FY 2008 Subgrantees

Subgrantee Grant 

Award 

Award 

Amount

Date of 

FEMA 

Award 

Obligation 

Date 

Days to 

Obligate

Capitol Region Council of 

Governments 008ACRGD $7,500 9/3/2008 3/2/2012 1,276 

Litchfield Hills Council of Elected 

Officials 008ALHCB $7,500 9/3/2008 2/15/2012 1,260 

Litchfield Hills Council of Elected 

Officials 008ALHCA $40,000 9/3/2008 2/15/2012 1,260 

Windham Region Council of 

Governments 008AWINB $7,500 9/3/2008 12/28/2011 1,211 

Department of Energy and 

Environmental Protection 008ADEPA $40,000 9/3/2008 11/30/2011 1,183 

Town of Westport 008A158A $7,500 9/3/2008 11/8/2011 1,161 

Capitol Region Council of 

Governments 008ACRGA $1,091,600 9/3/2008 6/6/2011 1,006 

South Central Regional Council of 

Governments 008ASCRA $40,000 9/3/2008 5/24/2011 993 

Capitol Region Council of 

Governments 008ACRGC $40,000 9/3/2008 12/30/2010 848 

City of Hartford 008A064A $60,000 9/3/2008 12/20/2010 838 

City of Bridgeport 008A015A $1,020,600 9/3/2008 12/9/2010 827 

City of New Haven 008A093A $30,000 9/3/2008 11/12/2010 800 

Town of Wilton 008A161A $60,000 9/3/2008 11/12/2010 800 

Connecticut River Estuary 

Regional Planning Agency 008ACREA $150,000 9/3/2008 10/29/2010 786 

Department of Public Health 008ADPHA $276,963 9/3/2008 9/3/2010 730 

Town of Clinton 008A027A $60,000 9/3/2008 8/5/2010 701 

Borough of Naugatuck 008A088A $60,000 9/3/2008 7/27/2010 692 

Town of Waterford 008A152A $60,000 9/3/2008 7/26/2010 691 

Capitol Region Council of 

Governments 008MCRGA $321,221 9/3/2008 6/9/2010 644 

University of Connecticut 008AUCTA $14,797 9/3/2008 2/4/2010 519 

Department of Emergency 

Services & Public Protection 008ADPSA $221,370 9/3/2008 2/4/2010 519 

University of Connecticut Health 

Center 008AUCHA $5,008 9/3/2008 1/22/2010 506 

Western Connecticut State 

University 008AWCSA $5,761 9/3/2008 1/22/2010 506 

www.oig.dhs.gov 17 OIG-13-43 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Southern Connecticut State 

University 008ASCSA $7,518 9/3/2008 1/22/2010 506 

Council of Governments of 

Central Naugatuck Valley 008ACNVA $935,100 9/3/2008 1/22/2010 506 

State Capitol Police Department 008ACAPA $7,734 9/3/2008 1/19/2010 503 

Eastern Connecticut State 

University 008AECSA $6,012 9/3/2008 1/13/2010 497 

Windham Region Council of 

Governments 008AWINA $951,700 9/3/2008 9/30/2009 392 

City of Stamford 008U135A $1,937,495 9/3/2008 6/9/2009 279 

Capitol Region Council of 

Governments 008UCRGA $1,967,045 9/3/2008 6/9/2009 279 

Source: DHS OIG, compiled from FEMA and SAA source documents. 

FY 2009 Subgrantees

Subgrantee Grant 

Award 

Award 

Amount

Date of 

FEMA 

Award 

Obligation 

Date 

Days to 

Obligate

Town of Westport 009A158B $16,373 8/21/2009 6/12/2012 1,026 

City of New Haven 009A093A $834 8/21/2009 3/14/2012 936 

Windham Region Council of 

Governments 009AWINB $5,000 8/21/2009 3/6/2012 928 

Capitol Region Council of 

Governments 009ACRGD $5,000 8/21/2009 3/2/2012 924 

Litchfield Hills Council of Elected 

Officials 009ALHCB $5,000 8/21/2009 2/15/2012 908 

Litchfield Hills Council of Elected 

Officials 009ALHCA $40,000 8/21/2009 2/15/2012 908 

City of Hartford 009A064B $31,772 8/21/2009 12/29/2011 860 

Department of Energy and 

Environmental Protection 009ADEPA $40,000 8/21/2009 11/30/2011 831 

Town of Westport 009A158A $5,000 8/21/2009 11/8/2011 809 

Capitol Region Council of 

Governments 009MCRGA $321,221 8/21/2009 11/3/2011 804 

South Central Regional Council 

of Governments 009ASCRA $40,000 8/21/2009 10/12/2011 782 

Town of Clinton 009A027A $60,000 8/21/2009 7/20/2011 698 

City of Hartford 009A064A $60,000 8/21/2009 7/20/2011 698 

Town of Wilton 009A161A $60,000 8/21/2009 7/20/2011 698 

Town of Waterford 009A152A $60,000 8/21/2009 7/8/2011 686 

Borough of Naugatuck 009A088A $60,000 8/21/2009 6/29/2011 677 

Department of Public Health 009ADPHA $255,000 8/21/2009 6/9/2011 657 

City of Bridgeport 009A015A $973,750 8/21/2009 5/31/2011 648 

www.oig.dhs.gov 18 OIG-13-43 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Capitol Region Council of 

