Department of Homeland Security
 

The Commonwealth of Virginia’s Management of 

State Homeland Security Program and Urban Areas 

Security Initiative Grants Awarded During Fiscal Years 

2008 Through 2010 

OIG-13-10 November 2012
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Securi ty 

Washington, DC 20528 1 www.oig.dhs.gov 

NOV 14 2012 

MEMORANDUM FOR: Elizabeth M. Harman 

Assistant Administrator 

Grant Programs Directorate 

Federal Emergency Management Agency 

FROM: Anne L. Richards ~ i~ Assistant Inspector General for Audits 

SUBJECT: The Commonwealth of Virginia's Management of State 

Homeland Security Program and Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2008 Through 

2010 

Attached for your action is our final report, The Commonwealth of Virginia's Management 

of State Homeland Security Program and Urban Areas Security Initiative Grants Awarded 

During Fiscal Years 2008 Through 2010. We incorporated the formal comments from the 

Federal Emergency Management Agency (FEMA) in the final report. 

The report contains seven recommendations aimed at improving the overall management, 

performance, and oversight of FEMA's Homeland Security Grant Program. Your office 

concurred with all seven recommendations. Based on information provided in your 

response to the draft report, we consider the recommendations resolved. Once your office 

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

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

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

disposition of any monetary amounts. 

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

of our report to appropriate congressional committees with oversight and appropriation 

responsibility over the Department of Homeland Security. We will post the report on our 

website for public dissemination. 

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

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

Attachment 
 

 

Table of Contents 

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

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

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

Commonwealth Could Not Quantify Improved Preparedness............................... 3 

Recommendation ................................................................................................... 4 

Management Comments and OIG Analysis ........................................................... 4 

Grant Management Oversight Needs Improvement.............................................. 5 

Recommendations .................................................................................................. 7 

Management Comments and OIG Analysis ............................................................ 8 

Untimely Award of Grant Funds ............................................................................. 9 

Recommendation.................................................................................................. 10 

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

Untimely Expenditure of Grant Funds .................................................................. 11 

Recommendation.................................................................................................. 12 

Management Comments and OIG Analysis .......................................................... 12 

Appendixes 

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

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

Appendix C: VDEM Management Comments to the Draft Report ................... 20 

Appendix D: Homeland Security Grant Program ............................................... 23 

Appendix E: Commonwealth of Virginia Homeland Security Governance ....... 24 

Appendix F: Commonwealth of Virginia Procurement and Financial 

Management Compliance Issues and Schedule of 

Questioned Costs .......................................................................... 26 

Appendix G: Major Contributors to This Report ............................................... 28 

Appendix H: Report Distribution ....................................................................... 29 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Abbreviations 

CFR Code of Federal Regulations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency

FY fiscal year

HSGP Homeland Security Grant Program 

OIG Office of Inspector General

SHSP State Homeland Security Program 

UASI Urban Areas Security Initiative 

VDEM Virginia Department of Emergency Management

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary

Public Law 110-53, ImplementingfRecommendationsfoffthef9/11fCommissionfActfoff

2007, requires the Department of Homeland Security (DHS), Office of Inspector General 

(OIG), to audit individual States’ management of State Homeland Security Program and 

Urban Areas Security Initiative grants. This report responds to the reporting 

requirement for the Commonwealth of Virginia. 

The objectives of the audit were to determine whether the Commonwealth of Virginia 

distributed and spent State Homeland Security Program and Urban Areas Security 

Initiative grant funds (1) effectively and efficiently and (2) in compliance with applicable 

Federal laws and regulations. We also addressed the extent to which grant funds 

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

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

included a review of $90 million in State Homeland Security Program and Urban Areas 

Security Initiative grants awarded to the Commonwealth during fiscal years 2008 

through 2010. 

In most instances, the Commonwealth of Virginia distributed and spent State Homeland 

Security Program and Urban Areas Security Initiative grant funds in compliance with 

applicable Federal laws and regulations. Additionally, the Commonwealth developed 

Homeland Security Strategies that included goals and objectives that were consistent 

with Federal requirements. However, the Commonwealth needs to (1) develop a 

comprehensive performance measurement system, (2) strengthen grant management 

oversight, and (3) award and expend grant funds in a timely manner. 

We made seven recommendations to the Federal Emergency Management Agency, 

which, if implemented, should strengthen program management, performance, and 

oversight. The Federal Emergency Management Agency concurred with our 

recommendations and is taking or planning to take steps for corrective actions. 

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Department of Homeland Security 

Background 

DHS, through the Homeland Security Grant Program (HSGP), provides Federal funding to 

help State and local agencies enhance their capabilities to prevent, deter, respond to, 

and recover from terrorist attacks, major disasters, and other emergencies. Within DHS, 

the Federal Emergency Management Agency (FEMA) administers the HSGP. Appendix C 

contains a description of the interrelated grant programs that compose the HSGP. 

The HSGP is one tool in a comprehensive set of measures that Congress authorized and 

the administration implemented to help strengthen the Nation against risks associated 

with potential terrorist attacks. The program is an important part of the administration’s

larger, coordinated effort to strengthen homeland security preparedness. The HSGP 

implements measures to fulfill the objectives of post-9/11 laws, strategy documents, 

plans, and Homeland Security Presidential Directives. 

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

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

HSGP. The Commonwealth of Virginia has designated the Virginia Department of 

Emergency Management (VDEM) as the State Administrative Agency that applies for 

grant funds and provides administrative oversight of the HSGP. VDEM administers the 

Commonwealth’s emergency services and disaster preparedness programs and 

distributes aid among its subdivisions. Appendix D contains details on the entities in the 

Commonwealth involved in HSGP coordination.

HSGP guidance also requires the development of a State Homeland Security Strategy for 

State Homeland Security Programs (SHSPs) and an Urban Areas Security Initiative (UASI) 

Homeland Security Strategy for UASI. The State and UASI strategies must include goals 

and objectives that address the four mission areas: Prevent, Protect, Respond, and 

Recover, as well as align with national priorities. In addition, the UASI strategy must be 

consistent with the State strategy. The Commonwealth of Virginia had a State Homeland 

Security Strategy, as well as UASI Homeland Security Strategies for Richmond and 

Norfolk, for fiscal years (FYs) 2008 through 2010. 

