Department of Homeland Security
 

The State of Illinois’ Management of Urban Areas 

Security Initiative Grants Awarded During 

Fiscal Years 2006 Through 2008 

OIG-13-08 November 2012
 
 

 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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

NOV 9 2012 

MEMORANDUM FOR: Elizabeth M. Harman 

Assistant Administrator 

Grant Programs Directorate 

Federal Emergency Management Agency 

FROM: ards 

pector General for Audits 

Anne L. Rich

Assistant Ins

SUBJECT: ThefStatefoffIllinois’fManagementfoffUrbanfAreasfSecurityf

InitiativefGrantsfAwardedfDuringfFiscalfYearsf2006f

Throughf2008f

Attached for your action is our final report, ThefStatefoffIllinois’fManagementfoffUrbanf

AreasfSecurityfInitiativefGrantsfAwardedfDuringfFiscalfYearsf2006fThroughf2008.ffWe 

incorporated the formal comments from the Office of Policy and Program Analysis and 

substantive comments from State of Illinois officials in the final report. 

The report contains eight recommendations aimed at improving the State’s 

management of Urban Areas Security Initiative grants. Your office concurred with the 

intent of three recommendations and concurred with the remaining five 

recommendations. State of Illinois officials also agreed with the recommendations. 

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

recommendations 1 through 5, 7, and 8 resolved and open. Once your office has fully 

implemented the recommendations, please submit a formal closeout letter to us within 

30 days so that we may close the recommendations. The memorandum should be 

accompanied by evidence of completion of agreed-upon corrective actions and of the 

disposition of any monetary amounts. 

Recommendation 6 remains unresolved and open. As prescribed by the Department of 

Homeland Security Directive 077-01, Follow-Up and Resolution 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 

will be considered open and unresolved. 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Consistent with our responsibility under the InspectorfGeneralfAct, we are providing 

copies of our report to appropriate congressional committees with oversight and 

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

the report on our website for public dissemination.

Please call me with any questions, or your staff may contact John E. McCoy II, 

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

Attachment 

2 

MANAGEMENT CONSULTANTS &

CERTIFIED PUBLIC ACCOUNTANTS

September 20, 2012 

Ms. Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General

U.S. Department of Homeland Security 

245 Murray Drive, S.W., Building 410 

Washington, DC 20528 

Dear Ms. Richards, 

Regis & Associates, PC performed an audit of the State of Illinois’ management of the 

Department of Homeland Security’s Urban Areas Security Initiative grants for Fiscal 

Years 2006 through 2008. The audit was performed in accordance with Contract 

Number TPD-FIGBPA-07014; Task Order 0001, dated September 29, 2009. This report 

presents the results of the audit, and includes recommendations to help improve the 

State of Illinois’ management of the audited Urban Areas Security Initiative grants. 

Our audit was conducted in accordance with applicable GovernmentfAuditingfStandards, 

2007 revision. The audit was a performance audit, as defined by Chapter 1 of the 

Standards, and included a review and report on program activities with a compliance 

element. Although the audit report comments on costs claimed by the State, we did not 

perform a financial audit, the purpose of which would be to render an opinion on the 

State of Illinois’ financial statements, or the funds claimed in the Financial Status 

Reports submitted to the Department of Homeland Security. 

We appreciate the opportunity to have conducted this audit. Should you have any 

questions or need further assistance, please contact us at (202) 296-7101. 

Sincerely, 

Peter R. Regis, CPA 

Partner

Regis & Associates, PC 

1400 Eye Street, NW, Suite 425, Washington, D.C. 20005 Tel 202-296-7101 Fax 202-296-7284 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

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

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

State Grants Management Practices Were Generally Effective, But Some 

Improvements Needed .................................................................................... 3 

Capabilities and Risk Assessments ......................................................................... 4 

Recommendations ................................................................................................. 6 

Management Comments and Auditors’ Analysis .................................................. 6 

Performance Measurement Processes .................................................................. 7 

Recommendation ................................................................................................... 8 

Management Comments and Auditors’ Analysis .................................................. 8 

Property, Inventory, and Procurement Requirements .......................................... 9 

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

Management Comments and Auditors’ Analysis ................................................ 11 

Timeliness of Subgrantee Awards ........................................................................ 12 

Recommendation ................................................................................................. 13 

Management Comments and Auditors’ Analysis ................................................ 13 

Appendixes

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

Appendix B: Management Comments to the Draft Report............................... 17 

Appendix C: Homeland Security Grant Program Background .......................... 21 

Appendix D: Organization Chart ........................................................................ 22 

Appendix E: Report Distribution ....................................................................... 23 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

www.oig.dhs.gov OIG-13-08 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Abbreviations

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency

FY fiscal year

OIG Office of Inspector General

THIRA Threat and Hazard Identification and Risk Assessment 

UASI Urban Areas Security Initiatives 

www.oig.dhs.gov OIG-13-08 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary

Regis & Associates, PC completed an audit of the State of Illinois’ Management of the 

Urban Areas Security Initiative Grants awarded during fiscal years 2006 through 2008. 

The audit objectives were to determine whether the State distributed and spent Urban 

Areas Security Initiative grant funds strategically, effectively, and in compliance with

laws, regulations, and guidance. The audit included a review of approximately 

$145 million of Urban Areas Security Initiative grants awarded by the Federal Emergency 

Management Agency (FEMA) to the State of Illinois.

