Department of Homeland Security
 

Federal Emergency Management Agency Needs To 

Improve Its Internal Controls Over the Use of 

Disaster Assistance Employees 

OIG-13-13 November 2012
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

NOV 2 9 2012 

MEMORANDUM FOR: Albert B. Sl igh, Jr. 

Associate Administrator, Mission Support 

y nagem nt A e cy 

FROM: 

Assistan

D. Michael 

t Insp

Sea 

~ General I' 

, ~ -

Office of Erner ncy Management Oversight 

SUBJECT: Federal Emergency Management Agency Needs To 

Improve Its Internal Controls Over the Use of Disaster 

Assistance Employees 

Attached for your information is our final letter report, Federal Emergency Management 

Agency Needs To Improve ItslnternaJ Controls Over the Use of Disaster Assistance 

Employees. We initiated this audit from an DIG Hotline complaint alleging that a Federal 

Emergency Management Agency (FEMA) regional office improperl y used the Disaster 

Assistance Employee (DAE) program to circumvent the hiring of full-time employees. 

Our review did not substantiate the allegation. We provided FEMAwith a draft of this 

report and have incorporated its formal comments in the final report. 

The report contains four recommendations aimed at improving the DAE program. Your 

office concurred with three recommendations and partially concu rred with a fourth 

recommendation. As prescribed by the Department of Homeland Security Directive 

077-1, Follow-Up and Resolutions for the Office of Inspector General Report 

Recommendations, within 90 days of the date of this memorandum, please provide our 

office with a written response that includes your (1) agreement or disagreement, (2) 

corrective action plan, and (3) target completion date for each recommendation. Also, 

please include responsible parties and any other supporting documentation necessary 

to inform us about the current status of the recommendation. Until your response is 

received and evaluated, the recommendations wi ll be considered open and unresolved. 

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. 

Major contributors to this report are Tuyet-Quan Thai, Regional Director; Scott 

Wrightson, Supervisory Program Analyst; and Joshua Wilshere, Auditor. 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Please call me with any questions, or your staff may contact John Kelly, Deputy Assistant 

Inspector General, Office of Emergency Management Oversight, at 202-254-4163. 

Attachment 

 

www.oig.dhs.gov 2 OIG-13-13
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Background 

The Federal Emergency Management Agency (FEMA) is authorized under the Robert T. 

Stafford Disaster Relief and Emergency Assistance Act, as amended, to expand its staff 

size temporarily to respond to major disasters and emergencies. Disaster assistance 

employees (DAEs) fulfill this role by performing key program, technical, and 

administrative functions during disasters. DAEs are excepted-service intermittent 

employees, either cadre reservists or local hires. Cadre reservists have an initial 

appointment of no more than 24 months that expires on September 30 of each year 

ending in an even number (e.g., 2010), and may not work for more than 78 weeks (or 

18 months) during the 104-week appointment period. FEMA measures deployments 

during the same 2-year period from October 1 through September 30 of each evennumbered year, regardless of whether an employee was already a FEMA employee at 

the beginning of the period or was hired during the period. Local hires have an initial 

appointment of 120 days, which is renewable. 

The DAE program has undergone several changes. FEMA Instruction 8600.1, Disaster 

Assistance Employee Program, was issued in June 1991 as the guiding administrative

policy for the program. That instruction specifically states that DAE reservists are used 

only to perform disaster assistance program-related work. The work is defined as 

specific disasters, emergencies, projects, or activities of a noncontinuous nature. Other 

than for training, the activation of DAE reservists for assignments in headquarters and 

regional offices is prohibited. 

DAE management challenges are not new. In 1999, Director’s Policy No. 1-99 

established the basis for a systematic, formalized approach to ensure the readiness of 

the DAE workforce to respond to disasters quickly and effectively, wherever needed. 

This directive described actions to achieve the desired readiness and capability. In 

subsequent years, a number of these actions have been implemented to various 

degrees, such as expanding all disaster operations by locally hiring DAEs for positions

that do not require FEMA-specific expertise or when limited advance training or minimal 

on-the-job orientation or training is sufficient. 

In addition to establishing a framework for managing DAEs, Director’s Policy No. 1-99 

instituted the use of the Automated Deployment Database (ADD) as a management tool 

to monitor overall cadre readiness and capabilities. ADD is intended to track all FEMA 

deployable employees, including full-time employees, cadres of on-call reserve 

employees, and local hire employees. Tracking also includes cadre readiness, initial 

disaster site location (duty station), and training. 