From FY 2008 through FY 2010, the Commonwealth of Virginia received $96.8 million in 

HSGP funds. This HSGP funding included $90 million in SHSP and UASI grants. 

Appendix A contains details on the objectives, scope, and methodology of this OIG audit. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Results of Audit 

In most instances, the Commonwealth of Virginia distributed and spent grant funds in 

compliance with applicable Federal laws and regulations. Additionally, the 

Commonwealth developed Homeland Security Strategies that included goals and 

objectives consistent with Federal requirements. To improve its grants management 

practices, the Commonwealth should develop a comprehensive performance 

measurement system, strengthen grant management oversight, and award and expend 

grant funds in a timely manner.

Commonwealth Could Not Quantify Improved Preparedness 

The Commonwealth of Virginia made efforts to measure improved preparedness 

by using preparedness and capability reports and other assessments. However, 

it could not demonstrate quantifiable preparedness improvements and 

accomplishments because it did not set measurable target performance levels 

that could be compared with actual achievement. Without goals and objectives 

against which it can measure progress, the Commonwealth cannot evaluate the 

effect of grant expenditures on its preparedness and response capabilities. 

Code of Federal Regulations (CFR) 44 CFR 13.40, MonitoringfandfReportingf

ProgramfPerformance,f(a)fMonitoringfbyfgrantees, requires grantees to monitor 

grant- and subgrant-supported activities to ensure that performance goals are 

being achieved. According to DepartmentfoffHomelandfSecurityfStatefandfUrbanf

AreafHomelandfSecurityfStrategyfGuidancefonfAligningfStrategiesfwithfthef

NationalfPreparednessfGoal, dated July 22, 2005, an objective sets a tangible and 

measurable target level of performance over time against which actual 

achievement can be compared, including a goal expressed as a quantitative 

standard, value, or rate. Therefore, an objective should be— 

•	 Specific, detailed, particular, and focused—help to identify what is to be 

achieved and accomplished; 

•	 Measurable—quantifiable, provide a standard for comparison, and identify a 

specific achievable result; 

•	 Achievable—not beyond a State, region, jurisdiction, or locality’s ability;

•	 Results-oriented—identify a specific outcome; and 

•	 Time-limited—have a target date for achieving the objective. 

Although the goals and objectives in the Commonwealth’s State and UASI 

strategies aligned with national priorities and met most Federal guidance 

requirements, they did not include measurable target levels of performance to 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

compare with actual achievement. Furthermore, objectives did not always have 

target dates for completion. For example, the Commonwealth’s objective to 

implement the Ready Virginia Communications Plan was not measurable or 

time-limited. Without measurable target performance levels for goals and 

objectives, the Commonwealth could not evaluate the effect of grant 

expenditures on its preparedness and emergency response capabilities. 

Recommendation 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, assist VDEM to: 

Recommendation #1:

Develop a comprehensive performance measurement system for its Homeland 

Security Strategies’ goals and objectives that includes target levels of performance 

and the means to measure progress toward enhancing preparedness. 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #1: FEMA concurred with 

recommendation 1. According to FEMA, the FY 2012 HSGP, Funding Opportunity 

Announcement, provided instruction to States on updating their homeland 

security strategies so that their goals and objectives align with Presidential Policy 

Directive 8 and the Whole Community approach. 

The National Preparedness Directorate in FEMA is developing processes to 

measure core capabilities in accordance with the National Preparedness Goal 

pursuant to Presidential Policy Directive 8, which will be completed and 

submitted to FEMA leadership by December 2012. Upon official release of the 

guidance on performance measures, the Grant Programs Directorate will require 

VDEM to update its strategy and fully comply with the additional guidance. 

VDEM’s Response to Recommendation #1: VDEM agreed with recommendation 1. 

VDEM indicated that its Homeland Security Working Group has been working on 

the recent Threat and Hazard Identification and Risk Assessment and State 

Preparedness Report requirement due to FEMA by December 31, 2012. Once 

FEMA approves these reports, the Commonwealth will be able to update the 

Homeland Security Strategy to include the OIG recommendations. 

OIG Analysis: The actions proposed by FEMA and VDEM meet the intent of 

recommendation 1. When implemented, the actions identified in the responses 

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Department of Homeland Security 

should address the conditions identified during the audit. This recommendation 

will remain resolved and open until we have reviewed the updated Homeland 

Security Strategies. 

Grant Management Oversight Needs Improvement 

VDEM needs to improve its policies and procedures so that it can better monitor 

subgrantees throughout the grant performance period. Federal regulation 

44 CFR 13.40, MonitoringfandfReportingfProgramfPerformance, requires 

grantees to oversee subgrantee activities to ensure that they comply with 

applicable Federal requirements. VDEM’s policies and procedures did not exist 

or were insufficient to provide the required oversight. For example, the highlevel guidance in VDEM grants management monitoring procedures did not 

include detailed steps for reviewing files when conducting oversight or a 

methodology for selecting subgrantees for onsite monitoring.

According to Office of Management and Budget Circular A-133, Compliancef

Supplementf2011,fPartf3-CompliancefRequirements,fM-SubrecipientfMonitoring, 

grantees are responsible for monitoring subgrantees’ use of Federal awards 

through reporting, site visits, regular contact, or other means. VDEM Grants 

Management Office administrators conducted three onsite monitoring visits 

during FYs 2008 through 2010. 

The VDEM internal auditors did not have policies or procedures for selecting 

grant programs to audit and limited their reviews to closed FY 2005 through 

FY 2007 SHSP projects. By limiting reviews to closed projects, VDEM lost the 

opportunity to identify and correct grant compliance issues before funds were 

expended and grants were closed. 

