Department of Homeland Security
 

Indiana’s Management of State Homeland 


Security Program and Urban Areas Security Initiative 


Grants Awarded During Fiscal Years 2008–2010 


OIG-13-45 February 2013
 
 

 

 

 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: rds 

ector General for Audits 

Anne L. Richa

Assistant Insp

SUBJECT: Indiana’s Management of State Homeland Security 

Program and Urban Areas Security Initiative Grants 

Awarded During Fiscal Years 2008–2010

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

Security Program and Urban Areas Security Initiative Grants Awarded During Fiscal Years 

2008–2010. We incorporated the formal comments from the Federal Emergency 

Management Agency and the State of Indiana in the final report. 

The report contains five recommendations aimed at improving the overall effectiveness 

of the State of Indiana’s management of State Homeland Security Program and Urban 

Areas Security Initiative grants. Your office concurred with all five recommendations. 

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

recommendations 1 through 3 and 5 open and resolved, and recommendation 4 closed 

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

please submit a formal closeout letter to us within 30 days so that we may close the 

recommendations. The memorandum should be accompanied by evidence of 

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

amounts. 

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

copies of our report to appropriate congressional committees with oversight and 

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

the report on our website for public dissemination. 

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

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

Attachment 
 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

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

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

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

Improvements Are Needed To Enhance the State of Indiana’s Grant 

Management Practices........................................................................................... 3

Recommendations ............................................................................................... 10 

Management Comments and OIG Analysis ......................................................... 11 

Appendixes 

Appendix A: Objectives, Scope, and Methodology ........................................... 14 

Appendix B: FEMA Management Comments to the Draft Report .................... 18 

Appendix C: State of Indiana Management Comments to the Draft Report.... 21 

Appendix D: Description of Homeland Security Grant Program....................... 27 

Appendix E: State of Indiana Homeland Security Districts ............................... 28 

Appendix F: Grant Transaction Flowchart ........................................................ 29 

Appendix G: Major Contributors to This Report ............................................... 30 

Appendix H: Report Distribution ....................................................................... 31 

Abbreviations 

CFR Code of Federal Regulations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency

FY fiscal year

GMS Grants Management Section 

GPD Grant Programs Directorate 

HSGP Homeland Security Grant Program 

IDHS Indiana Department of Homeland Security 

OIG Office of Inspector General

SMART specific, measurable, achievable, results-oriented, and time-limited 

SHSP State Homeland Security Program 

UASI Urban Areas Security Initiative 

OIG Office of Inspector General

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary

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

2007, as amended, 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 Indiana. 

The objectives of the audit were to determine if the State of Indiana 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. We also addressed the extent to which grant funds enhanced Indiana’s 

ability to prevent, prepare for, protect against, and respond to natural disasters, acts of 

terrorism, and other manmade disasters. The audit included a review of approximately 

$57.3 million in State Homeland Security Program and Urban Areas Security Initiative 

grants awarded to Indiana during fiscal years 2008 through 2010. 

In most instances, the State of Indiana distributed and spent the awards in compliance 

with applicable laws and regulations. However, we identified several areas in which the 

Federal Emergency Management Agency (FEMA) and the State can improve management 

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

Specifically, the State needs to revise its State Homeland Security Strategy and the

Indianapolis Urban Area Homeland Security Strategy to include measurable objectives 

with realistic target dates for completion, obligate grant funds promptly, and monitor 

subgrantee compliance with inventory management requirements. Additionally, FEMA 

should ensure that the State closely monitors the obligation and expenditure of Urban 

Areas Security Initiative grants. 

As a result of the issues discussed in the report, the State (1) could not fully assess 

whether State Homeland Security Program and Urban Areas Security Initiative funding 

enhanced its preparedness and security; (2) may have negatively affected planning and 

delayed the expenditure of grant funds; (3) could not ensure that assets purchased with 

grant funds were adequately safeguarded to prevent loss, theft, or misuse; and (4) may 

have unnecessarily delayed improvements to the Indianapolis Urban Area’s 

preparedness and security. These issues existed because FEMA and the State of Indiana 

did not provide sufficient guidance and oversight of the grant process. We made five 

recommendations for FEMA to initiate improvements which, if implemented, should 

help strengthen grant program management, performance, and oversight. FEMA 

concurred with all five recommendations. 

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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. Within DHS, 

FEMA is responsible for administering the HSGP. To support preparedness, FEMA 

develops policies, ensures that adequate plans exist and are validated, defines 

capabilities required to address threats, provides resources and technical assistance to 

States, and synchronizes preparedness efforts throughout the Nation. Appendix D 

provides a detailed description of the HSGP’s interrelated grant programs.

HSGP guidance requires the Governor of each State and Territory to designate a State 

Administrative Agency to apply for and administer grant funding awarded under the 

HSGP. The State Administrative Agency is the only entity eligible to apply for HSGP 

funds. FEMA requires that the State Administrative Agency be responsible for obligating 

grant funds to local units of government and other designated recipients within 45 days 

after receipt of funds. The Indiana Department of Homeland Security (IDHS) is the State 

Administrative Agency responsible for administering the HSGP. Within IDHS, the Grants 

Management Section (GMS) manages Federal grant funding awarded to Indiana for the 

advancement of homeland security initiatives, in accordance with the Indiana Strategy 

for Homeland Security. 

Federal regulations require that grantees monitor grant and subgrant-supported 

activities to ensure compliance with Federal requirements and achievement of 

performance goals. DHS guidance requires States to develop strategies that include 

objectives that set a target level of performance over time against which actual 

achievement can be compared. Further, objectives should be specific, measurable, 

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

FEMA awarded the State of Indiana more than $57 million in HSGP funds during fiscal 

years (FY) 2008, 2009, and 2010. This included $35.6 million in State Homeland Security 

Program (SHSP) grant funds and $21.7 million in Urban Areas Security Initiative (UASI) 

grant funds. Indiana has 92 counties that are divided into 10 Homeland Security 

Districts. Appendix E depicts the 10 Homeland Security Districts. IDHS awarded SHSP 

funds to subgrantees in various state agencies, counties, and local jurisdictions within 

the districts. IDHS also awarded UASI funds to its one urban area, the Indianapolis 

Urban Area, which includes the City of Indianapolis, and Marion and Hamilton Counties. 

Appendix A provides details on the audit objectives, scope, and methodology.

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

Improvements Are Needed To Enhance the State of Indiana’s Grant 

Management Practices

In most instances, the State of Indiana distributed and spent SHSP and UASI grant 

funds in compliance with applicable Federal laws and regulations. However, we 

identified four areas in which FEMA and the State can improve management of 

SHSP and UASI grant programs. Specifically:

•	 The Indiana Strategy for Homeland Security (State strategy) and the 

Indianapolis Urban Area Homeland Security Strategy (urban area strategy) 

include some objectives that did not set measurable target levels of 

performance over time. 