Generally, the State did an efficient and effective job of administering the program 

requirements and distributing grant funds to the State’s two Urban Areas Security 

Initiative subgrantees, the City of Chicago and Cook County, which comprise the 

Chicago/Cook County urban area. The Chicago/Cook County urban area developed 

measurable goals, which were reflected in the Urban Area Strategy, and linked allhazards capabilities to goals through related projects. The Urban Area used reasonable 

methodologies for prioritizing needs, and the State distributed funds and resources 

based on the Urban Area strategic goals and investment justifications. Grants were 

generally administered in compliance with applicable guidance and the State generally 

provided adequate monitoring and oversight. 

However, improvements are needed in the State’s management of the Urban Areas

Security Initiative grants to enhance capabilities and risk assessments; measure 

performance; require the Urban Area subgrantees to comply with property, inventory, 

and procurement requirements; and ensure subgrantee funds are awarded in a timely 

manner. The eight recommendations call for FEMA to initiate improvements, which if 

implemented, should help strengthen program management, performance, and 

oversight. FEMA concurred with the intent of three recommendations and concurred 

with the remaining five recommendations. The Illinois Emergency Management Agency 

agreed with the recommendations, and while it did not provide a formal response for 

inclusion in the final report, it provided substantive comments to the draft report. 

Comments to the draft report are incorporated as appropriate, and FEMA’s written 

comments are included in their entirety in appendix B. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

Homeland Security Grant Program 

The Homeland Security Grant Program is a Federal assistance grant program 

administered by the U.S. Department of Homeland Security (DHS), Grant Programs 

Directorate, within FEMA. 

The Homeland Security Grant Program provides Federal funding to help States and local 

agencies enhance their capabilities to prevent, deter, respond to, and recover from 

terrorist attacks, major disasters, and other emergencies. The Homeland Security Grant 

Program encompasses several interrelated Federal grant programs that together fund a 

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

training, and exercises, as well as management and administrative costs. A description 

of the individual grant programs within the Homeland Security Grant Program is 

included in appendix C. 

State Administrative Agency 

The Governor of Illinois designated the Illinois Terrorism Task Force, a Bureau of the 

Illinois Emergency Management Agency, the responsibility to manage the grant 

programs in accordance with established Federal guidelines, and allocate funds to 

Urban Areas Security Initiative (UASI) recipients. Appendix D contains a chart depicting 

the structure and relationship of the Illinois Emergency Management Agency, the Illinois 

Terrorism Task Force, and Chicago/Cook County Urban Area. 

Urban Area Working Group 

Chicago/Cook County Urban Area Working Group is the Federally-required governance 

group for purposes of the UASI grant. The Urban Area Working Group responsibility is 

to aid the Urban Area to plan, set priorities, and determine how UASI grant funds will be 

spent to further homeland security preparedness for its region. The Urban Area 

Working Group is also responsible for coordinating the development and 

implementation of all program initiatives related to UASI funds. 

Chicago Office of Emergency Management and Communications, and the Cook County 

Judicial Advisory Council provided the grants management functions for City of Chicago 

and Cook County, during the period covered by the audit. The City and County 

departments provided staff support and meeting organization for the Urban Area 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Working Group, and assisted in writing and submitting Federally required grant 

documents to the State. 

Grant Funding 

The State of Illinois received approximately $145 million in funds for the UASI grant 

program during fiscal years (FYs) 2006 through 2008. During each of those years, the 

State Administrative Agency awarded subgrants to the Urban Area’s two subgrantees, 

which are the City of Chicago and Cook County. 

The Urban Area used the grant funds primarily to purchase equipment for 

interoperability among law enforcement, fire service, and medical emergency agencies; 

and to provide preparedness training and exercises. Table 1 identifies a breakdown of 

the UASI grant funds awarded by year.

Table 1 

Illinois Homeland Security Grant Program 

UASI Awards FYs 2006 through 2008 

FY 2006 FY 2007 FY 2008 Total 

$52,260,000 $47,280,000 $45,861,000 $145,401,000 

Regis & Associates, PC completed an audit of the State of Illinois’ management of UASI 

grants awarded during FYs 2006 through FY 2008. The audit objectives were to 

determine whether the State distributed and spent Urban Areas Security Initiative grant 

funds strategically, effectively, and in compliance with laws, regulations, and guidance. 

Appendix A to this report provides details on the purpose, scope, and methodology of 

this audit. 

Results of Audit 

State Grants Management Practices Were Generally Effective, But Some 

Improvements Needed

Generally, the State did an efficient and effective job of administering the 

program requirements and distributing grant funds, but improvements are 

needed. The Urban Area developed measurable goals, which were reflected in 

the Urban Area Strategy, and linked all-hazards response capabilities to goals 

through related projects. The Urban Area used reasonable methodologies for 

prioritizing needs, and the State distributed funds and resources based on the 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Urban Area strategic goals and investment justifications. Grants were generally 

administered in compliance with applicable guidance, and the State generally 

provided adequate monitoring and oversight. 

To enhance Illinois’ management of the UASI grant program the State needs to: 

• Perform capabilities and risk assessments; 

• Establish and document a performance measurement process; 

• Comply with property, inventory, and procurement requirements; and 

• Award subgrantee funds in a timely manner.

Capabilities and Risk Assessments

The Urban Area performed a capability assessment in FY 2006. However, the 

Urban Area did not reassess its capability gaps in FY 2007 and FY 2008. Also, the 

Urban Area did not perform a comprehensive risk assessment. 

Urban Area Did Not Update Capabilities Assessments

In FYs 2007 and 2008, the Urban Area did not update its capabilities assessments 

to reflect capabilities enhancements, as part of the annual planning process. 

During FY 2006, first responders and emergency management officials from the 

City of Chicago and Cook County, representing the Urban Area, participated in a 

Statewide capabilities assessment, conducted by the State of Illinois. This 

Statewide assessment was part of the State’s Program and Capability Review 

Enhancement Plan that was required to be submitted to FEMA with the FY 2006 

grant application. However, in FY 2007 and FY 2008 the Urban Area did not 

conduct assessments of current capabilities. Although an updated assessment 

was not mandated, updated assessments are necessary to reevaluate gaps 

identified in FY 2006. 