Compliance Issues 

In our review of 16 SHSP- and UASI-funded grant projects totaling $12.7 million 

awarded from FY 2008 through FY 2010, we identified instances in which 

subgrantees’ procurement procedures, as well as their financial and property 

management, did not comply with Federal, State, or local requirements.

Additionally, in one instance VDEM did not comply with Federal requirements 

for allocating grant funds. These instances of noncompliance might have been 

identified earlier through increased oversight of performance.

We identified instances of noncompliance with procurement procedures and 

financial management resulting in questioned costs of $660,657, as shown in 

table 1. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table 1. Procurement and Financial Management Issues 

Compliance Issues Questioned Costs 

Full and Open Competition $538,902 

Employee Compensation $121,328 

Reimbursement of Expenses $ 427 

Total $660,657 

Source: OIG. 

One of the questioned costs included a $104,505 radio communications 

equipment purchase made without completing the competitive bidding process 

required by the VirginiafPublicfProcurementfAct.

1 We also determined that a 

Commonwealth employee working multiple grant programs was compensated 

for $97,328 without properly accounting for hours worked on each grant, as 

mandated by the CFR.2

 Appendix E contains additional information on the 

procurement and financial management compliance issues identified in table 1 

and the potential monetary benefits. 

Subgrantees did not always maintain and control equipment inventory as 

required in Federal regulations. According to 44 CFR 13.32, Equipment,f

(d) Managementfrequirements, among other requirements (1) property records 

must be maintained that include the property’s cost, description, identification 

number, location, use, condition, and ultimate disposition; (2) a physical 

inventory must be taken and the results reconciled with property records at least 

every 2 years; and (3) a control system must be developed to ensure adequate 

safeguards to prevent loss, damage, or theft of the property. Property records 

for 9 of the 16 subgrantee projects reviewed either did not exist or did not 

contain all information required by Federal regulations. One subgrantee could 

not demonstrate that it had conducted a physical inventory of the equipment 

purchased with Federal funds. Four of the 16 subgrantees had not possessed 

the equipment purchased for at least 2 years and therefore, were not required 

to conduct a physical equipment inventory. However, according to the CFR, the 

subgrantees should have had controls to safeguard and account for equipment; 

such controls did not exist or were inadequate. 

Further, 2 of the 16 subgrantees did not mark equipment purchased with HSGP 

funds. According to FEMA’s grant agreements, grant recipients are required, 

1 For purchases of more than $30,000, the VirginiafPublicfProcurementfAct requires written informal solicitation of a 

minimum of four bidders or offerors.
 2

 According to 2 CFR Part 225, Appendix B, Sections 8.h.(4) and 8.h.(5)(a), “Where employees work on multiple
 

activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports ...” 

“[that] must reflect an after-the-fact distribution of the actual activity of each employee.”
 

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Department of Homeland Security 

when practicable, to prominently mark any equipment purchased with grant 

funding. 

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate require VDEM to: 

Recommendation #2:

Revise its policies and procedures for monitoring subgrantees to provide 

reasonable assurance that subgrantees are complying with Federal laws and 

regulations applicable to all compliance issues, including procurement 

procedures, financial management, property records, and equipment inventory. 

Recommendation #3:

Develop and implement policies and procedures for selecting open and closed 

State Homeland Security Program and Urban Areas Security Initiative subgrantee 

projects for audits conducted by the Virginia Department of Emergency 

Management. 

Recommendation #4:

Ensure correct allocation of grant funds by implementing employee activity 

reports that reflect an after-the-fact distribution of actual employee activity for 

employees working on multiple grant programs. 

Recommendation #5: 

Complete a review of the questioned costs to determine whether (1) the sole 

source procurements were justified and the prices obtained were fair and

reasonable; and (2) the employee compensation was justified and the level of 

compensation was reasonable. Limit the allowable costs for the procurements 

and employee compensation to amounts determined to be fair and reasonable. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #2: FEMA concurred with 

recommendation 2. According to FEMA, it will require VDEM to submit a 

revision to its policies and procedures for monitoring subgrantees within 120 

days of receipt of FEMA’s management comments to this report. VDEM’s 

revision to its policies and procedures should focus on subgrantees’ compliance 

with Federal laws and regulations applicable to all compliance issues, including 

procurement procedures, financial management, property records, and 

equipment inventory. 

FEMA’s Response to Recommendation #3: FEMA concurred with 

recommendation 3. According to FEMA, it will require VDEM to develop and 

implement policies and procedures that clarify the roles and responsibilities of 

the VDEM internal auditors with respect to their evaluation or oversight of the 

SHSP and UASI. Where applicable, those policies and procedures should be 

integrated with VDEM's existing subrecipient monitoring protocols for selecting 

open and closed SHSP and UASI subgrantee projects for any audits or reviews 

conducted by VDEM. VDEM should submit to FEMA those policies and 

procedures or any revised monitoring protocols that address the issues raised in 

this recommendation within 90 days of receipt of FEMA’s management 

comments to this report. 

FEMA’s Response to Recommendation #4: FEMA concurred with 

recommendation 4. According to FEMA, it will require VDEM to submit an 

employee time distribution plan that reflects an after-the-fact distribution of 

actual employee activity for employees working on multiple grant programs 

within 180 days of receipt of FEMA’s management comments to this report. 

FEMA’s Response to Recommendation #5: FEMA concurred with 

recommendation 5. FEMA stated that it will require VDEM to (1) complete a 

review of the questioned costs to determine whether sole source procurements 

were justified and the prices obtained were fair and reasonable; (2) review 

whether the employee compensation was justified and the level of compensation

was reasonable; and (3) report on those findings within 90 days of receipt of 

FEMA’s management comments to this report. 

VDEM’s Response to Recommendations #2 through #5: VDEM agreed with 

recommendations 2 through 5. According to VDEM, its grant process was 

revised with the FY 2011 grant cycle that incorporated the grant management 

oversight recommendations in this report. VDEM indicated that its Grants Office 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

is in the process of updating and enhancing its Subgrantee Administrative Guide, 

eGMS Training Manual, and internal policies and procedures. 