•	 IDHS did not obligate grant funds within 45 days of receiving FEMA grant 

awards. 

•	 Subgrantees did not manage grant-funded equipment inventory according to 

Federal regulations or IDHS internal guidance. 

•	 FEMA did not ensure that IDHS closely monitored the obligation and 

expenditure of the 2008 UASI grant. 

As a result, the State (1) could not fully assess whether SHSP and UASI funding 

enhanced its preparedness and security; (2) may have negatively affected 

planning and delayed the expenditure of grant funds; (3) could not ensure that 

assets purchased with grant funds were adequately safeguarded to prevent loss, 

theft, or misuse; and (4) may have unnecessarily delayed improvements to the 

Indianapolis Urban Area’s preparedness and security. 

Measurable Performance 

Indiana’s State strategy and the urban area strategy include some objectives that 

do not set measurable target levels of performance over time. The State 

strategy contains several objectives that are not specific or measurable. Both 

strategies contained some objectives that omitted target dates for achieving the 

objectives. FEMA did not demonstrate that it provided the State with comments 

on its strategy, nor was there evidence to support its approval of either strategy. 

As a result, IDHS could not fully assess whether SHSP and UASI funding enhanced 

the preparedness and security of the State of Indiana. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

According to 44 Code of Federal Regulations (CFR) 13.40(a), Monitoring and 

Reporting Program Performance, grantees must monitor grant- and subgrantsupported activities to ensure compliance with applicable Federal requirements 

and achievement of performance goals. 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, an objective sets a target level of performance over time 

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

as a quantitative standard, value, or rate. 

The guidance also mandates that an objective be SMART. For example, specific 

objectives help identify what is to be achieved and accomplished. Measurable 

objectives must be quantifiable. Time-limited objectives should have a target 

date for achieving the objective. 

In its January 2010 assessment of Indiana’s February 2008 State strategy, IDHS 

itself noted that some of its objectives did not comply with the SMART guidelines 

outlined by DHS. According to the assessment, several of the objectives and 

associated measures were very difficult to evaluate because of their generic 

wording. The report suggested that future objectives and measurements be 

developed using the SMART standard. 

For example, under the strategy’s second goal, Planning and Risk Analysis, 

Objective 2.8 – Institutionalize the National Incident Management System, 

according to the IDHS assessment, “the program manager indicated that due to 

the importance of this program it should be retained in the next strategy

however, the measure needs to be more specific/measurable.” 

Also, under the strategy’s third goal, Protect, Objective 3.1i – Implement a

system that allows first responders access to building floor plans, IDHS noted 

that the program was no longer applicable and “determined to be unachievable 

due primarily to lack of a funding stream from the IDHS permitting process.” 

Both the February 2008 State strategy and the April 2007 urban area strategy 

contained some objectives and measures that were not time-limited. The State 

strategy contained 8 goals and 146 objectives to address the four mission areas 

and eight national priorities of the National Preparedness Guidelines. However, 

27 of these objectives did not include target dates for achieving the objective. 

Similarly, the urban area strategy, dated April 3, 2007, contained 8 goals and 53 

objectives, but 29 objectives had no target date for achievement. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Congress has shown interest in FEMA’s efforts to develop metrics and measures 

for the HSGP grants. Under Public Law 111-271, Redundancy Elimination and 

Enhanced Performance for Preparedness Grants Act, Congress required the 

National Academy of Public Administration to assist FEMA in developing and 

implementing measurable national preparedness capability requirements and 

evaluation criteria. These requirements are to include a specific timetable for 

promptly developing a set of quantifiable performance measures and metrics to 

assess the effectiveness of the programs under which covered grants are awarded. 

FEMA did not demonstrate that it provided Indiana with comments on its State 

strategy. Although a FEMA program analyst said that FEMA reviewed and 

provided comments on all State strategies, the analyst did not provide us with 

any evidence of those comments to Indiana. Also, IDHS reported that FEMA did 

not provide feedback on Indiana’s State strategy. 

FEMA also did not approve either Indiana’s latest State strategy or the urban 

area strategy. FEMA provided the OIG team with a copy of the State strategy 

marked “Approved by FEMA” which showed many completion dates of 2005 

through 2008 for implementation steps. IDHS provided a State strategy dated 

February 6, 2008, which was an updated version of the strategy that FEMA 

provided. The 2008 document contained completion dates of 2008 through 

2010, and IDHS confirmed the strategy FEMA provided was not the most current 

version. IDHS also provided a copy of the urban area strategy dated April 3, 

2007. Neither IDHS nor the UASI could provide documentation showing that 

FEMA had approved either strategy. 

Without measurable goals and objectives in the State and urban area strategies, 

the State could not evaluate progress, compile key management information 

accurately, track trends, and keep planned work on track. Moreover, 

measurable goals and objectives would provide the State with a basis to evaluate 

its progress in improving preparedness, prevention, response, and recovery

capabilities.

Obligation of Grant Funds 

IDHS did not obligate SHSP and UASI grant funds within 45 days as required by 

DHS Homeland Security Grant Program Guidance and Application Kits for FYs 

2008, 2009, and 2010. The kits also contained the following requirements: 

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

the awarding entity; 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

funds) on the part of the awarding entity; 

•	 There must be documentary evidence of the commitment; and 

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

We reviewed 36 awards that IDHS made to 10 local SHSP subgrantees from 

FY 2008 through FY 2010. Of these 36 awards, IDHS initially documented 

commitment of funds by issuing nine grant award letters. Three of the nine 

award letters were dated more than 45 days after IDHS received the award from 

FEMA. For the other 27 awards, IDHS signed subgrant agreements to document 

the written commitment of funds. These 27 subgrant agreements were signed 

between 132 and 781 days after FEMA awarded the grants to IDHS. 

An IDHS official said its GMS did not send grant award letters to subgrantees for 

every project. Although the GMS sent letters to subgrantees for district 

allocations, the GMS relied on project managers to send non-district award 

letters for projects such as Exercise Initiatives, Explosives Ordinance Device 

Projects, and Critical Infrastructure. The GMS was unaware that project managers 

were not sending the letters until we requested them during our audit. 

IDHS also did not issue a written commitment for the 2008 UASI funds, as 

required by FEMA, prior to signing a subgrant agreement with the City of 

Indianapolis. IDHS said it did not issue a commitment letter to the UASI because 

its award is always 80 percent of the UASI allocation. FEMA awarded the 2008 

UASI funds to Indiana on August 22, 2008. IDHS signed a subgrant agreement 

with the city on April 30, 2010, or 616 days after FEMA awarded the grant to IDHS. 