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In 2007, FEMA commissioned a disaster reserve workforce study by a national strategic 

consulting firm, which determined that approximately 7,900 reservists were needed to 

support normal and high-demand periods based on projected deployment and risk 

tolerance data. 1 The study noted that the optimal size of the DAE workforce depends, 

to an extent, on the degree of uncertainty that is acceptable concerning whether the 

workforce is properly sized to accomplish its mission.

FEMA structures the missions of DAEs into 23 program areas, managed by regional 

cadre managers.2

 Although every program area is not necessarily represented in all 

regional offices, most major program areas, such as Individual Assistance, Public 

Assistance, and Mitigation, have a presence in all regions. Cadre managers help 

coordinate disaster response and recovery needs and deploy DAEs to meet those needs. 

From October 2006 to September 2010, FEMA paid nearly $800 million in salary to more 

than 11,000 DAEs. 

Results of Audit 

FEMA paid approximately 1,600 individuals $36 million more than they would have 

received if FEMA had enforced its limitation of using DAEs no more than 18 months in a 

2-year period ending September 30 of even-numbered years. FEMA made those 

payments in violation of FEMA Directive 8600.1 because it did not design the ADD 

system in a manner that allowed FEMA managers to systematically monitor the 

deployment period of DAEs. Thus, FEMA managers could not ensure that DAEs did not 

exceed the regulatory limit of 18 months of work in a 2-year period. In summary, 14 

percent (1,600 of 11,000) of FEMA DAEs employed from October 2006 to September 

2010 worked for longer than the 78 weeks allowed by policy. 

A number of factors contributed to DAE deployments exceeding FEMA policy caps. 

Regional cadre managers at three FEMA regional offices said that, because of system 

limitations, they would have to take extraordinary and time-consuming steps to manage 

to a 78-week deployment limit. In addition, they said that mission considerations, such 

as the scarcity of skilled employees to fill certain roles and the overall disaster activity in 

a region, may necessitate the extension of certain DAEs beyond the deployment cap.

For example, if a person is one of a few in the cadre who has specific skills, or if a major 

1 FEMA: New Disaster Reserve Workforce Model, Booz Allen Hamilton, 2007. 2

 Program areas are Community Relations, Congressional Affairs, Environmental Historic Preservation, 

Equal Rights, External Affairs, Federal Coordinating Officers, Finance/Administration, Hurricane Liaison, 

Incident Management Assistance Teams, Individual Assistance, Legal Affairs, Logistics, Long-Term 

Community Recovery, Mitigation, National Response Coordination Centers, Operations, Planning, Public 

Affairs, Public Assistance, Safety, Security, Training, and Disaster Generalists. 

www.oig.dhs.gov 4 OIG-13-13 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

disaster or several smaller disasters affect the region at once, a manager may have no 

choice other than deploying DAEs repeatedly in excess of the deployment cap. 

The extent to which DAEs were deployed in excess of 18 months in a 24-month period 

ranged from individuals who were deployed for an extra week or two to more than 400 

individuals who were deployed for 26 weeks (6 months) to a year above the cap. The 

more notable examples of DAEs whose deployments exceeded the cap included a FEMA 

Region II DAE who was deployed full-time (208 weeks) during the entire 4-year period 

we examined, and a Region VII DAE who was deployed for 207 of 208 weeks during the 

period. 

However, it does not appear that FEMA’s noncompliance with Directive 8600.1 resulted 

in FEMA spending Disaster Assistance Fund appropriations on unnecessary work. In 

addition, contrary to the Office of Inspector General (OIG) Hotline complaint that was 

the origin of this report, we identified limited examples of employees whose 

deployment roles appeared to be positions of a continuous nature and not limited to a 

specific disaster, emergency, or project, as required by FEMA Directive 8600.1. 

However, those employees are being used to perform closeout activities on long-term 

public assistance and mitigation projects, not to perform nondisaster-related activities. 

FEMA Managers Are Not Effectively Managing to the DAE Deployment Cap

Our analysis revealed that approximately 1,600 DAEs who were cadre reservists were 

deployed in excess of FEMA policy during the 4-year period from October 2006 to 

September 2010. FEMA Directive 8600.1 prohibits DAEs from being deployed for longer 

than 78 weeks during any 104-week period ending in September of an even-numbered 

year. Although many DAEs were deployed just a few weeks more than the policy cap, 

others were deployed for much longer—in some cases, up to a year more than the cap. 

Several FEMA regional offices we visited shared key factors that contributed to DAEs 

being deployed in excess of FEMA’s policy cap. Owing to system limitations, some 

managers were unable to track deployments effectively. Managers also cited other 

considerations such as operational and mission-related goals as obstacles to 

implementing deployment caps. These obstacles included having too few highly skilled 

or experienced staff to perform certain functions, longer-lived functions requiring longer 

deployments, and some cadres being understaffed. 