OIG Analysis: The actions proposed by FEMA and VDEM meet the intent of 

recommendations 2 through 5. When implemented, the actions identified in the 

responses should address the conditions identified during the audit. These 

recommendations will remain resolved and open until we have reviewed the 

following: 

•	 Recommendation 2: VDEM’s revised policies and procedures for monitoring 

subgrantees; 

•	 Recommendation 3: VDEM’s policies and procedures that clarify the roles 

and responsibilities of the VDEM internal auditors with respect to their 

evaluation or oversight of the SHSP and UASI; 

•	 Recommendation 4: VDEM’s employee time distribution plan that reflects 

an after-the-fact distribution of actual employee activity for employees 

working on multiple grant programs; and 

•	 Recommendation 5: VDEM’s review of the questioned costs identified in the 

report and the actions taken for costs determined not to be fair and 

reasonable. 

Untimely Award of Grant Funds

The Commonwealth of Virginia did not award funds to subgrantees in the 

federally required timeframe. VDEM submitted the Commonwealth’s required 

funding allocation plan to FEMA in the required timeframe, but SHSP and UASI 

funding for FY 2008 through FY 2010 was not made available to subgrantees 

until, in one example, as many as 842 days after the required period. Delays in 

awarding funds to subgrantees could result in delays for projects intended to 

increase homeland security and achieve program objectives. 

According to FEMA’s award conditions for FY 2008 through FY 2010, HSGP grant 

recipients must submit funding allocations to FEMA within 45 days of receiving 

the grant award. If this funding allocation information is not provided to FEMA 

within 45 days, FEMA may withhold further grant funding. HSGP guidance 

requires that each State make no less than 80 percent of the total grant amount 

available to local units of government and urban areas within 45 days of receipt 

of funds. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We reviewed 81 subgrantee projects that received SHSP and UASI funds from 

FY 2008 through FY 2010. For 76 of these projects, on average, 296 days passed 

between VDEM’s acceptance of HSGP grant funding and its awarding of funds to 

the subgrantees (see table 2). For 78 of 81 projects, grant award letters were 

not sent to subgrantees within the required 45-day period. Grant funds must be 

awarded to subgrantees before they can be reimbursed for allowable 

expenditures. 

Table 2. Average Days to Award SHSP and UASI Funds 

(FY 2008 through FY 2010)

Grant 

Year 

Award of Funds

(average days)

Subgrantee

Projects 

Reviewed 

Award Amounts Percentage of SHSP and 

UASI Grant Funds 

FY 2008 296 34 $15,298,645 49%

FY 2009 405 24 $16,445,409 55%

FY 2010 193 23 $18,188,308 63%

Total 296 81 $49,932,362 55%

Source: OIG. 

VDEM officials believed that, because they submitted the required funding 

allocation plan to FEMA within 45 days, they complied with grant award 

requirements. Additionally, VDEM indicated that it would not be able to award 

grant funds to local governments and urban areas within 45 days of receiving the 

awards because they required additional time to accept the grants and prepare 

grant applications for VDEM review and approval.

Recommendation 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, require VDEM to: 

Recommendation #6: 

Assess the current processes and procedures to improve the efficiency of 

awarding Homeland Security Grant Program funds to local units of government 

and urban areas. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #6: FEMA concurred with 

recommendation 6. According to FEMA, it will require VDEM to assess the 

current processes and procedures for awarding HSGP funds to eligible recipients. 

VDEM must provide a plan that will improve the efficiency of awarding HSGP 

funds to eligible recipients within 90 days of receipt of FEMA’s management 

comments to this report. 

OIG Analysis: The actions proposed by FEMA meet the intent of 

recommendation 6. This recommendation will remain resolved and open until 

we have reviewed VDEM’s assessment and plan for improving the efficiency of 

awarding HSGP funds to eligible recipients. 

Untimely Expenditure of Grant Funds 

Because subgrantees did not always expend grant funds in a timely manner, not 

all SHSP and UASI funds were expended within the grant performance period. As 

a result, first responders may not have been fully equipped, trained, and prepared. 

According to FEMAfInformationfBulletinfNo.f257, dated July 17, 2007, 

subgrantees face various obstacles in completing projects, but it is important to 

ensure that funds are obligated and expended in a timely manner and within 

established periods of performance. HSGP guidance states that the 36-month 

period of performance begins on the project or budget period start date that is 

included in the award package. Additionally, any unobligated funds are to be 

deobligated at the end of the closeout period, unless FEMA approves an 

extension of the performance period. 

According to the Commonwealth of Virginia’s financial records, as of April 2012, 

83 percent of FY 2008, 63 percent of FY 2009, and 24 percent of FY 2010 SHSP and

UASI grant funds awarded to subgrantees were expended, as shown in table 3. 

Table 3. Commonwealth of Virginia SHSP and UASI Grant Expenditures as of 

April 2012 (FY 2008 through FY 2010) 

Grant 

Year 

Date of 

Award 

End of 

Grant 

Period 

Total 

Awarded 

Total Expended Balance Percentage

Expended

as of April 

2012 

FY 2008 8/22/08 8/31/11 $31,281,500 $25,957,042 $5,324,458 83% 

FY 2009 8/21/09 7/31/12 $30,090,150 $19,030,857 $11,059,293 63% 

FY 2010 9/27/10 7/31/13 $28,728,273 $7,022,996 $21,705,277 24% 

Source: OIG. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

VDEM requested and FEMA approved three performance period extensions for 

the FY 2008 HSGP. In addition, the FY 2009 performance period was extended 

once. Currently, the FY 2008 performance period will end on February 28, 2013, 

and the FY 2009 performance period will end on December 31, 2012. 

According to VDEM, there may have been several reasons why grant funds were 

not spent in a timely manner. Delays may be a result of the need to fulfill 

Federal environmental and historic preservation requirements, the time needed 

to procure equipment, and the need for subgrantee coordination. 

Delays in expending grant funds may continue to impede the Commonwealth’s 

and subgrantees’ ability to improve preparedness and response capabilities. In 

addition, extensions in the grant performance period and delays in officially 

closing the grant could result in FEMA deobligating grant funds.