Not documenting commitment of funds to subgrantees promptly can negatively 

affect planning and delay expenditure of grant funds. The State’s Homeland 

Security Districts evaluate spending proposals through each District’s Planning 

Council and Oversight Committee. The districts then send proposals to IDHS for 

projects to which they would like to apply for grant funding. After IDHS reviews 

the proposed projects, it may award less funding to the districts than they 

requested in their budget proposals. If IDHS does not notify them promptly, 

districts may need to restart the process of prioritizing which of its previously 

proposed projects to fund. Accordingly, reprioritizing projects can increase the 

amount of time the district takes to spend the funds. 

Inventory Requirements 

IDHS’ subgrantees did not consistently manage grant-funded inventory equipment 

according to Federal regulations or IDHS internal guidance. Specifically, 

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Department of Homeland Security 

subgrantees did not comply with the property maintenance and physical 

inventory requirements of 44 CFR 13.32(d), Management Requirements, or IDHS’ 

Administrative Plan for Grants Managed by the Indiana Department of 

Homeland Security, dated April 2009. Subgrantees also did not comply with the 

FEMA grant guidance requirement to prominently mark any equipment 

purchased with grant funding with the statement “Purchased with funds 

provided by the U.S. Department of Homeland Security” when practical. 

Subgrantees did not manage equipment as required because IDHS did not 

enforce the inventory provisions of the CFR or its own internal guidance. 

Of the 13 SHSP subgrantees we selected for review, 11 purchased equipment 

using FY 2008 through FY 2010 grant funding. None of the 11 subgrantees 

complied with CFR requirements for maintaining property records. Specifically, 

of the 11 subgrantees: 

•	 Five did not maintain inventory records. 

•	 Six provided some form of an inventory record; however, they did not 

include all information the CFR requires, such as the location of equipment, 

identification number, and condition. 

•	 Nine did not consistently mark equipment with the statement “Purchased 

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

IDHS did not enforce the inventory provisions in 44 CFR 13.32(d) or its own 

Administrative Plan for Grants Managed by the Indiana Department of 

Homeland Security. The State conducted onsite monitoring reviews of 

subgrantees and identified problems with inventories, but it did not always 

follow up to ensure deficiencies were corrected. Until 2012, IDHS did not have a 

formalized method to ensure compliance with inventory requirements.

Weak subgrantee inventory management practices affect the accuracy and 

integrity of the inventory purchased with grant funds. For example, one district 

could not locate two pieces of equipment—a $50,718 generator and a $15,000 

John Deere Gator (all-terrain vehicle). The district fiscal agent responsible for 

the generator said it was stored at a fenced-in yard at a local police department. 

A police officer from that department accompanied the team to locate the 

generator, but we were unable to find it. Twelve days after our visit, the fiscal 

agent provided a photo of the generator and a close-up photo of its serial 

number. In the photo, the generator appeared to be at its assigned location; 

however, given its size, it is unlikely we would have missed it (see figure 1). 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Figure 1: Photo of Generator 

Source: District 2 personnel 

As a result of these inventory deficiencies, the State did not have adequate 

inventory controls in place. Accordingly, IDHS could not ensure that assets 

purchased with grant funds were adequately safeguarded to prevent loss, theft, 

or misuse. The State might not have had ready access to vital emergency 

preparedness equipment if needed. 

Expenditure of 2008 UASI Funds 

The City of Indianapolis purchased about $3 million in equipment after the 

deadline for expending funds specified in its subgrant agreement with the State. 

The city made these purchases between 30 and 44 months after FEMA awarded 

its FY 2008 UASI funds. IDHS did not ensure the city adhered to its planned 

milestones to spend the FY 2008 UASI funds. In addition, FEMA approved two 

requests submitted by IDHS to extend the grant period of performance by 6 

months, even though the reason for the extension requests was the same. IDHS, 

as well as FEMA, should have monitored the city’s progress in obligating and 

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expending this funding to better ensure that the city spent the grant funds by 

March 1, 2011, in accordance with its subgrant agreement with the State. 

FEMA awarded the FY 2008 UASI grant to the State of Indiana on 

August 22, 2008. The State subsequently entered into a subgrant agreement 

with the City of Indianapolis on April 30, 2010, authorizing expenditures for the 

FY 2008 UASI funding. The agreement specified that the city obligate the funds by 

October 30, 2010, and liquidate (expend) the funds by January 28, 2011.1 The 

State amended the agreement on September 24, 2010, and extended the 

obligation deadline to December 31, 2010, and the expenditure deadline to 

March 1, 2011. Thus, the city was required to spend its FY 2008 UASI funding by 

March 1, 2011. 

On May 19, 2011, the UASI Program Manager for the city sent a request to the 

State to extend the period of performance for the FY 2008 UASI grant by 6 

months. The request cited a number of changes in UASI leadership, including a 

change to elected and appointed officials who made up 50 percent of the 

Executive Committee, which had resulted in budget reprioritization. According 

to the request, the new UASI leadership wanted to examine the purpose of UASI 

expenditures thoroughly, thereby slowing project encumbrances (expenditures). 

IDHS did not ensure the city adhered to its plan to spend the funds as outlined in 

its May 19, 2011, request for extension. The city’s request included a project-byproject status and its plan to exhaust the balance of funds for each project. 

According to the request, funds for all projects would be expended by 

September 1, 2011. However, the UASI did not meet these milestones, and the 

city purchased about $2.6 million in equipment between September 2011 and 

April 2012. In all, the city purchased about $3 million in equipment after the 

amended March 1, 2011 deadline. 

FEMA approved two 6-month extension requests to the grant period of 

performance submitted by IDHS. The first extended the period of performance 

until February 29, 2012, and the second until August 31, 2012. Both IDHS 

requests to FEMA cited changes in the UASI Executive Committee leadership as 

the primary reason for needing an extension. However, according to the UASI’s 

first request to IDHS, dated May 19, 2011, the pace of changes in senior 

leadership had slowed during the 8 months prior to the request. FEMA should 

have worked with IDHS to determine whether other issues affected the city’s 

ability to spend the grant and what action, if any, could be taken. 

1

 Per the agreement, obligate “includes, but is not limited to, ordering, accepting delivery, installing 

equipment and full completion of any service agreements or contracts.” 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In addition to not expending funds promptly, the city did not seek State 

reimbursement for its UASI-related expenditures promptly. As of 

January 25, 2012, the city had submitted requests for reimbursement of only 

$257,030 of the nearly $5 million authorized by its subgrant agreement with the 

State. The UASI Program Manager said the office responsible for submitting 

reimbursement requests to the State was apparently not doing its job. As a 

result, the city requested reimbursement from IDHS for a majority of its 2008 

UASI expenditures during February, March, and April 2012. 