More Than 1,600 DAEs Were Deployed in Excess of the Policy Cap

During the 4-year period from October 2006 to September 2010, FEMA paid $36 million 

in salary to approximately 1,600 DAEs for deployments in excess of the 78-week 

deployment policy cap. Of the 1,600 DAEs who were deployed in violation of FEMA 

policy, about 350 were deployed above the cap during both 2-year periods we 

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examined, from October 2006 to September 2008 and from October 2008 to September 

2010. An additional 700 DAEs were deployed above the cap in the first 2-year period, 

while the remaining 560 DAEs were deployed above the cap in the second 2-year 

period. 

According to FEMA policy, DAEs who are cadre reservists should have initial appointments 

of no more than 24 months. These appointments expire on September 30 of each year 

ending in an even number. During this 104-week appointment period, a cadre reservist 

may not work for more than 78 weeks (or 18 months). For example, if a cadre reservist 

is appointed on August 1, 2008, the first appointment period ends on September 30,

2008. If this individual continues to work as of October 1, 2008, the individual can only 

work continuously for 78 weeks, or until March 31, 2010. If the individual does not 

work continuously (i.e., has time off between deployments), the times deployed are 

added together to derive the 18-month period. 

Analysis showed that 36 percent of the approximately 1,600 DAEs who worked in excess 

of the policy cap were deployed for up to 10 weeks over the 78-week cap. Thus, a large 

portion of the violations could likely have been managed by deploying alternative 

individuals instead of those who had reached the deployment limit. The remaining 64 

percent of DAEs who were deployed in violation of FEMA policies had deployments that 

ranged from 11 weeks (just under 3 months) over the cap to 35 employees who were 

deployed for all 208 weeks of the period. Figure 1 shows details of deployment cap

violations.

Figure 1. DAEs Deployed in Excess of FEMA Policy, by Time Deployed

700

600

500

400

300

200

100

0

Number of Employees

Less than 10 11-20 21-30 31-40 41 or more
 

Total Weeks Deployed In Excess of Cap

Source: FEMA payroll records. 

www.oig.dhs.gov 6 OIG-13-13 
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 Department of Homeland Security 

System Limitations Hinder Managers’ Ability To Manage to the Cap 

Although FEMA built ADD as a tool to monitor and deploy disaster staff, it was not 

designed to facilitate managers’ ability to manage to the cap. ADD does not have a 

built-in capability to notify FEMA managers when DAEs are close to exceeding the 

deployment limit. Nor does ADD enable managers to run reports of employees who 

may be above the 78-week deployment cap. The Government Accountability Office’s 

Internal Control Standards for the Federal Government require a system of internal 

controls that provide reasonable assurance of the effectiveness and efficiency of an 

agency’s operations, including the use of the agency’s resources, in part by designing 

internal controls to ensure ongoing monitoring. However, because monitoring 

employee deployments and managing to the policy cap was complex and timeintensive, it was frequently not done. 

Regional cadre managers in three regional offices told us that they did not manage to the 

78-week maximum deployment standard because they could not easily track an 

employee’s deployments. In the past, FEMA sent employee deployment reports to 

regional offices, which regional managers could use to track deployments against the 

cap. However, FEMA has not provided regional offices with these summary deployment 

reports in more than a decade, and has not enabled managers to produce them on their 

own in ADD. Instead, FEMA provides managers with cadre availability reports which 

show all employees within a cadre and their deployment status (e.g., deployed, 

available for deployment, unavailable for deployment). However, these data are 

provided without consideration of the 78-week cap. When a disaster strikes, cadre 

managers must quickly identify employees on their rosters who can staff the disaster, 

often in consultation with the Federal Coordinating Officer appointed for the specific 

disaster. Regional cadre managers informed us that they generally do not have the 

luxury of determining service time before deploying employees. If a disaster is large 

enough, or if the region has been hit with several disasters at once, they have to deploy 

all available resources in their region without consideration of service time. According 

to the managers, large disasters often necessitate that they deploy everyone who is 

available, and they may have to look outside their region for more employees to fill the 

necessary roles. 

Managers said that system limitations impede their ability to take service time into 

account. Although managers have access to an employee’s deployment history and 

number of deployment days through ADD, calculating deployment time is a complex 

and laborious process. For example, one manager who tracks deployment times 

constructed a spreadsheet to record the number of deployments for each employee, 

calculates the numbers of days in each deployment period, adds the days together, and 

then compares the results to the given 2-year period. Other managers told us that they 

did not think it was a reasonable task for cadre managers to perform, given that each 

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cadre can have 100 employees or more. Further, these calculations would have to be 

performed on a recurring basis. Nearly all regional cadre managers told us they manage 

their cadres as an additional duty beyond their primary responsibilities, and could not 

find time to track each individual manually. 3 Some of the managers, however, said that 

if they were provided with summary employee deployment data reports, they would be 

able to manage more effectively to a maximum deployment period. 