ThefNationalfPreparednessfGuidelines,fSeptemberf2007fstates that strategies are 

multi-year planning vehicles supported by specific annual work plans that 

describe each year’s approach to meeting the longer term strategy. The core of 

the Capabilities-Based Preparedness approach is the comparison of current 

capabilities with risk-based target capability levels. Further, thefNationalf

PreparednessfGuidelinesfstate that capability assessments measure the current 

level of capability against the target levels of capability from the Target 

Capabilities List applicable to the respective level of government.

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We discussed with Urban Area officials why capabilities were not reassessed for 

the Urban Area. According to the City of Chicago grants management officials, 

they did perform subsequent capability assessments in FY 2007 and FY 2008, 

which they believed to be sufficient. They noted that these assessments were 

done at the City of Chicago department level, and discussed at the Urban Area 

committee meetings. However, the documentation provided to us during the 

audit did not validate that these capability assessments were performed. For 

example, the documentation provided consisted of a series of handwritten 

meeting notes, which had very little content to support performance of actual 

capability assessment. In our discussion with Cook County officials, they stated 

they did not have the resources to complete a formal capability assessment in 

FYs 2007 and 2008. 

Urban Area Did Not Perform a Comprehensive Risk Assessment 

The Urban Area did not perform a comprehensive risk assessment that focused 

on the Urban Area as a whole during FYs 2006-2008. The City of Chicago 

conducted a risk assessment in March 2006, but it only covered the City of 

Chicago and did not address any other area of Cook County. Cook County did 

not complete a risk assessment; therefore, the entire Urban Area risk assessment 

was not addressed. 

Risk assessments are critical to the planning process, because they allow the 

Urban Area Working Group to measure existing capability levels against the 

target or planned levels of capability, and aid in the decision making process in 

allotting funds to those areas to minimize or close capability gaps. The risk 

assessment process is significant, because it can provide an assessment of 

strengths and weaknesses of the Urban Area’s threats and vulnerabilities, and its 

capabilities to protect citizens, facilities, infrastructure, and key assets. 

The FY 2006 National Infrastructure Protection Plan required States to establish 

security partnerships, facilitate coordinated information sharing, and enable 

planning and preparedness for Critical Infrastructure/Key Resource protection 

within their jurisdictions. The process for Critical Infrastructure/Key Resource 

protection included developing a unified approach to Critical Infrastructure/Key 

Resource identification, risk determination, mitigation planning, prioritized 

security investment, and exercising preparedness among all relevant 

stakeholders within their jurisdictions.

According to Cook County officials, they did not have the resources to complete 

the risk assessments countywide. Their grant funding was targeted at 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

investments to acquire equipment and infrastructure resources that were 

prioritized in the Urban Area strategy. 

Without risk assessments, the Urban Area may not be able to identify capability 

gaps, which could lead to investing grant funds in efforts that do not reduce 

gaps. The need for capabilities or risk assessments may also create unnecessary 

redundancies, or having funds targeted to areas where capabilities are no longer 

needed. In the event of an all-hazards situation, these capability gaps could 

result in some or all portions of the designated Urban Area being unprepared, 

which may lead to loss of life and property. 

Recommendations 

We recommend that the Assistant Administrator, Grant Programs Directorate, 

require the Director of the Illinois Emergency Management Agency to ensure 

that the Urban Area Working Group: 

Recommendation #1:

Updates capabilities assessments at least annually, in order to determine the 

status on the Urban Area’s capabilities. 

Recommendation #2: 

Performs risk assessments that cover the entire Urban Area. 

Management Comments and Auditors’ Analysis 

FEMA concurred with the intent of Recommendations 1 and 2, and indicated in 

its written response that its Threat and Hazard Identification and Risk 

Assessment (THIRA), a risk assessment process, incorporates the intent of the 

recommendations. The THIRA is now a requirement for grantees, with the first 

iteration due December 31, 2012. 

Although the State did not provide a formal response for inclusion in the final 

report, it provided substantive comments to the draft report. In its comments, 

the State noted that the Urban Area participated in the development of the 

State Preparedness Report in FY 2007 and FY 2008 as required in the guidance. 

The Urban Area also conducted multiple Homeland Security Exercise and

Evaluation program validations during this period. The State also noted that 

during this period, the State of Illinois conducted a comprehensive Statewide risk 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

assessment as part of the 2006 Emergency Management Accreditation Program 

process. Additionally, the State of Illinois conducted a Statewide multi-hazard 

assessment for FEMA in October 2007. 

The actions proposed by FEMA, and comments from the Illinois Emergency 

Management Agency, meet the intent of the recommendations. 

Recommendations 1 and 2 are considered resolved and open, pending final 

implementation of the proposed FEMA actions. 

Performance Measurement Processes

The Urban Area did not establish a process to measure performance and

progress towards strategic goals and objectives. The Urban Area also did not 

establish procedures for documenting the performance measures it claimed to 

have performed. Specifically, City of Chicago officials stated that there were 

informal performance measurement processes, during FYs 2006 through FY 

2008, but they were not able to explain, demonstrate, or adequately support 

those assertions. City of Chicago officials stated that they collected performance 

data at City of Chicago department and agency levels. However, there was no 

indication that such data was being analyzed, reconciled, or used for 

performance measurement. 