Recommendation 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, require VDEM to: 

Recommendation #7: 

Assess the current process and identify ways to improve subgrantees’ 

performance in meeting established grant performance timelines. 

Management Comments and OIG Analysis 

FEMA’s Response to Recommendation #7: FEMA concurred with 

recommendation 7. FEMA stated that it will require VDEM to assess the current 

processes and procedures to identify ways to improve subgrantees’ performance 

in meeting established grant performance deadlines. VDEM must provide a plan 

that will improve subgrantees’ performance in meeting those deadlines within 

180 days of receipt of FEMA’s management comments to this report. 

VDEM’s Response to Recommendations #6 and 7: VDEM explained that it has 

utilized the Initial Strategy Implementation Plan submission to FEMA, ensuring 

that the obligation was made to local governments within the 45-day period. 

According to VDEM, this has been the only documented way to adhere to the 

Environmental Historic Preservation requirements, review budgets in advance, 

and allow the local governments to accept the funds into their locality. There is 

an unrealistic expectation that local governments would be able to receive an 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

award from VDEM releasing the funds for expenditure within 45 days and still 

adhere to the Federal and State requirements for spending Federal funds. VDEM 

has recently implemented an electronic grants management system that will 

speed up this process and have the funds into the local governments’ hands 

more quickly by issuing formal allocation letters to the local governments. 

However, the formal award will not be released until all grants have been made. 

OIG Analysis: The actions proposed by FEMA meet the intent of 

recommendation 6 and 7. These recommendations will remain resolved and 

open until we have reviewed VDEM’s assessment and plans for improving the 

efficiency of awarding HSGP funds to eligible recipients and for improving 

subgrantees’ performance in meeting established grant performance deadlines. 

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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 objectives of the audit were to determine whether the Commonwealth of Virginia’s 

management distributed and spent SHSP and UASI grant funds (1) effectively and 

efficiently and (2) in compliance with applicable Federal laws and regulations and DHS 

guidelines. We were to also address the extent to which grant funds enhanced the 

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

disasters, acts of terrorism, and other manmade disasters. 

The scope of this audit included the Commonwealth’s plans to improve preparedness 

and response to all types of hazards, goals and objectives set in those plans, 

measurement of progress toward the goals, and assessments of performance 

improvement resulting from this measurement. 

Together, the HSGP and its interrelated grant programs fund a range of preparedness

activities, including planning, organization, equipment purchase, training, exercises, and 

management and administration costs. However, only SHSP and UASI funding, 

equipment, and supported programs were reviewed for compliance.

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

and FY 2010, as shown in table 4. 

Table 4. Commonwealth of Virginia HSGP Awards (FY 2008 through FY 2010) 

Grant Programs FY 2008 FY 2009 FY 2010 Total

State Homeland Security Program $21,800,000 $20,048,000 $18,680,612 $60,528,612

Urban Areas Security Initiative Program $9,481,500 $10,042,150 $10,047,661 $29,571,311

Total $31,281,500 $30,090,150 $28,728,273 $90,099,923

Citizen Corps Program $331,501 $329,655 $282,223 $943,379

Metropolitan Medical Response System 

Program $1,927,326 $1,927,326 $1,904,514 $5,759,166

Operation Stonegarden N/A N/A N/A N/A

Grand Total $33,540,327 $32,347,131 $30,915,010 $96,802,468 

Source: OIG. 

www.oig.dhs.gov 14 OIG-13-10 
 

 

 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The audit methodology included work at FEMA headquarters, Commonwealth of 

Virginia offices, Richmond and Norfolk urban areas that received grants, and various 

subgrantee locations. To achieve our audit objective, we analyzed data, reviewed 

documentation, and interviewed key Commonwealth and local officials directly involved 

in the management and administration of the Commonwealth of Virginia’s HSGP. 

We sampled project files from State agencies, designated UASI areas, and local 

government subgrantees that received SHSP or UASI grants awarded in FY 2008, 

FY 2009, or FY 2010, as shown in table 5. 

Table 5. Subgrantee Sample Selection (FY 2008 through FY 2010)

Subgrantees Grant Amount Project Description 

1. Loudoun County, 2008 SHSP $1,481,960 Bomb Squad Equipment and Training 

2. Fauquier County, 2009 SHSP $882,130 P25 Software Upgrade Project 

3. Stafford County, 2010 SHSP $970,600 Regional Radio Communication 

Interoperability 

4. Henrico County, 2008 SHSP $1,266,100 Bomb Squad Equipment and Training 

5. Henrico County, 2009 SHSP $1,730,000 Richmond Area Microwave Interoperability 

System

6. Nottoway County, 2008 SHSP $1,300,000 Regional Interoperable Communication 

7. Colonial Heights City, 2008 UASI $5,256 Chemical, Biological, Radiological, Nuclear, 

and Explosives Equipment

8. Richmond City, 2008 SHSP $1,176,300 Bomb Squad Equipment and Training 

9. Louisa County, 2010 SHSP $1,249,666 Central Virginia Regional Information 

Sharing Project 

10. Hopewell City, 2008 UASI $10,000 Chemical, Biological, Radiological, Nuclear, 

and Explosives Equipment

11. New Kent County, 2008 UASI $12,307 Mass Casualty Incident Trailer 

12. Brunswick County, 2008 SHSP $985,531 Regional Information Network Sharing 

13. York County, 2009 UASI $75,223 Emergency Power Generator

14. Virginia Department of Social 

Services, 2008 SHSP $945,000 Shelter Retrofitting 

15. Hampton Roads Planning District 

Commission, 2009 UASI $488,655 Pet Evacuation and Management Resources

16. Hampton Roads Transit, 2008 UASI $150,000 Regional Security for Mass Transit 

Total of Subgrantee Awards $12,728,728

17. Virginia Department of Emergency 

Management, 2008–2010 $2,189,471 Management and Administration 

Grand Total of Awards Selected $14,918,199

Source: OIG.

www.oig.dhs.gov 15 OIG-13-10 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

At each location, we interviewed officials responsible for project oversight, reviewed 

documentation supporting Commonwealth and subgrantee management of grant 

funds, and physically inspected selected equipment procured with grant funds. 