These delays in expenditures may have unnecessarily delayed improvements to 

the Indianapolis Urban Area’s preparedness and security. Furthermore, the 

UASI’s mass billing of invoices to IDHS may have negatively affected IDHS staff’s 

ability to manage other grant projects. The State and FEMA should have better 

monitored the city’s progress in meeting the expenditure milestones in its 

May 19, 2011, extension request. 

Recommendations 

We recommend that the Federal Emergency Management Agency Assistant 

Administrator, Grant Programs Directorate: 

Recommendation #1:

Require the Executive Director, Indiana Department of Homeland Security, to 

include measurable objectives with realistic target dates for completion in the 

State and urban area homeland security strategies. 

Recommendation #2: 

Require that for all future grants, the Indiana Department of Homeland 

Security’s Grants Management Section comply with the requirements as stated 

in DHS Homeland Security Grant Program Guidance and Application Kits to 

obligate grant funds to subgrantees within 45 days and to document the 

commitment of those funds. 

Recommendation #3: 

Require the Indiana Department of Homeland Security to enforce the inventory 

requirement provisions of 44 CFR 13.32(d) and its own internal guidance. 

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Recommendation #4: 

Limit the number of extensions granted to the period of performance for 

Homeland Security Grant Program grants. 

Recommendation #5: 

Work with the Indiana Department of Homeland Security to develop procedures 

to closely monitor the progress of subgrantees who request extensions to the 

period of performance and hold them accountable if they do not meet 

Homeland Security Grant Program project milestones. 

Management Comments and OIG Analysis 

FEMA thanked us for the opportunity to comment on the draft report and said it 

would use the findings to strengthen the effectiveness and efficiency of its 

execution and measurement of the subject grant programs. A summary of 

FEMA’s and the State’s responses to the recommendations and our analysis 

follows.

FEMA’s and the State’s Responses to Recommendation #1: FEMA concurred 

with this recommendation. The Assistant Administrator, Grant Programs 

Directorate (GPD), will require the State of Indiana and the Indianapolis Urban 

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

include measurable target levels of performance, as well as objectives that are 

SMART. According to the State of Indiana, it is in the process of revising its 

strategy. FEMA’s estimated completion date for this recommendation is 

September 30, 2013.

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

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

remain open pending confirmation that FEMA has received the revised 

Homeland Security Strategies from the State of Indiana and the Indianapolis 

Urban Area.

FEMA’s and the State’s Responses to Recommendation #2: FEMA concurred 

with this recommendation. The Assistant Administrator, GPD, will require the 

IDHS GMS to assess and streamline, where possible, processes and procedures 

for obligating funds to subgrantees. IDHS will report to the GPD the results of 

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

funds to subgrantees. According to the State of Indiana, IDHS has made a 

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concerted effort to ensure that formal letters of obligation are issued. As of 

August 2010, IDHS prepared and sent formal letters of obligation to its local 

subgrantees, State partners, and internal IDHS partners. FEMA’s estimated 

completion date for this recommendation is June 28, 2013. 

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

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

remain open pending confirmation that FEMA has received IDHS’ assessment 

and the steps it plans to take to expedite the obligation of grant funds. 

FEMA’s and the State’s Responses to Recommendation #3: FEMA concurred 

with this recommendation. The Assistant Administrator, GPD, will require IDHS 

to submit written policies and procedures addressing the requirement provisions

of 44 CFR 13.32(d), as well as any internal guidelines, along with documentation 

detailing how IDHS will correct the deficiencies outlined in the final report and 

communicate requirements with subgrantees more effectively. According to the 

State of Indiana, IDHS has taken many positive steps to address the equipment 

inventory concerns identified by this report, including issuing a comprehensive 

Information Bulletin to all subgrantees in January 2012. This bulletin requires 

that subgrantees conduct and submit the results of a physical inventory to IDHS 

by April 15 of each year. FEMA’s estimated completion date for this 

recommendation is June 28, 2013. 

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

recommendation 3, which is resolved and open. This recommendation will 

remain open pending confirmation that FEMA has received IDHS’ written policies 

and procedures and evidence these procedures were communicated to 

subgrantees. 

FEMA’s and the State’s Responses to Recommendation #4: FEMA concurred 

with this recommendation. On February 17, 2012, the Assistant Administrator, 

GPD, issued an Information Bulletin providing grantees with guidance on, among 

other things, the specific procedures to be followed in requesting an extension 

to period of performance. These procedures specify that grantees’ requests for 

extensions will be considered only through formal, written requests and must 

contain specific and compelling justification as to why an extension is required. 

The GPD will grant extensions only for compelling legal, policy, or operational 

changes. The Assistant Administrator, Grants Program Directorate must approve 

these requests. 

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

recommendation 4, which is resolved and closed. 

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FEMA’s and the State’s Response to Recommendation #5: FEMA concurred 

with this recommendation. The Assistant Administrator, GPD, will require IDHS 

to develop and submit subgrantee monitoring procedures that are compliant 

with Federal requirements and address accountability of subgrantees who

request extensions to the period of performance and do not meet their project 

milestones. FEMA’s estimated completion date for this recommendation is 

June 28, 2013. 

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

recommendation 5, which is resolved and open. This recommendation will 

remain open pending confirmation that FEMA has received IDHS’ written 

monitoring procedures to address subgrantee accountability for meeting period 

of performance milestones. 

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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. 

This report provides the results of our work to determine whether the State of Indiana 

distributed and spent SHSP and UASI grant funds (1) effectively and efficiently and (2) in 

compliance with applicable Federal laws and regulations. We also addressed the extent 

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

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

The HSGP and its 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 supporting programs were reviewed for compliance. 

The scope of the audit included the SHSP and UASI grant awards for FYs 2008, 2009, and 

2010. We reviewed the strategies developed by the State to improve preparedness and 

response to all types of hazards, the goals and objectives set within those strategies, the 

measurement of progress toward the goals and objectives, and the assessments of 

performance improvement that result from this activity. 

The scope of the audit included the following grants: 

Table 1. Indiana SHSP and UASI Awards FYs 2008 Through 2010 

Funded Activity FY 2008 FY 2009 FY 2010 Total

State Homeland Security 

Program $12,650,000 $11,633,500 $11,326,441 $35,609,941

Urban Areas Security 

Initiative $7,478,500 $7,104,700 $7,104,699 $21,687,899

Total $20,128,500 $18,738,200 $18,431,140 $57,297,840

Source: DHS-OIG
 

www.oig.dhs.gov 14 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We interviewed officials from the State Administrative Agency, IDHS. We reviewed 

various State documents, such as the Administrative Plan for Grants Managed by the 

Indiana Department of Homeland Security, dated April 2009. We then documented the 

flow of transactions and events, including the key controls over the end-to-end process 

of developing the State Homeland Security Strategy, preparing investment justifications, 

and the grant transaction flow (see appendix F). 