We identified limited examples of regional managers attempting to manage to the 78-

week standard. For example, one Region VI manager designed an ad hoc spreadsheet 

outside of ADD that contained up-to-date deployment information for each employee in 

the manager’s cadre. However, the manager said that it still took significant time to 

populate and update the spreadsheet on a regular basis with employee information 

from ADD. Through these efforts, the manager was able to identify individuals who 

were reaching the maximum 78-week deployment period, and to keep them from 

further deployments during the period. However, the manager also stated that he was 

the only regional cadre manager whose sole duty was that of managing the cadre. 

Region VII recently instituted a similar tracking system. The new system initially 

resulted in managers having to file waivers for 21 employees who had exceeded the 78-

week cap. Region VII management approved 7 and denied 14 waivers after identifying 

other DAEs who could perform the work and had not reached their deployment caps. 

Operational and Other Concerns May Hinder Deployment Cap Implementation

Operational concerns and other practices also affected the ability of regional cadre 

managers to implement the deployment cap. FEMA’s Director’s Policy 1-99 requires 

that cadre managers develop cadres of well-qualified, more frequently deployed DAEs in 

key positions and functions that require FEMA expertise, and requires that managers be 

held accountable for cadre readiness. Several managers said that they are concerned

that the continuity of long-lived tasks and FEMA’s ability to perform highly specialized or 

advanced tasks would be negatively affected should a cap be enforced. Further, 

recruiting and hiring of DAEs is not organized and consistent across regions, and may 

prevent managers from filling cadres with enough employees to manage to a 

deployment cap. Finally, regional cadre managers are able to fill DAE roles with specific 

individuals as long as those employees work within the region, and the managers are 

not required to identify the people who can fill those roles and are the least recently 

deployed. 

3

 Cadre managers generally serve operational roles within the program area they manage, in addition to 

their duties managing DAE deployments. For example, an External Affairs cadre manager might have an 

operational role as the Regional Director of External Affairs. 

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Mission Requirements Can Benefit From Deploying or Extending the Same Individuals 

Public Assistance and Mitigation cadre managers said that they had particularly longlived missions that would be negatively affected by a 78-week cap. The projects 

associated with those two areas often continue for months or years after disasters 

strike. DAEs are working closely with State and local officials on projects, and FEMA 

receives negative comments from those officials when a project liaison is changed in the 

middle of a disaster. In those cases, managers try to keep the same person in a role in 

order to maintain continuity of operations for the State and local officials. Managers 

said that a deployment cap that forces them to remove employees from long-lived

projects may have a negative effect on FEMA’s relationships with State and local

governments. Some DAEs may be essential on long-lived projects, and FEMA policy 

allows the 78-week rule to be waived with justification for some employees. However, 

the policy prohibits an employee who exceeds the cap on one project from being 

deployed on subsequent disasters within the same monitoring period. 

In addition, cadre managers said that some DAEs fill highly technical or highly 

specialized roles that that are not easily interchangeable with other DAEs, leading to a 

shortage of those resources within cadres. For example, Public Assistance needs skilled 

engineers and architects, who are generally in short supply. Therefore, a DAE who has 

that skill set might be deployed repeatedly without breaks simply because there is no 

one else to fill that role in a region. A similar dynamic exists for External Affairs cadre 

managers we spoke with. They said that while their lower-level positions were more 

interchangeable, the very senior External Affairs Officer (EAO) positions are much 

harder to staff. Therefore, the EAOs were more likely to be staffed on more disasters 

with shorter breaks. However, managers agreed that, for shorter-lived deployments 

and for less specialized or less technically skilled employees, they should be able to 

manage to a 78-week cap. 

Inconsistent Recruiting and Hiring Can Lead to Understaffed Cadres 

Recruiting and hiring of DAEs is not consistent across regions, and is not centrally 

planned at the regions we examined. A manager at one region we visited said that 

resumes are received at both the national and local level, but because cadre 

management is a secondary responsibility, there was not a comprehensive hiring plan. 

Two of the three regions we recently visited started trying to hire using job fairs, but 

only one of them hired new DAEs as a result. Some cadre managers also told us that 

they preferred to keep their cadres lean because cadre management was an additional 

duty. This kind of management has the effect of keeping fewer employees more 

employed, which makes them easier to manage but also hinders a manager’s ability to 

implement a deployment cap. Further, even when DAE recruiting is more proactive, the 

temporary nature of DAE employment and Federal background and credit requirements 

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can make it difficult to hire enough employees to staff cadres. At one region we visited, 

the office had invested $30,000 in an advertising and direct recruiting campaign, but 

had seen few results. 