FY 2011 grants were not included in the scope of this audit because DHS did not allocate 

those funds to grant recipients until August 24, 2011. Grant recipients would not have 

had sufficient time to expend these funds prior to our fieldwork. 

We conducted this performance audit between February and August 2012 pursuant to 

the InspectorfGeneralfActfoff1978, as amended, and according to generally accepted 

government auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our

findings and conclusions based upon our audit objectives. We believe that the evidence 

obtained provides a reasonable basis for our findings and conclusions based upon our 

audit objectives. 

www.oig.dhs.gov 16 OIG-13-10 
 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

Appendix B

FEMA Management Comments to the Draft Report 

U.S. D~plr1n1~nl or lIomd.nd 5«uril)' 

Washington. DC ~12 

OCT 2 3 2012 

MEMORANDUM FOR: Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General 

FROM: David J. Kaufman ~~ ~ Director 

Office of Policy and Program Analysis 

SUBJECT: Response to DIG Draft Report. The Commonwealth of Virginia's 

M(lIJagemenr of State Nomeland Security Program and Urbm1 Areas 

Security Initiatil'e Grants Awarded During Fiscal Years 2008 through 

1010 (12-101-AUD-FEMA) 

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

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

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

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

Recommendation #1: We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate, assist the Virginia Department of Emergency Management (VDEM) to develop a 

comprehensive performance measurement system for its Homeland Security Strategies' goals and 

objectives that includes target levels of performancc and the means to measure progress toward 

enhancing preparedness. 

fEMA Responsl.': FEMA concurs with the recommendation. The FY12 Homeland Security Grant 

Program (HSGP) Funding Opportunity Announcement (FOA) provided instruction to states on 

updating their homeland security strategies so thai their goals and objectives align to Presidential 

Policy Directive 8 (PPD-8) and the Whole Community approach. 

The FOA states that State and Urban Area Homelalld Security Strategies should be updated every 

IWO (2) years at a minimum to ensure that their strategies cOlI/inlie to address all homeland security 

mission areas (prevem, protec/ against, respond 10, recO\~er [rom, and mitigate all hazards) and 

reflect hall' their goah and objectives align to PPD-8 and tlte Whole Community approach. When 

rel'isiting and upc/ating the strategies, goals. and objectives, Stales (md Urban Areas are strongly 

encouraged 10 consider collaboration across disciplines, j urisdictions. and agencies within the 

framework of the mission areas and based on a capability-based planning approach. 

www.oig.dhs.gov 17 OIG-13-10 
 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

The NationaJ Preparedness Directomte (NPO) in FEMA is responsible tor strategy oversight and 

guidance development. NPD is currently developing processes to measure core capabilities in 

accordance with the National Preparedness Goal pursuant to PPD-8 which will be completed and 

suhmiued to FEMA leadership hy Decembe r 2012. Upon offici al release urthe guidance on 

performance measures, GPD will require the VDEM to update their strategy and fully comply with 

the additional guidance. FEMA requests that the recommendation be considered resolved and open 

pending completion of the stated corrective actions. 

Recommendation #2: \Vc recommend that the FEMA Assistant Administrator. Grant Programs 

Directorate require VDEM to revise Its policies and procedures for monitoring subgrantees to 

provide reasonable assurance that subgrantees are compl ying with Federal laws and regulations 

applicable to all compliance issues. including procurement procedures, financial management. 

property records, and equipment invcntory. 

FE\tA Response: FEMA concurs with this recommendation. FEMA will require VDEM to submit 

a revision to its policies and procedures for monitoring subgrantees within 120 days of receipt of this 

letter. The revision should focus on subgrantees' compliance with Federal laws and regulations 

applicable to all compliance issues. including procurement procedures, financial management, 

properLy records, and equipment inventory. FEMA believes this satisfies the intent of the 

recommendation and requests that this recommendation be considered resolved and open pending 

completion of the stated corrective actions. 

Recommendation #3: \Ve recommend that the FEMA Assistant Administrator, Grant Programs 

lJirectoraie require VlJEM to develop and implement policies and procedures for selecting open and 

closed State Homeland Security Program and Urban Areas Security Initiative subgrantee projects for 

audits conducted by the VDEM. 

FEMA Response: FEMA concurs with this recommendation. FEMA will require VDEM to 

develop and implement policies and procedures that clarify tlIe JOles and responsibilities of the 

VDEM internal auditors with respect to their e"aluation or oversight of the State Homeland Security 

Program and Urban Area Security Initiative. Where applicable, those policies and procedures 

should be integrated with VDEM's existing subrecipient monitoring protocols fur seleding open ami 

closed State I Iomeland Security Program and Urban Area Security Initiative subgrantcc projects for 

any audits or reviews conducted by VDEM. VDEM should submit to FEMA those policies and 

procedures or any revised moniloring protocols that address the issues raised in Recommendation #3 

within 90 days of receipt of this letter. FEMA believes this satisfies the intent of the 

recommendation and requests that this recommendation be considered resolved and open pending . 

completion of the stated correcti ve actions. 

Recommendation #4: \Vc recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate require VDEM to ensure correct allocation of grant funds by implementing employee 

activity reports that reflect an after the fact distribution of actual employee activity for employees 

working on multiple grant programs. 

FEMA Response: FEMA concurs with the recommendation. FEMA will require VDEM to submit 

an employee time distribution plan that reflects an after-the-fact distribution of actual employee 

activity for employees working on multiple grant programs within I ~u days of receipt of this letter. 

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

www.oig.dhs.gov 18 OIG-13-10 
recommendation be considered resolved and open pending completion of the siated corrective 

actions. 

Recommendation #5: We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate require VDEM to complete a review of the questioned costs to determine whether (I) the 

sole source procurements were justified and the prices obtained were fair and reasonable; and (2) the 

employee compensation was j ustified and the level of compensation was reasonable. Lim it the 

allowable costs for thc procurements and employee compensation to amounts determined to be fair 

and reasonabl e. 