Cook County did not provide any evidence that a performance measurement 

process existed during the period covered by our audit. According to Cook 

County officials, they conducted annual exercises from multiple disciplines within 

the Urban Area to measure performance, but were unable to provide 

documentation to support this assertion. Cook County officials also stated they 

measured performance through a criteria-based evaluation program identified in 

the Urban Area Homeland Security Strategy. However, these officials were 

unable to provide evidence that this occurred.

According to DHSfStatefandfUrbanfAreafHomelandfSecurityfStrategyfGuidancefonf

AligningfStrategiesfwithfthefNationalfPreparednessfGoalf(Julyf2005), to ensure 

the success of the strategy, the Urban Area must guarantee that it has an 

evaluation plan for monitoring progress, compiling key management 

information, tracking trends, and keeping the strategy on track. The evaluation 

plan should outline a process for reviewing and analyzing the steps being taken 

to achieve the goals and objectives of the strategy as well as determining 

whether the right elements are being used to measure progress. Measurable 

goals and objectives are the foundation to determining progress. Goals and 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

objectives that are specific, quantifiable, and time sensitive allow for progress to 

be measured during the evaluation process. 

The Urban Area Working Group did not invest funding and staffing to establish a 

process for measuring performance of the Urban Area. Without a performance 

measurement process, the Urban Area was not be able to demonstrate progress 

towards achieving its strategic goals and objectives, or to measure the affect of 

grant-funded projects effectively. Further, the Urban Area was not able to 

measure preparedness improvements in order to gauge their capabilities and 

preparedness levels in the event of a catastrophic event. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate, 

require the Director of the Illinois Emergency Management Agency to: 

Recommendation #3:

Ensure that the Urban Area Working Group establishes and utilizes a 

performance measurement process that can assess the progress towards 

implementing the Urban Area strategic goals and objectives. 

Management Comments and Auditors’ Analysis 

FEMA concurred with the intent of Recommendation 3, and indicated in its 

written response that it redesigned the State Preparedness Report, which is 

required from all grantees by December 31, 2012, to include assessments that 

are customized to each capability target that is relevant to the jurisdiction in 

question. The capability targets come directly from the Threat and Hazard 

Identification and Risk Assessment (THIRA). 

In its substantive comments to the draft report, the State noted that beginning 

in FY 2010, the State of Illinois required the Urban Area subgrantees to develop 

specific measurable outcomes associated with the approved projects. These 

outcomes, including incremental milestones, are required to be reported to the 

State on a quarterly basis throughout the performance period. 

The actions proposed by FEMA, and comments from the Illinois Emergency 

Management Agency, meet the intent of the recommendation. 

Recommendation 3 is considered resolved and open, pending final 

implementation of the proposed FEMA action. 

www.oig.dhs.gov 8 OIG-13-08 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Property, Inventory, and Procurement Requirements 

The State did not ensure the submission of timely, complete, and accurate 

inventory records by the two Urban Area subgrantees, City of Chicago and Cook 

County, as required by the State. The Urban Area did not properly tag 54 out of 

84 equipment inventory items observed as purchased with DHS funds. Also, 

Cook County did not always comply with Federal and local procurement 

regulations regarding UASI funded expenditures. 

The Urban Area Did Not Submit Timely, Complete, and Accurate Inventory 

Records 

The State did not enforce the submission of timely, complete, and accurate 

inventory records by the City of Chicago and Cook County that would enable the 

State and other stakeholders to plan for their usage. These records are 

necessary for the State to perform inventory verification. Both the City of 

Chicago and Cook County did not provide timely, accurate, and complete 

inventory records to the State on multiple occasions.

According to the State, Cook County submitted a report in January of 2006 that 

did not meet the Federal rules for property management (i.e., not tied to the 

grant funding, no acquisition price, or no location). According to State Officials, 

multiple requests were made for the annual inventory report. 

According to the State, the City of Chicago submitted an incomplete report in 

2008; they then submitted an incomplete update in January 2010. State officials 

noted that the State’s grant Compliance Officer has spent more than 150 hours 

since January 2010 attempting to reconcile the inventories submitted by the City 

of Chicago and Cook County with Illinois Terrorism Task Force payment records. 

However, instead of initiating corrective actions to resolve the issues, the State 

continued to work with the City of Chicago and Cook County to incrementally 

correct the inventories with the expectation that they would eventually comply 

with the State’s requirement to provide complete and accurate annual grant 

funded inventory reports. 

Equipment Purchased with DHS Grant Funds Were Not Properly Tagged

The Urban Area did not properly tag 54 of the 84 equipment inventory items 

observed, as equipment purchased with DHS funds. These included a Bomb and 

Arson Vehicle costing $131,797 and a High Capacity Imaging Device costing 

$214,657. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA’s special award condition in the grant award to the State includes a 

requirement that recipients agree, when practicable, that any equipment 

purchased with grant funding shall be prominently marked as: “Purchased with 

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

The State did not enforce FEMA guidelines to ensure that equipment purchased 

with DHS grants was tagged and identified as being purchased with DHS funds. 

The City of Chicago, as a result of this audit, is tagging their equipment, as 

required. According to the City of Chicago, they were previously unaware of the 

requirement. Cook County’s policy required departments receiving equipment 

to use an internal Cook County Department of Homeland Security Fixed Asset 

tag, instead of the DHS tag. According to Cook County officials, they believed 

that their internal policy takes precedence over FEMA’s policy. 

Without adequate and complete inventory records, there is no reasonable 

assurance that assets acquired with grant funds were adequately safeguarded to 

prevent loss, damage, or theft. Without proper identification, it would be 

difficult to identify and account for the equipment purchased with DHS funds. In 

the event of an all-hazards event, the inability to deploy needed equipment 

because of improper accountability of such equipment could result in loss of life 

and property. 