Requests for Specific Individuals Are Standard Practices for Staffing Within Regions 

Most of the cadre managers at the three regions we visited said that, when they needed 

a DAE, they tried to identify whether they had a person who could fill that role within 

their own region who was available for deployment. If they could identify an individual, 

FEMA policy allows them to make a specific request for that individual, regardless of 

how often or how recently that person has been deployed. Therefore, several cadre 

managers said that it was not uncommon for the same people—usually the highestperforming or most skilled—to be deployed repeatedly. Managers can enter unlimited 

name requests into ADD without justification, as long as the DAEs being requested are 

within region assets. This is the opposite of how ADD name requests work when the 

DAE being requested is outside of the region making the request. A manager requesting 

a DAE from outside of the manager’s region is required to select from among employees 

who have been deployed the least recently, as long as they have the skills required. In 

the case of a specific name request, however, the request and a justification are 

transmitted to FEMA headquarters. 

Limited Instances Exist of FEMA Using DAEs To Perform Nondisaster-Related Functions

FEMA policies require that DAEs be used for disaster-related purposes. We received an 

OIG Hotline complaint that FEMA regional offices were using DAEs for nondisaster-related 

purposes. We identified limited examples of this practice. For example, a manager at 

the regional office where the OIG Hotline complaint originated told us that a DAE was 

used to carry out an office’s information technology and network maintenance 

responsibilities because the office did not have a full-time or term employee available to 

perform the task. The manager acknowledged that DAEs are not supposed to perform 

nondisaster-related tasks; however, the manager said that without a DAE to perform 

those functions, the office would not have operated properly. The position in question 

has since been filled by a term employee. The same manager said that DAEs had been 

used to deliver public messages emphasizing disaster planning and preparedness that 

were not related to a specific disaster. However, managers at the other two regional 

offices we visited said that they had never used DAEs to perform nondisaster-related 

functions. Nor did we identify widespread use of DAEs for nondisaster-related functions 

at the regional office where the hotline complaint originated. 

Thus, although the hotline complaint had some merit, the facts and circumstances 

concerning the infractions indicated that occurrences were insignificant. At the three 

regions we visited, we did not find evidence that DAEs were widely used to perform 

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nondisaster-related functions that are supposed to be performed by full-time and term 

employees. Instead, we determined that the DAEs performed closeout functions on 

projects in areas such as Public Assistance and Mitigation. Regional managers said that 

work on those projects often continues after the Joint Field Office is closed, and that 

DAEs at the regional office often perform tasks such as closing out project worksheets. 

Those types of activities are consistent with FEMA policies regarding the use of DAEs. 

Examples of Employees Exceeding Deployment Cap and Their Assigned Projects 

We found no evidence of FEMA using DAEs systematically to do the work of full-time 

employees on nondisaster-related work. We identified a number of DAEs whose 

deployments exceeded the policy cap. These individuals were deployed up to the full 

208 weeks during the 4-year period that we examined. Among the most-deployed 

individuals, the longest period during which they remained undeployed was as little as 3 

days over a 4-year period. This indicates that some DAEs basically remain full-time 

employees without breaks in service. However, contrary to the OIG Hotline complaint, 

these individuals worked on disaster-related work. Table 1 shows details of these 

examples. 

Table 1. Examples of FEMA DAE Deployments Exceeding FEMA Policy Caps 

Example 

Number Region Weeks Deployed 

Weeks Over Cap Longest

Period 

Without 

Deployment

(in days)

Deployments/

Disasters Cadre 2007–

2008

2009–

2010

1 II 208 26 26 3 12/6

Environmental 

and Historical 

Preservation 

2 VII 207 25 26 9 15/10 Logistics 

3 II 205 26 23 3 10/5 Public Assistance

4 VII 202 24 22 7 17/14 Public Assistance

5 VI 201 21 24 21 18/11 Logistics 

6 II 194 19 19 17 37/15 Logistics

7 VI 186 6 24 79 21/15 Finance and 

Administration 

8 VII 179 8 15 54 19/17 Planning 

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FEMA Faces No Adverse Impact by Allowing DAEs To Exceed Caps 

We determined that FEMA would not realize cost savings simply by applying a 

deployment cap. Although specific DAEs received salary in excess of what is allowed if 

FEMA had operated within the policy cap, they were paid for actual work performed. If

FEMA had adhered to the cap, the same individuals likely would not have been 

deployed repeatedly. However, other individuals would have had to be deployed in 

their place to accomplish FEMA’s mission. Those individuals likely would have worked 

similar hours and collected similar salaries to the DAEs meeting the deployment cap. In 

addition, managers in the regions we visited said that if they were to manage to a cap, 

they might have to deploy some less experienced individuals, which might have an 

effect on FEMA’s mission effectiveness. 