We judgmentally selected and visited 13 subgrantees to whom IDHS awarded SHSP 

funding in FYs 2008, 2009, and 2010. These 13 subgrantees included 10 local 

jurisdictions and 3 state agencies. We visited the following subgrantees: 

Local Jurisdictions

• City of Elkhart 

• City of South Bend 

• Elkhart County 

• Kosciusko County 

• Starke County 

• City of Columbus 

• Bartholomew County 

• Lawrence County 

• City of Evansville 

• Vanderburgh County 

State Agencies

• Indiana State Police 

• Indiana National Guard 

• Indiana Board of Animal Health 

The 10 local jurisdiction subgrantees were located in 3 of the State’s 10 Homeland 

Security Districts. We chose the two districts that received the largest funding 

allocations (District 2 and District 10). Although ranked eighth in the amount of its 

allocation, we chose a third district (District 8) where prior IDHS site visits had disclosed 

several findings. These three districts were geographically dispersed throughout the 

State (see appendix E). We met with officials from each subgrantee in these districts. 

We also judgmentally selected and reviewed three State agencies.

To review SHSP expenditures, IDHS provided OIG with subgrantee agreements, requests 

for expenditures, and associated vendor invoices from its Indiana Grants Management 

System for each subgrantee. We reviewed 100 percent of these documents prior to 

visiting the subgrantee. We then created data collection instruments to summarize our 

tests of whether funds expended for equipment purchases and exercises complied with 

www.oig.dhs.gov 15 OIG-13-45 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

grant requirements and State-established priorities. During the site visits, we 

interviewed responsible officials, reviewed additional documentation supporting State 

and subgrantee management of grant funds, and we inspected select equipment 

procured with grant funds. 

We judgmentally selected equipment from subgrantee inventory records, requests for 

expenditure, and vendor invoices. We determined the validity of the inventory records 

and the condition of the equipment. We also determined whether the equipment 

purchased was approved in the subgrant agreement with the State, and whether the 

equipment was listed on FEMA’s Authorized Equipment List. We physically inspected 

the following equipment: 

Table 2. Dollar Amount of Equipment Inspected by DHS OIG 

District/State 

Subgrantee/UASI

$ Amount 

Equipment 

Purchased 

$ Amount 

Equipment 

Inspected 

Percentage of 

Equipment 

Inspected 

District 2 $2,114,413 $661,130 31%

District 8 $1,359,667 $303,014 22%

District 10 $2,235,427 $706,801 32%

State Police $ 706,823 $562,145 80%

Board of Animal Health $ 35,411 $ 8,078 23% 

City of Indianapolis $3,252,282 $2,725,913 84% 

TOTAL $9,704,023 $4,967,081 51%

Source: DHS OIG Analysis and Inspection of Equipment. 

We performed limited transaction testing of UASI expenditures. At the time of our first 

visit to the Indianapolis Urban Area in February 2012, the City of Indianapolis had 

requested reimbursement for $257,000 in expenditures. When we returned in May 

2012, IDHS was in the process of reviewing about $4 million in reimbursement requests. 

Due to time constraints and IDHS’ ongoing processing of invoices, we limited our review 

to interviewing program officials about their strategic planning and risk analysis process 

and inspecting selected equipment purchased with UASI funding. 

We relied on data processed by the Indiana Grant Management System that contained 

information on the grant funds awarded from FY 2008 through FY 2010. We conducted 

limited tests on this data and compared it with source documentation to ensure that the 

data were sufficiently reliable to be used in meeting our audit objective. 

www.oig.dhs.gov 16 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We conducted this performance audit between December 2011 and August 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 17 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

FEMA Management Comments to the Draft Report

U.S. I}rplrtmcnl of Ilomrlllnd Sri:urily 

Wu hinglOl1. DC 20-172 

JAN 1 6 1013 

MEMORANDUM FOR: Anne L. Richards 

Assistant Inspector General ror Audits 

Office or Inspector General 

FROM: 

rr-

/- David J. Kaufman -;;i,,:...... ~~­ Associate Administrator ror 

Policy. Program Analysis and International Arfairs 

SUBJECT: Response to GIG Draft Report: ''The State of I"dialla 's 

Managemeflt a/State Home/and Sec/wiry Program and Urb(m 

Areas Security Initia/iI'c Grams Awarded During Fiscal Ycws 

2008 Through 20/0"· - OIG Project '0.12-100-AUD-FEMA 

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

used to strengthen thc effectivcness 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: 

OIG Recommendation # 1: Require the Executive Director, Indiana Dcpartment or Homeland 

Security, to include measurable objectives with realistic target dates for completion in the State 

and urban area homeland security stratcgies, 

FEMA Respo nse: FEMA concurs with this recommendation, The Assistant Administrator of 

the Grant Programs Directorate (GPO) shall require the State or Indiana and the Indianapolis 

Urban Area to update their respective Homeland Security Strategies. ensuring the strategies 

include measurable target levels of performance, as well us objectives that life specific, 

measurable, achievable, results-oriented, and time-limited, and an appropriate evaluation, State 

of Indiana and the Indianapolis Urban Area shall submit the revised Homeland Security 

Strategies to GPO for review within six months after issuance of the 010 final report. 

FEMA requests this recommendation be reso lved and open pending the completion, submission 

and review of the strategy revisions. The estimatcd completion date (ECO): September 30, 

2013. 

OIG Recomme nd ation #2: Require that for all ruture grants, the Indiana Department or 

Homeland Security's Grams Management Section comply with the requirements as stated in 

DHS' Homeland Security Grant Program Guidance and Application Kits to obligate grant funds 

to subgramees within 45 days and to document Ihe commitment of those funds. 

www.oig.dhs.gov 18 OIG-13-45 
OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

FEMA Response: FEMA concurs with this recommendation. The Assistant Administrator of 

the Grants Programs Directorate shal1 require Indiana Department of Homeland Security's 

Grants Management Section to assess and streamline (where possible) processes and procedures 

for obligating funds to sub grantees. The Indiana Department of Homeland Security shal1 report 

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

funds to the subgrantees within 90 days after the issuance of the OIG final report. 

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

corrective action. The ECD: June 28, 2013. 

OIG Recommendation #3: Require the Indiana Department of Homeland Security to enforce 

the inventory requirement provisions of 44 eFR 13,32(d) and its own internal guidance. 

FEMA Response: FEMA concurs with this recommendation, Within 90 days of issuance of the 

final report. the Assistant Administrator of the Grant Programs Directorate shall require the 

Indiana Department of Homeland Security to submit written policies and procedures addressing 

the requirement provisions of 44 CFR 13.32(d) as well as any internal guidelines along with 

documentation detailing how the Indiana Department of Homeland Security will correct the 

deficiencies outlined in the final audit report and communicate requirements with subgrantees 

more effectively. 