Governments 009ACRGC $40,000 8/21/2009 5/27/2011 644 

Capitol Region Council of 

Governments 009ACRGB $914,500 8/21/2009 5/27/2011 644 

Southern Connecticut State 

University 009ASCSA $7,572 8/21/2009 5/25/2011 642 

Council of Governments of 

Central Naugatuck Valley 009ACNVA $698,875 8/21/2009 4/8/2011 595 

Central Connecticut State 

University 009ACCSA $6,556 8/21/2009 3/31/2011 587 

Connecticut River of Estuary 

Regional Planning Agency 009ACREA $851,250 8/21/2009 3/18/2011 574 

Department of Emergency 

Services & Public Protection 009ADPSA $222,456 8/21/2009 3/11/2011 567 

Eastern Connecticut State 

University 009AECSA $6,556 8/21/2009 12/30/2010 496 

University of Connecticut 009AUCTA $17,804 8/21/2009 12/30/2010 496 

Windham Region Council of 

Governments 009AWINA $759,625 8/21/2009 12/30/2010 496 

State Capitol Police Department 009ACAPA $8,080 8/21/2009 12/16/2010 482 

Capitol Region Council of 

Governments 009ACRGA $2,705,845 8/21/2009 3/30/2010 221 

City of Stamford 009A135A $2,765,240 8/21/2009 3/12/2010 203 

Source: DHS OIG compiled from FEMA and SAA source documents 

FY 2010 Subgrantees

Subgrantee Grant 

Award 

Award 

Amount

Date of 

FEMA 

Award 

Obligation 

Date 

Days to 

Obligate

Capitol Region Council of 

Governments 010MRCGA $317,419 8/18/2011 6/15/2012 302 

Hartford UASI 010ACRGB $2,683,242 8/18/2011 6/15/2012 302 

Western CT State University 010AWCSA $5,504 8/18/2011 5/18/2012 274 

Department of Public Health 010ADPHA $297,500 8/18/2011 4/12/2012 238 

Windham Region Council of 

Governments 010AWINA $679,625 8/18/2011 1/26/2012 161 

University of Connecticut 010AUCTA $17,087 8/18/2011 1/13/2012 148 

Southern Connecticut State 

University 010ASCSA $7,193 8/18/2011 1/11/2012 146 

State Capitol Police Department 010ACAPA $7,664 8/18/2011 1/11/2012 146 

Eastern Connecticut State 

University 010AECSA $6,228 8/18/2011 1/9/2012 144 

www.oig.dhs.gov 19 OIG-13-43 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Council of Governments of 

Central Naugatuck Valley 010ACNVA $608,875 8/18/2011 10/31/2011 74 

Connecticut River Estuary 

Regional Planning Agency 010ACREA $827,250 8/18/2011 10/31/2011 74 

Source: DHS OIG, compiled from FEMA and SAA source documents. 

www.oig.dhs.gov 20 OIG-13-43 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Regional Map of Connecticut 

Connecticut, through DEMHS, designated 169 municipalities and two Native American 

Tribal Nations as local jurisdictions. Although the State has eight distinct counties, there 

are no corresponding government entities that either provide or support public safety 

services. Therefore, DEMHS developed five regions to provide a system of emergency 

management coverage to the State. 

Source: Connecticut DESPP DEMHS
 

www.oig.dhs.gov 21 OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Homeland Security Grant Programs

The 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 HSGP 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 SHSP. FEMA expends funding 

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 (beginning in FY 2010) 

www.oig.dhs.gov 22 	 OIG-13-43 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G 

Major Contributors to This Report 

Paul Wood, Audit Director 

LaParacina Williams, Audit Manager 

David DeHaven, Auditor-in-Charge 

Virginia Feliciano, Auditor 

Andrew Herman, Auditor 

Keith Lutgen, Program Analyst 

Katrina Bynes, Referencer 

www.oig.dhs.gov 23 OIG-13-43 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix H

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, Grants Programs Directorate 

FEMA Audit Liaison 

Grants Program 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 24 OIG-13-43 
 

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

at: @dhsoig. 

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