Conclusion 

Currently, FEMA is not managing DAEs to a 78-week standard for maximum deployment 

lengths, as evidenced by 14 percent of its DAE workforce exceeding the 78-week cap 

during the 4-year study period. In addition to system limitations, a number of 

operational concerns present challenges to FEMA managers in enforcing the deployment 

cap. Although FEMA improperly paid approximately 1,600 DAEs $36 million, we 

determined that we did not have an adverse financial effect to FEMA when DAEs 

exceeded the cap. Since the use of DAEs enables FEMA to maintain a workforce that 

can expand or contract efficiently and effectively based on where and when 

presidentially declared disasters occur, the benefits and costs of implementing the 

policy cap should be reevaluated.

Recommendations

We recommend that the Associate Administrator, Mission Support: 

Recommendation #1: 

Reevaluate the appropriateness of the 78-week cap on the use of its DAE workforce. If 

FEMA decides that the cap is not necessary, it should abolish the cap. 

Recommendation #2: 

If FEMA decides to maintain the cap, take appropriate steps to ensure that the 

Automated Deployment Database, or its replacement, incorporates features that will 

allow managers to identify when DAE program workers will exceed the 78-week 

maximum deployment limitation. 

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 Department of Homeland Security 

Recommendation #3: 

If FEMA decides to maintain the cap, identify all currently employed DAEs who have 

exceeded the 78-week deployment limitation and initiate actions to (a) replace those 

DAEs with other DAEs, or (b) approve waivers if those DAEs cannot be replaced. 

Recommendation #4: 

If FEMA decides to maintain the cap, institute a monitoring program that provides FEMA 

senior management information concerning the extent to which FEMA field and 

headquarters offices are complying with the cap. 

Management Comments and OIG Analysis

We obtained written comments on a draft report from FEMA’s Office of Policy and 

Program Analysis. We have included a copy of the comments in their entirety in 

appendix B. 

In the comments, the Director for the Office of Policy and Program Analysis concurred 

with three of the report’s recommendations, and partially concurred with the fourth 

recommendation. We have reviewed management’s comments and provide an 

evaluation below. 

In response to our first recommendation, that FEMA reevaluate the appropriateness of 

the 78-week deployment cap, FEMA concurred. FEMA stated that it was in the process 

of evaluating the appropriateness of the deployment cap policy and anticipated making 

a determination during fiscal year 2012. We will determine the status of this 

recommendation once we receive the detailed corrective action plan in FEMA’s 90-day 

letter.

In response to our second recommendation, that FEMA ensure that ADD or its 

replacement incorporate features that allow managers to identify when DAEs exceed 

the deployment cap, FEMA concurred. FEMA stated that the replacement system for 

ADD will include functionalities to track deployments, including compliance with any 

deployment caps. We will determine the status of this recommendation once we 

receive the detailed corrective action plan in FEMA’s 90-day letter.

FEMA partially concurred with our third recommendation, that FEMA identify all 

currently employed DAEs who have exceeded the 78-week deployment cap and initiate 

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actions to replace those employees, or grant waivers for them. According to FEMA, no 

DAEs were currently working in excess of the 18-month deployment cap because all 

DAEs were reappointed as of March 2012. However, FEMA agreed that if it should 

decide that a cap is necessary, it will take actions to ensure adherence through better 

cadre management. We believe that FEMA’s proposed actions adhere to the intent of 

our recommendation. However, we will determine the status of this recommendation 

once we receive the detailed corrective action plan in FEMA’s 90-day letter. 

Although this reappointment likely shifts some DAEs from working in violation of the 78-

week cap to working in compliance with the cap, it does not ensure future compliance 

with any deployment cap that FEMA determines is appropriate. If FEMA decides that a 

deployment cap is necessary, it must take steps to monitor and take action on DAEs who 

reach or have exceeded the cap. 

In response to our fourth recommendation, that FEMA institute a monitoring program 

that provides senior management with information concerning deployment cap 

compliance at the regions, FEMA concurred. FEMA stated that program officials would 

include deployment information in program updates given to senior management. We 

will determine the status of this recommendation once we receive the detailed 

corrective action plan in FEMA’s 90-day letter. 

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 Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

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

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

to the Inspector General Act of 1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the Department. 