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

actions stated above. The ECD: June 28, 2013. 

OIG Rec:ommendation #4: Limit the number of extensions granted to the period of 

perfonnance for Homeland Security Grant Program grants. 

FEMA Response: FEMA concurs with this recommendation. FEMA notes that per Secretary 

Napolitano's guidance issued on February 13,2012 titled "Guidance 10 State Administrative 

Agencies to Expedite the Expenditure o/Certain DHSlFEMA Grant Funding, " and subsequent 

lnfonnation Bulletin (IB) No. 379, extensions to the initial period ofperfonnance identified in 

Homeland Security Grant Program grants will be considered on1y through fonnal, written 

requests to the grantee's respective GPO Program Analyst and must contain specific and 

compelling justifications as to why an extension is required. Extensions are granted on1y due to 

compelling legaJ, policy, or operational challenges. FEMA's enforcement of this policy has 

limited the number of extensions granted. 

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

be resolved and closed. 

OIG Recommendation #5: Work with the Indiana Department of Homeland Security to 

develop procedures to closely monitor the progress of subgrantees that request extensions to the 

period of perfonnance and hold them accountable if they do not meet Homeland Security Grant 

Program project milestones. 

2 

www.oig.dhs.gov 19 OIG-13-45 
OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

FEMA Response: FEMA concurs with this recommendation. Within 90 days of receipt of the 

issuance of the OIG report, the Indiana Department of Homeland Security is required by the 

Assistant Administrator of the Grants Programs Directorate to dcvelop and submit subgrantee 

monitoring procedures that are compliant with federal requirements and address accoWltability 

of those subgrantees that request extensions to the period of perfonnance and do not meet their 

project milestones. 

FEMA requests this recommendation be resolved and open pending submission and FEMA 

approval of the stated corrective actions. The ECD: JWle 28, 2013. 

Thank you for the work that you and your team 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. 

3 

 

www.oig.dhs.gov 20 OIG-13-45 
OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix C 

State of Indiana Management Comments to the Draft Report

MITCHEll E. DANIELS, Jr., GovornorSTATE OF INDIANA 

L eadership 'or M SMre and Secure Indi Mna 

JotJoph E, WalntJcott, Jr., EXOGutivo Direc tor Indiana Department o( Nomeland Security Indian. C;ovemtrlflnt IJtJnter:iouth 

302 w....t W_""""on Slmol 

IndiDtUJPOIi$. IN 49204 

3f7-232·3IJEIO 

D=e:",I,IC, 10,20 12 

M " Anne R ich ords 

A!':.~i!<; nnt Im:pcctnr Ocncml for Andit!<; 

Office of Ioll:peelo r GCllerol; Deportment o fHo'lielond Security 

245 M",my Drive, SW, n\lilding 4 IO/Moi l St£)P 2t.OO 

Was hinSto n, DC 20528 

D .. "" M". Rid", ... I". 

TI,i1\; letter is in ,-'::S I)()Il;wl to the Audit Report o rthe State or I"diana's M a n agement of State I lol1lela" d 

S ccu rity P''OSI'OI1l a nd U rbon Arens Security Init int lve Grnnrs Awnnlcd during F iSCJII V e lln; 2008 through 

2012 (010 Project No. 12- 100 AUD Fl:iMA). Purs uant to Public Lnw 110-53, Implementing 

R ... ""ulIlI lI .. lIllllli""" "rl.it .. 911 I COlllllli!':.<; ion A.:t 01"2007, a s a mcndoxl, II I·cquin:d audit was conduetcd hy the 

Ik llll1111lcnt of H o nll:llInd Secu rity (DHS) Office o flnGllCc to r GeneruT (OIG) for the aforcnlllntioned G rants;. 

T ill'; 1",jill"" Slrnl.eW" rv, HUII".h",u St:c • ..-ity WIIS <It:vt:luIJ"u ,,,,<I ".,jJn)v"u IJ:,,, ...... I ( >II I"., H UIII.,I"",1 

S.:eurily "n:,;id':Iltilil Dirvetiv<:lHSPD-8 rc cll ~cd o n Decemoor 17, 2003. 

T hi!: IIlcliAIiA ~ltlT C Srmlcgy WA!'; Ihe n e irculmed for review nnd inplll hy All slAkeho lcieno: in nee emher 

2007. Tho Indi ona Stllla SlI'atogy WAS /inal izcd, approvoxl and adopted by tha Indiano Cou nte,' Torrorit;1lI 

""d SeclIl";ly Cvu""i1 i" Fd.>fl"" y ur200R. At 11",1 ti" ." FEMA· ,., 1O " l'fu ... ,,1 vrtl ,,, '"dill'''' Sh.te Slf""'~ 

lipecifi c milell;t(llle1l- and/or tllrset dlltes were no t n requirement, Mony of the S h'lltcSic Gools nnd 

Obj.,cti ... c>j do have: spec ific dllles tor comp letion, however by their very nal uN, lI1any ol" tlu:sc Roul:\ and 

hj ccTi vc.~ Are nmlti_yt'"..n r pmjec:ll';. Whi le vArion!'; nl'lpccl!1; n fn prnj cci mAy he eomrle reci wiTh one yenr o f 

fund ing., tho complelion ol' lhe entire projoci wos rel ialll UllOli fundi ng lrom fulure g rant years. 

The CI"'Nllt IndiAnll- Slnlt(OSY (0" Homeland Security il: l>¢i"S re ... ised ond updllted at th is time. IDHS 

plnm. te) s"b",;1 Ihi:s d ocument to FEMA 101' their I'Cview n nd apilroval with in Ihe lirst qUArter 0 1"20 13 

flIul will inc illne 1I-p ooifie, JlI"Ojecl oriented memmmh ic mi leslOn=, 

2. arm" d ""'rtf 1 dl"r 

The Tml,,,,," Dcpurlmcnt or H o m.:.IOlld Secu"i ty (IOHS) IlCkIlOwlcdJl.(o9 thllt 101'11101 awor d l(Ou(Orn of 

o hl iCfllion were IlOt l to Ollr gmllt .c:n h-recipiclll1/. for the 2 00R find 2009 '·lo l11clnl101 Sccurity Omnt 

Program ( HSGI') grunt alVard!: to includ(O the Urban AreaG Security Initilltive (UAS I) w ithin the 45-dlly 

li,"(:fuII"c. We "Iso uekllowledgc tlmt Itln n nl oward leller.c: "robligalio n we,'e no t pro vided lo r our 

intc n ud lDHS proj ects and os well as Indialltl SUlle A gency pOl1ncn . 