Federal and Local Procurement Regulations Were Not Always Followed

Cook County did not always comply with Federal and local procurement 

regulations regarding UASI funded expenditures. The Office of Inspector General 

(OIG) conducted a separate review of UASI-funded procurements for Project 

Shield interoperable communications equipment in Cook County and identified 

deficiencies in the procurement process. See report number OIG-12-19 

HomelandfSecurityfGrantfProgramfFundsfAwardedfforfProjectfShieldfdated 

December 2011 for further details. In addition, the OIG conducted a limited 

review of other UASI-funded procurements in both the City of Chicago and Cook 

County, and determined that Cook County did not have documentation, such as 

competitive quotations and sole source justifications, for procurements outside 

of Project Shield. 

Recommendations 

We recommend that the Assistant Administrator, Grant Programs Directorate, 

require the Director of the Illinois Emergency Management Agency to: 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation #4:

Maintain complete, accurate, and timely inventory records of all equipment 

purchased, including non-expendable property, with Department of Homeland 

Security grant funds. 

Recommendation #5:

Ensure the Urban Area tags and identifies equipment in compliance with FEMA 

requirements. 

Recommendation #6:

Ensure that Cook County complies with Federal and Local procurement 

regulations. 

Recommendation #7:

Review all Cook County procurements, funded by UASI funds, to determine 

reasonableness of cost, and recover amounts deemed unreasonable. 

Management Comments and Auditors’ Analysis 

FEMA concurred with Recommendations 4, 5, 6, and 7. Regarding 

Recommendations 4 and 5, FEMA will require the State Administrative Agency, 

within 90 days, to provide a plan for managing grant funded equipment, to 

include a detailed process for tagging and identifying equipment. For 

Recommendation 6, FEMA will require the Illinois Emergency Management 

Agency Director to ensure the development of procurement Standard Operating 

Procedures for Cook County, as related to Federal awards. However, FEMA did 

not provide a final implementation timetable. For Recommendation 7, FEMA 

will require the Illinois Emergency Management Agency Director to ensure that 

the Urban Areas Working Group creates and reviews a complete list of all Cook 

County for 2006-2008 with UASI funds, and provide to FEMA within 180 days an 

analysis of any items and costs deemed unreasonable. 

In its substantive comments to the draft report, the State provided a summary of 

monitoring visits to Cook County and Chicago during the period and beyond, 

which did not specifically address the intent of the recommendations.

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The actions proposed by FEMA meet the intent of the recommendations. 

Recommendations 4, 5, and 7 are considered resolved and open, pending final 

implementation of the proposed actions. Until FEMA provides a firm timetable 

for implementing Recommendation 6, the recommendation will remain 

unresolved and open. 

Timeliness of Subgrantee Awards

The State did not award funds to the Urban Area subgrantees timely as required 

by FEMA. For FYs 2006 through 2008, the subgrants were awarded after the 

required timeframes established by FEMA, as shown in table 2. 

Table 2: Timeliness of Subgrantees Awards 

Subgrantee / FY Amount 

Deadline to 

Award 

Subgrantees 

Subgrantee 

Award Date 

# of 

Days 

Late 

City of Chicago 2006 $39,195,000 09/22/06 10/02/06 10 

Cook County 2006 $13,065,000 09/22/06 10/02/06 10 

City of Chicago 2007 $30,732,000 10/08/07 03/26/08 170 

Cook County 2007 $16,548,000 10/08/07 03/28/08 172 

City of Chicago 2008 $29,536,975 10/18/08 11/24/08 37 

Cook County 2008 $15,904,525 10/18/08 11/05/08 18 

The Special Terms and Conditions of the FEMA Grant Award states that the 

recipient must submit within 60 days of the grant award an Initial Strategy 

Implementation Plan of the funding to be allocated per Investment based upon 

the final grant award amounts. The recipient must also submit a certification 

that funds have been obligated to local units of government (to include the 

identification of subgrantees and sub-award amounts). Failure to provide this 

information within the required time frame may result in National Preparedness 

Directorate withholding grant funds from further draw down. 

In FYs 2006 and 2007, the requirement was 60 days and was changed in FY 2008 

to 45 days. The DHS Financial Management Guide dated January 2006, states 

that obligations are a legal liability to pay, under a grant, subgrant, and/or 

contract, determinable sums for services or goods incurred during the grant 

period. The award document constitutes the operative document obligating and 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

reserving Federal funds for use by the recipient in execution of the program or 

project covered by the award. 

State officials believed that they complied with the FEMA requirement to

obligate funds to its subgrantees within the established timeframe (60 or 45 

days, as applicable) of the State receiving FEMA award. State officials believed 

that through other communications, such as email, that the City of Chicago and 

Cook County officials were notified of their awards and amounts, prior to the 

actual date of the signed subgrant award letters. However, subgrantees could 

not use the funds until the award letters were signed. 

Delays in making funds available to the subgrantees may result in delaying 

projects intended to increase homeland security and achieve program 

objectives. Consequently, this could affect the subgrantees’ preparedness for 

catastrophic or potential hazardous events threatening the Urban Area. 

Additionally not complying with requirements to provide these funds within the 

established timeframe could result in FEMA withholding grant funds from 

further drawdown. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate 

require the Director of the Illinois Emergency Management Agency to: 

Recommendation #8:

Comply with FEMA’s requirement to ensure that funds are obligated to the 

subgrantees within the FEMA specified timelines. 

Management Comments and Auditors’ Analysis 

FEMA concurred with Recommendation 8, and indicated in its written response 

that it will require the State Administrative Agency within 90 days to review 

current State of Illinois policies and procedures to identify opportunities to 

expedite the fund obligation process to subgrantees. 