Based on an OIG Hotline complaint that a FEMA regional office improperly used the DAE 

program to circumvent the hiring of full-time employees, we initiated a review of 

FEMA’s internal controls over the use of DAEs. The objectives of the review were to 

(1) determine the extent to which FEMA may be deploying DAEs in violation of its own 

policies and procedures and (2) determine whether FEMA deployed DAEs for routine, 

nondisaster-specific work. 

To determine the extent to which FEMA may be deploying DAEs in violation of its own 

policies and procedures, we obtained FEMA DAE payroll records for October 2006 

through September 2010 and analyzed the pay activity to determine which DAEs 

worked more 18 months out of 24 months, ending on September 30 of years ending in 

an even number. We also reviewed documents used by FEMA headquarters and field 

staff regarding DAE deployment. 

To determine whether FEMA deployed DAEs for routine, nondisaster-specific work, we 

analyzed the results of the tests conducted to identify DAEs who FEMA paid more than 

39 pay periods in both the 52-pay-period cycles ending on September 30, 2008, and

September 30, 2010. We also interviewed FEMA field and headquarters staff regarding 

the facts and circumstances concerning those DAEs. 

We briefed FEMA concerning the results of fieldwork and the information summarized 

in this report. We appreciate the efforts by FEMA management and staff to provide the 

information and access necessary to accomplish this review.

We conducted this performance audit between August 2011 and January 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 15 OIG-13-13 
 O

 

FFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

Management Comments to the Draft Letter Report 

LT.S. Drpllrtn,r nl (lrll .. mtl~ntl StrUr; > 

Washington. DC 20·H2 

~1031i112 

MEMORA, DUM FOR: D. Michael Beard 

Assistanllnspector General. Emergency Management Oversight 

Office of Inspector General 

FROM: David J. Kaufman 1111 ---- Director I~ Office of Policy and Program Analysis 

SUBJECT: OIG Draft Letter Report 11-124-EMO-FEMA, Federal Emergency 

Mllllagemeni Agency Needs 10 Improve lIS ImernaJ Comro/s over the 

Use 0/ Disaster Assis/{ll1ce Employees 

The Department of Homeland Security/Federal Emergency Management Agcncy (FEMA) 

appreciates the opportunity to review and respond 10 the DHS Office of Inspector General (OIG) 

Draft Lelter Report II ~ I 24-EMO-FEMA, Federal Emergency MalJagemenl Agency Needs 10 

Impror/! its lntet/wl Controls o\'cr 'he Use of Disaster AssiSlllnce Employees (OAEs). As FEMA 

transitions to a new FEMA Reservist Program. the OIG's analysis and recommendations will 

improve our ability to manage our disaster worHorce, 

As explained in the review. FEMA has taken- and continues to take-significant aClions to improve 

our reservist program and the support we provide to disaster survi\lors. FEMA appreciates the 

findings provided by OIG related to why reservists havc been deployed in excess of official policy 

caps; we also note that the OIG found no evidence of FEMA using DAEs systcmatically to do the 

work of futl-time employees on non-disaster related work. 

FEMA notes that the OIG conducted this rcview betwecn August 2011 and January 20 12, and that 

the audit's scope was limited to whether FEMA uses DA 's in accordance with official policies and 

procedures. FEMA appreciates the opportunity to provide the fotlowing related updates and 

information outside of the timeframe and seope of this audit: 

• New Resen 'ist I)rogram - FEMA is transilioning the existing DAE program to a new 

Reservist Program that can better enhance the Agency's capabilities to support disaster 

survivors by ensuring the workforce has the proper tools. training. experience. and 

management support. The changes that will come through the Reservist Program are a direct 

result of the workforce's feedback and recommendations and leadership's commitment to 

listen and take action on that feedback. These changes include developing and implementing 

reservist program policy and guidance documents. nationalizing the program to ensurc 

www.fcma.,O\' 

www.oig.dhs.gov 16 OIG-13-13 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

consistent national-level cadre management, supporting all reseTVists in deploying at least 

once a year, and ensuring the consistent application of deployment caps and fair application 

of such policies. 

• Disaster Workforce Systems - In fiscal year 2012, FEMA is identifying requirements for a 

system to replace the current Automated Deployment Database (ADD). This systemtargeted to be implemented in fiscal ycar2013-will have as a requirement the improved 

ability to monitor deployment history and duration. Further, FEMA has identified an 

infonnation technology system to track the training, development, and qualifications of its 

disaster workforce. FEMA has committed to use the Bureau of Land Management's [ncident 

Qualifications and Certification System (lQCS) and is scheduled to implement IQCS by 

October 1,2012. 