FEMA Response: FEMA concurs with this recommendati on. FEMA will require VDEM to 

complete a review ofthe questioned costs to determine whether sole source procurements were 

j ustified and the prices obtained were fair and reasonable. VDEM should also review whether the 

employee compensation was j usti ried and the level of compensation was reasonahle. VDF.M must 

report on those findings within 90 days of receipt of this letter. FEMA believes this will satisfy the 

intent of the recommendation and requests that this recommendation be considered resolved and 

open pending completion of the stated corrective actions. 

Recommendation #6: We recommcnd that the FEMA Assistant Administrator, Grant Programs 

Directorate require VDEM to assess the current processes and procedures to improve the efficiency 

of awanling Homeland Security Grant Prtlgrarn rumls to Im;al un iL ... or govemment and urban areas. 

FK\IA Response: FEMA concurs with this recommendation. FEMA will require VDEM to assess 

the current processes and procedures for awarding HSGP funds to eligible rel:ipienls. VDF.M must 

provide a plan that will improve the efficiency of awarding llSGP funds to eligible recipients within 

90 days of receipt of this letter. FEMA believes this satisfies the intent of the recommendation and 

requests that this recommendation be considered resolved and open pending completion of the stated 

corrective actions. 

Recommcnd3tion #7: We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate require VDEM to assess the currellt process and identify ways to improve subgrantees' 

performancc in meeting cstablishcd grant performance timclincs 

FE:\IA Response: FEMA C(lOl:Urs with this r~co mm~ndation. FF.MA wil l require VDF.M to assess 

the current process and identify ways to improve subgrantees' performance in meeting established 

grant perfonnance timelines. VDEM must provide a plan that improves subgrantees' perfonnance in 

meeting those timelines within 180 days of receipt of this letter. FEMA believes this satisfies the 

intent of the recommendation and requests that this recommendation be considered resolved and 

open pending completion of the stated corrective actions. 

Again, we thank you for the oppmtunity to provide commel11s concerning tllis repOlt. Please contact 

Audit Liaison Gina Norton at 202-646-4287, regarding further questions or concerns. 

 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

www.oig.dhs.gov 19 OIG-13-10 
 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

Appendix C

VDEM Management Comments to the Draft Report 

COMMON WEALTH ofVIRGINLj MICHAEL M. CUNE Department of Emergency Managemel1l 10501 Trade Court Stale Coordlnalor Richmond. Virginia 23236-3713 

(804) 897-6500 JACK E. KING (TOO) 674·2417 Chief Deputy CoordInalOt FAX (804)897-6506 

October 10, 2012 BRETT A BURDICK 

Deputy Coordinator 

Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General 

Department of Homeland Security 

Washington, DC 20472 

Dear Ms. Richards: 

I appreciate the opportunity to present our views on the draft audit report for the 

Commonwealth of Virginia's management of the Department of Homeland Security, Federal 

Emergency Management Agency (FEMA), State Homeland Security Program and Urban Area 

Security Initiative awaroed during Fiscal Years 2008 - 2010. 

I would like to begin by thanking the Office of Inspector General (OIG) for the diligence in 

conducting this audit. Also, to express gratitude 10 you and your staff for the recommendations made 

in the draft report. The Commonwealth agrees that some of these recommendations are valid, and we 

have taken steps towards implementing these with recent grant funding. 

Respecting the OIG's considerable work and comnUbnent to effective government programs, 

the Commonwea1th nonetheless maintains that the State Homeland Security Program and Urban Area 

Security Initiative are successful programs. These programs have assisted first responders throughout 

the Commonwealth to better prevent, protect, respond, and recover from acts of terrorism. 

In addition, Virginia Department of Emergency Management (VOEM) believes that the dralI 

report contains areas that are in need of a response. While these comments were not requested, I feel 

that this is pertinent and should be included with our response to your report. 

"Working to Protect People. Property and Our Communities" 

www.oig.dhs.gov 20 OIG-13-10 
 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

 

Ann L. Richards 

Page 2 

October 10,2012 

• C()mmoll~ahh Could Not Quomifjl Improved I'reJHl,edne.fS 

DIG Recommendation III Develop a comprehensive performance measurement system for its 

Homeland Security Strategies' goals and objectives that include target levels ofperfonnancc and 

the means to measure progress toward enhancing preparedness. 

VDEM Response The Commonwealth agrees with this recommendation. The Homeland 

Security Working Group has been working on the recent Threat and Hazard Identification and 

Risk Assessment (TIiIRA) and Slate Preparedness Report (SPR) requirement due to FEMA on or 

before December 31, 20 12. Once these repons are approved by FEMA, the Commonwealth will 

be able to effectively update the Homeland Security Stralegy to include the DIG 

reconunendations. 

• Grollt Manogemellt Oversight Needs improlltmellt 

DIG Recommendation /I 2 Revise its policies and procedures for monitoring sUbgrantces. 

OIG Rewrnmendation /I 3 Develop and implement policies and procedures for sele<:ting open 

and closed subgrantce projects for audits. 

DIG Recommendation /I 4 Ensure correct allocation of grant funds by implementing employee 

activity reports. 

DIG Recommendation /I 5 - Complete a review of the questioned costs to detennine whether the 

costs were justified. 

VOEM Response - VDEM agrees with these four TeCOlllInendations. The grant process was 

revised with the FY 20 II grant cycle thai incorporated these recommendations. In addition, 

VDEM Grants Office is in the process of updating and enhancing the Subgran\e(: Administrative 

Guide, eGMS Training Manual, and internal policies and procedures. 