The actions proposed by FEMA meet the intent of the recommendation. The 

recommendation is considered resolved and open, pending final implementation 

of the proposed FEMA action. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

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

established by the HomelandfSecurityfActfoff2002 (Public Law 107-296) by amendment 

to the InspectorfGeneralfActfoff1978. This is one of a series of audit, inspection, and 

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

efficiency, and effectiveness within the Department. 

The purpose of the audit was to determine whether the State distributed and spent 

UASI grant funds strategically, effectively, and in compliance with laws, regulations, and 

guidance. The goal of this audit was to identify problems and solutions that can help 

the State of Illinois better prepare for and respond to threats, acts of terrorism, and 

other hazards. The audit further enabled us to answer the following nine researchable 

questions: 

• Were measurable goals developed from plans? 

• Do funded plans link all-hazards capabilities to goals? 

• Were funds and resources distributed based on goals? 

• Does the State accurately measure risk? 

• Does the State measure response capability? 

• Can the State demonstrate improved performance?

• Were grants administered compliantly? 

• Did the State monitor grant programs? 

• What innovative practices can be used by other States? 

The scope of the audit included the UASI grant awards for FYs 2006, 2007, and 2008 as 

described in appendix C of this report and summarized in table 1. 

The audit methodology included work at the offices responsible for the management of 

the grants, specifically: FEMA Headquarters, the State of Illinois Emergency 

Management Agency, the City of Chicago’s Office of Emergency Management 

Communications, and Cook County Department of Homeland Security. To achieve our 

audit objectives, we analyzed data, reviewed documentation, and interviewed the key 

State and Local officials directly involved in the management and administration of the 

City of Chicago/Cook County Urban Area grant programs. 

Because of procurement issues identified during a separate OIG audit of Cook County’s 

Project Shield, the OIG supplemented this audit with an additional review of the UASI 

procurement process. The OIG review was limited to the sample of financial 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

expenditures we selected to test for the City of Chicago and Cook County. The OIG 

conducted this review in response to procurement issues identified in its December 

2011 report titled HomelandfSecurityfGrantfProgramfFundsfAwardedfforfProjectfShield,f

OIG-12-19. The OIG findings from this limited review are discussed in the section titled 

FederalfandfLocalfProcurementfRegulationsfWerefNotfAlwaysfFollowed.

During the fiscal years covered by this audit, the State Administrative Agency awarded 

UASI funding to the City of Chicago and Cook County. The City of Chicago then 

disbursed the funding to four local agencies: the Office of Emergency Management and 

Communications, the Police Department, Fire Department and the Department of the 

Environment. However, the Office of Emergency Management and Communications 

procured and disbursed equipment on behalf of the Department of the Environment. 

These agencies then procured and disbursed the equipment throughout the City of 

Chicago. 

Cook County disbursed 96 percent of the funding to two local agencies: the Sherriff’s 

Department and the Judicial Advisory Council. These agencies then procured and 

subsequently disbursed the equipment throughout Cook County. 

We conducted site visits for equipment verification and interviews with Chicago/Cook

County Urban Area Working Group officials at the following 16 City and County local 

agencies and jurisdictions:

City of Chicago Departments 

• 311 Call Center

• Communication Emergency Center 

• Fire Department 

• Office of Emergency Management and Communications 

• Police Department 

Cook County Departments 

• Department of Homeland Security and Emergency Management

• Department of Public Safety 

• Emergency Telephone Systems Board 

• Medical Examiner’s Office 

• Sheriff’s Department

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Local Jurisdictions within Cook County 

• Fire and Emergency Management Services, Village of Western Springs 

• North Maine Fire Protection District, Des Plaines 

• Northeastern Illinois Public Safety Training 

• Oak Forest Hospital 

• Oak Park Police 

• Prospect Heights Police 

We interviewed responsible officials, reviewed documentation supporting the State and 

subgrantees management of the awarded grant funds. We judgmentally selected items 

from supplied inventory listings and physically inspected the equipment procured with 

the grant funds at various locations throughout Cook County and the City of Chicago. 

We held discussions with the appropriate officials which were awarded UASI Grants, in 

order to determine whether grant program funds were expended according to grant 

requirements and priorities established by the State of Illinois.

We conducted this performance audit between December 2009 and April 2010, 

pursuant to the InspectorfGeneralfActfoff1978, as amended, and according to generally 

accepted government auditing standards. Additionally, the OIG performed testing of 

the procurement process in February and March 2012. 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 on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our findings and 

conclusions, based on our audit objectives. 

Although this audit included a review of costs claimed, we did not perform a financial 

audit of those costs. This was a performance audit as defined by Chapter 1 of the 

Standardsfand included a review and report of program activities with a compliance 

element. Regis and Associates PC was not engaged to, and did not perform a financial 

statement audit, the objective of which would be to express an opinion on specified 

elements, accounts, or items. Accordingly, we were neither required to review, nor 

express an opinion on, the costs claimed for the grant programs included in the scope of 

the audit. Had we been required to perform additional procedures, or conduct an audit 

of the financial statements in accordance with generally accepted auditing standards, 

other matters might have come to our attention that would have been reported. This 

report relates only to the programs specified, and does not extend to any financial 

statements of the State of Illinois. 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

U.S. D~p3 rtm~nt of Uomtland Sec. rity 

Wnshill!,1oll. DC 20472 

AUG 1 5 2012 

MEMORANDUM FOR: Anne L Richards 

Assistant Inspector General fo r Audits 

omce or Inspector Geneml 

FROM: David J. Kaufma~ ./" 

Director 1ft-/" 

Office of Policy and Program Analysis 

SUBJECT: Response to Draft Report: The SUI!e oj minois' Managemem of Urban 

Areas Security II/itimi,;e Grams Awarded Dm'jng Fiscal Years 2006 

Through 2008 

fEMA appreciates the opportunity to review and respond to the Office of Inspector General draft 

report The Stale of Illinois' Managemenl of Urban Areas Security Initialive Grants AU'arded During 

Fiscal Years 2()06 Through 2U08. 