Th is oversight o n Ihe port of TDHS was out l ined 10 IDHS as n result of n m onitoring vi.c:it in t he s Ulnmer 

0 1'2010. 111<:11"(010,,(0 , as pllrt of the monito rillg rCfK)11, IIJHS h aG made II cOllcerted eno rt to rectity Ihil: 

mUllito rillg ousc,· ... "li" " . As or Aug UST or2010, IOHS hilS Ilrepn, ed and sent ro rmllt Telte,'s o f o blignlioll 

An Cqual OpportunHy Cmployt'l'r 

www.oig.dhs.gov 21 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

to our local sub-recipients as well as our state partners and our own internallDHS partners. We fee l as 

though we have corrected (his issue by providing the obligation letters within the 45-day requirement for 

the2010, 2011 and 2012 HSGP gronls. 

The UASI grant award is somewhat different and is a process based on a committee consisting of 

members of the slate and the Indianapolis Urban Area (including both Hamilton and Marion Counties). 

The award and obligation of the UASI grant funding is based on the decisions made by the members of 

this group. While this docs not negale the need for a fonnal obligation letter, all local UASI panners arc 

the prime decision makers for approved UASI initiati ves. 

3. Egflipmeltl lll veutorie.\' 

The Indiana Depanment of Homeland Security realized a great need for an employee in the Grunts 

Management Bronch solely dedicated to the daunting task of grant monitoring. This staff position was 

created and the firsllDHS Grants Compliance Monitor was hired in January 2009. During the initial 

months of this undertaking, the entire grant monitoring program was created, vetted and approved by 

JDHS management. This process culminated in the "Compliance Monitoring for Preparedness Grants 

Managed by the iJldiana Depanmcnt of Homeland Security" origina lly writtcn in May 2010 and revised 

in September 20 I I. 

Many positive steps have been taken to address the equipment inventory concerns in the Inspector 

General's Audit Repon. 

In 2008, IDHS created an Administrative Plan for Gmnt Programs Administered by the Indiana 

Department of Homeland Security, requiring all grantees to conduct a physical equipment 

inventory and submit the repon to IDHS with their quanerly progress repon due on April 15~· of 

each year, 

An equipment inventory spreadsheet tool was created in latc December 2010 by our grants 

compliance monitor to assist sub-recipients. This tool contained all of the information fields as 

required by 44 CFR 13.32(d) and is available for usc by our sub-rec ipients. This tool was not 

required to be used by thc locals as long as they already had an cstablished system for 

inventory/equipment control and that it too met all of the fede ral inventory requirements. 

• In the summer of2011, IDHS launched a new module within the Indiana Gr<lI1ts Management 

System (iGMS) called the Equipment Inventory Module. This tool was creatcd in rcsl>onse to 

requests from our sub-recipients and provides a standardi7.ed process for assistance with the 

inventory/equipment control documents requirement. The Equipment Inventory Module has 

been modified/changed as suggestions from our local panners have used the module. Again, 

th is is a tool for our grant sub-recipients to usc at their discretion. 

In January 20 12 a comprehensive Information Bulletin No. 12·01, Subject: Equipment 

Inventory Requirement for Preparedness Grants, was disseminated to all of our sub-recipients. 

This Infonnation Bulletin outlined the requirements ofCFR44 I 3.32(c) with an annual due date 

of April 15111• 

For 2008 and 2009 HSGP, the Grant Guidance Document indicates that lDHS and sub-grantecs 

are required to: 

o 5.10 - Equipment Marking. Applicants are advised that, when practicable, any 

equipment purchased with grant funding shall be prominently marked as follows: 

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

For 2010 IISGP the Gront Guidance Document indicates the following is the requirement: 

An Equal Opportunity Employer 

www.oig.dhs.gov 22 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

o 5.10 - Equipment Marking. Awardees may consider marking equipment in the 

fo llowing manner, "Purchased with funds provided by the U.S. Department of 

Homeland Security," in order to fac ilitate their own audit processes, as well as Federa l 

audits and monitoring visits, wh ich may result from receiving federal fu nding. 

• Clearly the above cited documents indicate that equipment marking requirements is required 

"when practicable" (2008/2009 HSGP) and each sub-recipient "may considcr marking 

equipment" (2010 HSGP). It appears there is an allowance of discretion on the pan of our subrecipients for the purpose of equipmcnt marking. 

4. PerfOrmauce Perioll ExlemiOlI.f 

'111e Indiana Department of Home land Security recogn izes thnt requests fo r extensions to performance 

periods appear to be excessive. To remedy that situation, lOl lS has instituted a poliey that "tightens up" 

the justifications for extcnsions ofpcrformance periods and also limits the number of approved 

performance period extensions. 

Specifically, lDHS Infonnation ])ullelin 12.G005 dated October 3, 2012 (attached) definitively outlines 

the pcrfonnancc periods for 201 1- 12 HSGP fu nds and 201 [ EM PG funds and all subsequent grants. 

For 20 I I HSGP grants the following applies: 

Perfomlance periods for this grant will not be approved past the dale of March 1,2013. 

A thirty (30) day extcnsion (March 31, 2013) may be approved upon request to the Grants 

Management Branch Chief. 

Any request for an extcnsion of the performance period past this timc will requ ire the requester 

to submil their justification and complete and submit a spending plan. 

If the extension is approved, the requestor will receive notification of the approval through 

iGMS. 

For the 2012 HSGP grants the following applies: 

An in itial six (6) month performance period will be approved. 

A thirty (30) day extension may be approved upon request to the Grants Managemclll Branch 

Chief. 

Any request for nn extension of the perfonnance period past this time will require the requester 

to submit their j ustification and complcte nud submit a spending plan. 

If the extension is approved, the requestor will reecive notification of tile approva l through 

iGMS. 

IDHS fcels that these requirements for accountability will alleviate the need to request I>crfonnnnec 

period extensions to U.S. Department of Homeland Security. 

5. S,Ib-Rec;II;elll Gmll! Pr0l!re.\·.\· 

In addition to the limitations of tile perfonnance period for HSGP grants, project manager (PM) 

meetings are held month ly. These meetings provide Grants Management nn opportunity to meet with 

project managers to discuss thc progress of the grant funds awarded to them as project managcrs. This 

meeting also outlincs the spending rates of each project managcr's sub-recipients. The Grants 

Management Branch Chief uses this process to emphasize to the PMs the need to contact their individual 

sub-recipients and havc a discussion with them regarding their spending rales and address any issues that 

the sUb-recipicnt may be facing such as a long bidding process, selection of vendors and possi ble 

equipment manufacture and/or shipment delays. All ofthcse discussions with the sub-recipients, the 

PMs and the Grants Management Branch Chief provide a clear picture of the status of grants. IDHS 

An Equal Opportunity Employer 

www.oig.dhs.gov 23 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

fc.::: ls Ihis sle p goes n very long way in crenCing nn nllllosphere ofn<::<::Ollnl nbility for oi l of o u r gmnl 

l'o;:o..ipiO;: l lb. 