• FEMA Force Structure - As noted in the report, FEMA commissioned a disaster reserve 

workforce study in 2007 which approximated the number of reservists FEMA would require 

to support high-demand operational periods. Building upon this study, FEMA's Office of 

Policy and Program Analysis (OPPA) and the Response Directorate have refined a force 

structure construct based on historic disaster and deployment data. These force structure 

requirements will infonn disaster assignments for all employees, including Reservists, Cadre 

of On-Call ResponseIRecovery Employees (CORE), and Permanent Full-Time (PFT) staff. 

The force structure identifies the appropriate size, grades, demographics, locations, functions, 

structure, and composition of the workforce needed to address current and future disaster 

workload requirements. It will allow FEMA to identify and address skill gaps or deficiencies 

in mission critical occupations. 

FEMA RespoDse to ole Recommendations 

The draft report contains four recommendations in which 01G recommended that FEMA take the 

following actions: 

OIG Recommendation #1 : Reevaluate the appropriateness of the 78-week cap on the use oflts 

DAE workforce. IfFEMA decides that the cap is not necessary, it should abolish the cap. 

FEMA's RespoDse to Recommendation #1: FEMA concurs with this recommendation. In December 

2011, FEMA's Response Directorate issued policy guidance to all Regional Administrators, Federal 

Coordinating Officers, and National and Regional Cadre Managers to temporarily suspend disaster 

reservists' deployment limits. This policy was issued in order to maintain continuity of critical response and 

recovery operations for tornado outbreaks, Hurricane Irene, and Tropical Stonn Lee. The suspension of 

reservists' deployment limits has continued as FEMA evaluates the cap policy and other options associated 

with it in support of the FEMA Qua1ification System and the new Reservist Program. FEMA expects to 

make a decision regarding the cap policy before the end of fiscal year 2012. 

FEMA considers this recommendation open and resolved until the cap policy decision is made. 

OIG Recommendation #2: If FEMA decides to maintain the cap, take appropriate steps to ensure that the 

Automated Deployment Database, or its replacement, incorporates features that will allow managers to 

identify when DAE program workers will exceed the 78·week maximum deployment limitation. 

www.oig.dhs.gov 17 OIG-13-13 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

FEMA's Response to Recommendation #2: FEMA concurs with this recommendation. FEMA recognizes 

the challenges our managers have faced in monitoring the deployment cap using existing technology. As 

stated above, FEMA is identifying requirements for a system to replace the current Automated Deployment 

Database (ADD); implementation of this new system will occur in fiscal year 2013. The intention is that this 

system will have as a requirement functionality that allows managers to monitor and perfonn analytics on 

deployment activity, including functionality that supports compliance with any deployment caps that are 

reinstated or adjusted. 

FEMA considers this recommendation open and resolved until implementation of the ADD system. 

OIG Recommendation #3: IfFEMA decides to maintain the cap, identify all currently employed 

DAEs who have exceeded the 78-week deployment limitation and initiate actions to (a) replace those 

DAEs with other DAEs, or (b) approve waivers if those DAEs cannot be replaced. 

FEMA's Response to Recommendation #3: FEMA partially concurs with this recommendation. In 

March 2012, all DAEs were reappointed and, therefore, no reservist is currently in excess of the 78-

week deployment limit. Should the cap be reinstated or adjusted, FEMA will ensure compliance with 

the policy through an improved technology system and centralized cadre management. 

FEMA considers this recommendation open and resolved until the cap has been reinstated or 

adjusted. 

OIG Recommendation #4: If FEMA decides to maintain the cap, institute a monitoring program 

that provides FEMA senior management infonnation concerning the extent to which FEMA field 

and headquarters offices are complying with the cap. 

FEMA's Response to Recommendation #4: FEMA concurs with this recommendation. As part of 

regular program updates to senior management, the Incident Workforce Management Office will 

provide information related to deployment duration and compliance along with current reservist 

program policies on this issue. 

FEMA considers this recommendation open and resolved until the cap has been reinstated or 

adjusted. 

Once again, thank you for the opportunity to comment on the draft report. FEMA looks forward to 

working with you on future engagements. Please contact our FEMA Audit Liaison, Gina Norton, at 

202-646-4287, with any questions or concerns regarding this response. 

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

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix D 

Report Distribution 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff

General Counsel 

Executive Secretariat

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 

Administrator, Federal Emergency Management Agency

Director, FEMA GAO/OIG Audit Liaison Office 

Director of Local Affairs, Office of Intergovernmental Affairs

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner

Congress

Senate Committee on Homeland Security and Governmental Affairs 

Senate Committee on Appropriations 

House Committee on Homeland Security Committee 

House Committee on Appropriations Committees

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

ADDITIONAL INFORMATION AND COPIES 

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

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

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

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

at: @dhsoig. 

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

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

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

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

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

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

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