The following are our responses to the recommendations for corrective action, 

Recommendation #1: \\le recommend that the Assistant Administrator, Grant Programs 

Directorate, require the Director of the llIinois Emergency Management Agency to ensure that the 

Urban Area Working Group urx:lates capabilities assessments at lea"t annually, in order to determine 

the status on the Urban Area's capabilities. 

FEMA Response: FEMA concurs with the intent oflhis recommendation. While capabilities 

assessments are strongly encouraged, annual updates are not currentl y a requirement. The Threat and 

Hazard Identification and Risk Assessment (THIRA ..), a risk assessment process, incorporales the 

intent of this recommendation. The THlRA helps whole community members identify and 

understand likely vulnerabilities in order to manage risk. Part of this process involves examining 

core capabilities as well as sening capability targets. The first iteration of the THIRA is due 

December 31 , 2012. FEMA requeSlS that this recommendation be resolved and open pending 

submission amJ revit!w of the Chic<lgo Urban Area's THlRA. 

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

Directorate, rcquirc the Director of the Illi nois Emergency Management Agency to ensure that the 

UrbWl Area Working Group performs risk asscssments that cover the entire Urban Area, 

www.ICmagov 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

FEMA Response: FEMA concurs with the intent of this recommendation. Thc introduction of the 

THlRA process (please see FEMA response to recommendation #1) identifies risk across the entire 

Urban Area and uses existing .r:isk assessments efforts already in place. THIRA is an adaptablc 

process which seeks to identify and define potential emergency situations and apply capability 

targets to leverage resources to prevent. protect against, mitigate, respond to, and recover from risks. 

FE:MA requests that this recommendation be resolved and opcn pcnding submission and review of 

the Chicago Urban Area's THIRA. 

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

Directorate. require the Director of the Illinois Emergency Management Agency to ensure that the 

Urban Area Working Group establishes and utilizes a perfonnance mea<;;urement process that can 

assess the progress towards implementing the Urban Area strategic goals and objectives. 

FEMA Response: FEMA concurs with the intent of this recommendation. Effective application of 

grant funding will result in the decrease of risk-gaps in required capability-over time. The 

assessment of CLUTent capability and documentation of oUb.tanding capability gaps, therefore, 

becomes a critical c:omponent to understanding grant effectiveness. States and territories submit this 

information through the State ~reparedness Report (SPR). All states and territories that receive 

federal preparedness assistance are required to submit an annual SPR capability assessment to the 

Administrator. In 2011, FEMA redesigned the SPR assessment with two important considerations. 

First, the SPR customizes each assessment to the capability targets that are relevant to the 

jurisdiction in question; these capability targets currently come directly from the THlRA, (Setting 

capabilities targets is Step 4 in the Comprehensive Preparedness Guide 201: THrRA Guide 

published in Apri12012.) The first iteration of the THIRA.. is due December 3l, 2012. Second, the 

SPR measures current capability levels for each of the 31 core capabilities in tenns of planning, 

organization, equipment, training, and exercises-the same elements that are used in grant project 

reporting through the Biannual Strategy Implementation Report (BSIR). This results in up to 1 S5 

individual measures with which to track residual capability gaps and to indicate the degree of 

progress over time as states continue to invest grant funding. Grantees are rcquired to demonstrate 

how proposed projects address gaps and deficiencies in delivering one or more core capabilities. 

FEMA requests that this recommendation bc resolved and open pcnding submission and review of 

the Chicago Urban Area's TIllRA. 

Recommendation #4: We recommend that the Assistant Administrator, Grant Programs Directorate, 

require the Director of the Illinois Emergency Management Agency to ensure that the Urban Area 

Working Group maintain complete, accurate, and timely inventory records of all equipment 

purchased, including non-expendable property, with Department of Homeland Security grant ftmds. 

FEMA Response: FEMA concurs with this recommerxiation. The CFR Title 44 § 13.32 (d), 

Managerrrent Requirements, states the minimum requirements for managing equipment purchased 

with grant fimds. Each state is monitored by FEMA to ensure compliance with the equipment 

management requirements cited within 44 CPR. Grantees must comply with these standards in 

accordance with the applicable grant terms, conditions and assurances. The SAA will be required to 

provide a plan for managing grant funded equipment (to include the maintenance of complete, 

accurate, and timely inventory) to their GPD Program Analyst within 90 days of the receipt of the 

response to the final report via the grantee notification. FEMA requests that this recommendation be 

resolved and open pending approval and implementation of the stated corrective action. 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Reeommendation #5: We recommend that the Assistant Administrator. Grant Programs Directorate, 

require the Director of the TIlinois Emergency Management Agency to ensure that the Urban Area 

Working Group ensure the Urban Area tags and identifies equipment in compliance with FEMA .. 

requirements. 

FEMA Response: FEMA concurs with this recommendation. Per FEMA response to 

recommendation #4, the SAA 'Will be required to provide a plan for managing grant funded 

equipment which will include a detailed process for tagging and identifYing equipment in 

compliance with 44 CFR. as well as applicable guidance within 90 days of the reccipt of the 

response to the [mal report via the grantee notitication. FEMA requests that this recommendation be 

resolved and open pending implementation of the stated corrective action. 

Recommendation #6: We recommend that the Assistant Administrator, Grant Programs Directorate, 

require the Director of the 11Iinois Emergency Management Agency to ensure that the Urban Area 

Working Group ensure that Cdok County complies with federal and local procurement regulations. 