'r he Indiono l.)op~rt lil ent ol"l-lomelAnd ~ecu ri ly Appreciates t he oppoThl11 ity to respond to t he 

years shows atlr commitment to a gran. progmm . hal is ' ranSp;'Iren' ami ''';COIIIII ... blc to 11 0' only Ollr .'S1Ib-

.'ooipients, but to the t~xp3yer . 

Should you have any qucstions o r requ ire Illnhe r infonnation. plea!Se feel free to c;ontltc1 me or our G",nts 

M~nase(11ent Uranch (.;h'ef, KAche l Woodall. 

l-ecommendUlions a s o utlined in the Department ofllome:land Se:e:\lrity. Offi<::e: ofln.spee:tor Gcrn;;r ... I's Audit 

Report. We bc:licvc tlutll!!c posilive lIud prol:.rc:ssive sleps 1011:) has lakeu re(;C;nlly lind over the IMst few 

";"=~!)y~ 

Juseph 

~XC UliYC 

U. Wl1inSU1lt

O irector 

' ~ 

Indiana i.>ep'l rtmeOl 01 Ilomel;m d !':Oec unty 

A nachmcnt 

An Equ&1 Opportu nity Empk>y(lr 

www.oig.dhs.gov 24 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Indiana Department of Homeland Security 

Information Bulletin 

Date: October 3, 20ll 

Bulletin No: 12.GOO5 

To: Al l District COordinators 

AIIIDHS Staff 

AlllDHS field Services Staff 

Al l Eml.'rgcnL"y M"n<lgcrncnl O;rL'Clor s 

from: Rill:hel WOOdill1 

Branch Chief, G rants Managemen t 

Subject: Performance Pertod End Da tes 

Purpose 

The purpose of this Inform"tlon Bu llet in is to pr ovine guidance and InfolTllatlon regarding the 

poliev for submission Clnd ClpproVClI of Performance Perioo End Oates. 

Bad<t:rou.,d 

In the past, the Indiana Departrne.,tof Homelan d Security I IDHS) has required that sub -

recipients of grant funds p rovide notes/justificatio ns when requestins an extension of the 

perfo rmance perIod end date. ThIs Information Bulletin updates that requIrement. 

Additional Guidance 

Beginning w it h the 20:11. 'SoMte Homeland s.c.:u rity Grant ISHSPj the following will <lpply: 

o Performance periods forthls grant 11'1111 not be approved past the dilte of Milrch 1 , 2013. 

o A thi rty (30) day extension IMarch 31, 2013) mily be approved upon request to the 

Grilnts Management Branch Chief. 

Any request for an extension o f the performance period p ast this time will require t he 

requestor to submit their Justification and comple te and submit a spending plan. The 

spendi ng plan form to be comp le ted Is attach ed to tills Informa tion Bullet1n. Vour 

spending plan will be uploaded to the blJdget/project in question. 

If your extension is approved, you will receive notification of the approval through 

IGMS. 

For the 2011 Emergency M.magerroent Pefformance Gra nt (EMPG) the followi.lg w ill apply: 

o The Performan ce Period for t his sra n t will n ot be approved past the date of March 31, 

2013. 

o A thirty (30) dilY extension (Apri l 30, 201 3 ) may be approved upon request t o the Gra nts 

Milnagement Bram:h Chie!. 

Any req uest for an extension of t h e performance pe riod past this time will require the 

requestor to submit the ir Justifica t Ion and comple te and submit a spending plan. The 

www.oig.dhs.gov 25 OIG-13-45 
 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

spending pl:oln form to be completed ~ ::I1t;>ched to this Information Bulletin. Your 

~pendinS p l::ln w ,1I b e uplaaded ta I he budget/praject in questioo. 

a If your eJltensbn is app ro~'cd, yO .... lIoIi ll receive noti ficatfon af the LlpprovLlI t hroush 

IGMS. 

Forthe 2012 Siot c Homeland Security Gran t (SHSP) and the Emergency Manasement Pe rformance 

G • .an t IEMPG) t he followins will apply: 

o An Initial si)ll (6) month$ performa n ce period will be appro_d. 

o A thi. tv {:'KI) day ext ensi<Jn may b.e approved upon requ~t to t~ Grant" M;:on;:oeP.l"npnt 

B.ranch Chief. 

o AIlV requp.$t h;lr ;:on ~tenslon o t the performance period past this. t im e wfU require the 

requestor to submit t heir Justlfi:atlon ilnd com plete and submit a Spend'fig plan. The 

spend ing plan form to be completed is anacf1ed to this Information BUlletin. Your 

spend ing plan will be uploaded 10 t he budg~l/pro ect In question. 

o If vour elo"tensinn is approl'ed, 'fDu "",!II /"@ceiYe no t ificat ion of the approva l th rough 

IGMS. 

General 

If plan~ are IlOt received at Grants(!Ddh i In.gov by the assigned deadline, naltl(!~ w ill be aSli(!ssed. 

penalties may Indude Items such as pladng a renrlctlon on creatinR RFEs and/or de' obliKation of rund5. 

QUe5tlons 

Please dirt!(;t Qutl~ iv"~ ,t'!ita,dlllg lhls p l ogram to you, Distlil;t Emergency Manageillent Fie ld 

Courdirfatol Of it member of t he IDHS Granl5 Man agement ..-taff. Grants Management may be 

leach ed by e-mail atgr ts @dh .in.I!ov or by p h one ! t 317-234-5917. 

Page 2 of 2 


 

www.oig.dhs.gov 26 OIG-13-45 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Description of Homeland Security Grant Program

The HSGP provides Federal funding to help State and local agencies enhance capabilities 

to prevent, deter, respond to, and recover from terrorist attacks, major disasters, and 

other emergencies. It 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: 

•	 The 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 identified planning, equipment, 

training, and exercise needs. 

•	 The 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. Funding is expended based 

on the Urban Area Homeland Security Strategies.

The HSGP also includes other interrelated grant programs with similar purposes. 

Depending on the fiscal year, these programs include the following: 

•	 Metropolitan Medical Response System

•	 Citizen Corps Program 

•	 Operation Stonegarden (only applicable for FY 2010)

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

State of Indiana Homeland Security Districts

Source: Indiana Department of Homeland Security. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Grant Transaction Flowchart

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G 

Major Contributors to This Report 

Linda Howard, Director 

Robert Ferrara, Audit Manager 

Gary Crownover, Program Analyst 

Kathleen Hyland, Auditor 

Kendra Kellett, Program Analyst 

David Kinard, Auditor 

Ebenezer Jackson, Program Analyst 

Kelly Herberger, Communications Analyst 

Katrina Bynes, Independent Referencer

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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 

FEMA Audit Liaison 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees, as appropriate 

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