FEMA Response: FEMA concurs with this recommendation. FEMA will require the lEMA 

Director to ensure the development of procurement Standard Operating Procedures (SOP) for Cook 

County as related to federal awanls. The SOP should include policies and procedures that adhere to 

federal, state, and local procurement regulations. In order to verify implementation, FEMA will 

require an update report on progress from lEMA within 120 days of the date of the grantee 

notification letter on this required corrective action. FEMA requests this recommendation be 

resolved and open pending implementation of the stated corrective actions. 

Recommendation #7: We recommend that the Assistant Administrator, Grant Programs 

Directorate, require the Director of the Illinois Emergency Management Agency to ensure that the 

Urban Area Working Group review all Cook County procurements, funded by UASI funds, to 

detennine reasonableness of cost. and recover amoWlts deemed unreasonable. 

FEMA Response: FEMA concurs with this recommendation. FE:MA ",ill require the lEMA 

Director to ensure the UAWG creates and reviews a complete list of all Cook COWlty pW"Chases for 

2006- 2008 with VASl funds. Within the list, the UAWG should identifY any items deemed 

potentially unreasonable. The lEMA will review the full list and provide further analysis of any 

items and costs that are deemed unreasonable. The results of that analysis V\oul be submitted to the 

GPD Program Analyst for FEMA review, within 180 days of the issuance of the final report. 

FEMA requests this recommendation be resolved and open pending full resolution of the stated 

corrective actions. 

Recommendation #8: We recommend that the Assistant Administrator, Grant Programs 

Directorate, require the Director of the I11inois Emergency Management Agency to comply with 

FEMA's requirement to ensure that funds are obligated to the subgrantees within the FEMA 

specified timelines. 

FEMA Response: FEMA concurs with this recommendation, HSGP guidance requires the SAA to 

obligate at least 80% of funds awarded under VASI to local units of government within 45 days of 

receipt of the funds. The SAA will be required to conduct an assessment of Illinois' current policies 

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OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

and procedures involved in the execution of gra..'1t agreements and obligation of funds to identify 

opportunities to expedite the process within 90 days of the receipt of the response to the final report 

via the grantee notification. Results of this assessment with areas of improvement must be submitted 

to the Program Analyst. Additionally, the SAA will be required to provide validation that funds have 

been obligated and subawarded within the 45 day period. FEMA requests that this recommendation 

be resolved and open pending implementation of the stated corrective action. 

Again, we thank you for the opportunity to review and comment on your draft report which contains 

recommendations aimed at improving the efficiency of our agency, Should you have any further 

questions regarding our response, please do not hesitate to call FE:MA's Acting Chief Audit Liaison, 

Gina Norton, at 202-646-4287. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Homeland Security Grant Program Background 

The Homeland Security Grant Program encompasses several interrelated Federal grant 

programs that together fund a range of preparedness activities including planning, 

organization, equipment purchase, training, and exercises, as well as management and 

administrative costs. Depending on the fiscal year, the program included some or all of 

the following programs: 

•	 State Homeland Security Program supports the implementation of State Homeland 

Security Strategies to address the identified planning, organization, equipment, 

training, and exercise needs to prevent, protect against, respond to, and recover 

from acts of terrorism and other catastrophic events. 

•	 Urban Areas Security Initiative Program funds address the unique planning, 

organization, equipment, training, and exercise needs of high-threat, high-density 

Urban Areas, and assists them in building an enhanced and sustainable capacity to 

prevent, protect against, respond to, and recover from acts of terrorism. 

•	 Law Enforcement Terrorism Prevention Program provides resources to law 

enforcement and public safety communities (working with their private partners) to 

support critical terrorism prevention activities, including: establishing / enhancing 

fusion centers and collaborating with non-law enforcement partners, other 

government agencies, and the private sector. 

•	 Citizen Corps Program mission is to bring community and government leaders 

together to coordinate the involvement of community members and organizations 

in emergency preparedness, planning, mitigation, response, and recovery. 

•	 Metropolitan Medical Response System Program funds support designated 

jurisdictions to further enhance and sustain a regionally integrated, systematic mass 

casualty incident preparedness program that enables a response during the first 

crucial hours of an incident. The program prepares jurisdictions for response to allhazards mass casualty incidents, including chemical, biological, radiological, nuclear, 

and explosives terrorism, epidemic disease outbreaks, natural disasters, and largescale hazardous material incidents. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Organization Chart 

Chicago/Cook County Urban Areas Security Initiative Grants

Illinois

Terrorism

Task Force

Illinois Emergency 

Management Agency

Office of Emergency 

Management and 

Communications 

Grant Management

Cook County 

Judicial Advisory Council

Grant Management

Chicago/Cook 

County Urban 

Area Work Group 

Mayor of Chicago Cook County Board 

President

Communication 

and Technology

Public Health Intergovernmental 

Committee

Exercise and 

Training

Regional Transportation

Catastrophic 

Planning Team 

Incident Response

Threat and 

Vulnerability

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Report Distribution 

Department of Homeland

Secretary 

Deputy Secretary 

Chief of Staff

Deputy Chief of Staff

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs

Assistant Secretary for Office of Legislative Affairs 

Acting Chief Privacy Officer 

Federal Emergency Management Agency

Administrator 

Assistant Administrator, Grant Programs Directorate 

Federal Emergency Management Agency Audit Liaison 

Grant Programs Directorate Audit Liaison 

Office of Management and Budget

Chief, Homeland Security Branch 

DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees, as appropriate 

www.oig.dhs.gov 23 OIG-13-08 
 

ADDITIONAL INFORMATION AND COPIES 

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

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

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

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

at: @dhsoig. 

OIG HOTLINE 

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

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

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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 

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