• UntimelyAWlm/ojGrolltFUllds 

DIG Recommendation 116 & 7 - Assess the current processes and procedures to improve the 

efficiency of awarding Homeland Security Grant Program fimds to local goverrunent and urban 

areas. Assess the current process and identify ways to improve subgrantces' performance in 

meeting established grant performance. 

www.oig.dhs.gov 21 OIG-13-10 
 

 

OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Ann L Richards 

Page 3 

Oclober 10,2012 

VPEM Response - Historically the Common~th has utilized the Initial Stra1egy 

Implementation Plan (1SIP) submission to FEMA ensuring the obligation was made 10 local 

governments within the 45-day period. This has been the onlydocumented way to adhere 10 the 

Environmental Historic Preservation (EHP) requirements, review budgetS in advance, and 10 

allow the local governments to aa.:ept the funds into their locality. There is an unrealistic 

expectation thai kx:al governments would be able to receive an award from VOEM releasing the 

funds for expenditw"e within 45 days and still adhere 10 the federal and state requirements for 

spending federal funds. 

VOEM has recently implemented an electronic grants management system that will speed up this 

process and have the funds inlO the kx:al government's hands more quickly by issuing formal 

allocation letters to the local governments. However, the fonnal award will not be released until 

all grants (both federal and state) have been made. 

In conclusion, the VOEM Grants Management Office has developed and implemented 

policies and procedures for the Homeland Security Grant Program, as well as other federal grMt 

programs managed by VOEM. We would like 10 thank the OIG for their time and effort in assisting us 

in guidance and direction as we move forward with implementing best practices for the SUIx:esS of 

these programs. If you have any questions, please contact Cheryl Adkins. grants director, at 

(804) 897-6597 or cherYI,adkinslQlvdcm,yjfljljnjagov. 

/lJ~

Sincerely, 

Michael M. 

~Ce:. Cline 

MMC/cja 

c; Hooorable Terrie Suit. Secretary of Veterans Affairs & Homeland Secwity 

Honorable Marta Decker, Secretary of Public Safety 

Jack King, VDEM ChiefOeputy Coordinator 

Brett Burdick, VDEM Deputy CoonIinator of Administration 

Cheryl Adkins, VOEM Grants Director 

www.oig.dhs.gov 22 OIG-13-10 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Homeland Security Grant Program 

The 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. 

The 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.

The Metropolitan Medical Response System Program supports the integration of 

emergency management, health, and medical systems into a coordinated response to 

mass casualty incidents caused by any hazard. Successful Metropolitan Medical 

Response System Program grantees reduce the consequences of a mass casualty 

incident during the initial period of a response by having augmented existing local 

operational response systems before an incident occurs.

The Citizen Corps Program brings community and government leaders together to 

coordinate the involvement of community members and organizations in emergency 

preparedness, planning, mitigation, response, and recovery.

Operation Stonegarden funds are intended to enhance cooperation and coordination 

among local, tribal, territorial, State, and Federal law enforcement agencies in a joint 

mission to secure the United States borders along routes of ingress from international 

borders to include travel corridors in States bordering Mexico and Canada, as well as 

States and territories with international water borders. This program was not included 

in the FY 2008 and FY 2009 Homeland Security Grant Program. 

www.oig.dhs.gov 23 OIG-13-10 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Commonwealth of Virginia Homeland Security Governance 

Source: Virginia Department of Emergency Management.

The Secretary of Veterans Affairs and Homeland Security coordinates all agencies 

involved in the Commonwealth’s homeland security efforts (including prevention, 

vulnerability reduction, response, and recovery).
 

The Virginia Department of Emergency Management coordinates the Commonwealth’s 

emergency preparedness, mitigation, response, and recovery activities.

The Secure Commonwealth Panel is an advisory board within the executive branch of 

the Commonwealth of Virginia’s government, reporting directly to the Secretary of 

Veterans Affairs and Homeland Security. The 34-member panel monitors and assesses 

implementation of Statewide deterrence, prevention, response, and recovery initiatives; 

and reviews, evaluates, and makes recommendations pertaining to the security and 

emergency preparedness of government at all levels in the Commonwealth. 

The Homeland Security Working Group is an operations team of State agencies that

meets regularly to assess the Commonwealth’s preparedness and capabilities. These 

partners coordinate, develop, and implement policies for funding and operations 

relating to preparedness for all types of hazards. 

www.oig.dhs.gov 24 OIG-13-10 
 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Regional Stakeholder Groups meet regularly and focus on regional initiatives in training, 

equipment, communication, and strategy to ensure access to response teams during 

emergencies and to facilitate testing, training, and exercises for mass casualty 

preparedness. 

The Virginia Military Advisory Council’s mission extends to the military commanders

stationed in the Commonwealth. The commanders work together to encourage regular 

communication on continued military facility viability; explore privatization 

opportunities; and resolve issues affecting preparedness, public safety, and security. 

The State Interoperability Executive Committee is the steering group for the 

Commonwealth Interoperability Coordinator and makes recommendations for the 

distribution of Federal grants funds to localities for voice and data communication 

projects. The State Interoperability Executive Committee consists of 13 representatives 

from regional, local, and State public safety associations and government. 

www.oig.dhs.gov 25 OIG-13-10 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Commonwealth of Virginia Procurement and Financial 

Management Compliance Issues and Schedule of Questioned 

Costs 

• ProcurementsfWithoutfFullfandfOpenfCompetitionf

A SHSP subgrantee purchased radio communications equipment for $104,505 

without full and open competition. The subgrantee acquired one quote before 

purchasing the equipment. For purchases over $30,000, the VirginiafPublicf

ProcurementfActfrequires a written informal solicitation of a minimum of four 

bidders or offerors. 

A UASI subgrantee purchased a Mass Casualty Incident trailer for $12,157. The 

subgrantee’s purchase of the trailer did not comply with the county’s 

procurement policy, which requires a general requisition form to be completed 

and three telephone quotes to be obtained if the expected total cost of goods is 

between $2,000 and $20,000. 

A subgrantee purchased seven pet supply trailers for $422,240 using UASI grant 

funding. The subgrantee made the purchase without obtaining four quotes from 

vendors prior to submitting the purchase order, as required by the Virginiaf

PublicfProcurementfAct. Furthermore, the subgrantee did not follow its own 

procurement procedures requiring three different price quotations.

• QuestionedfEmployeefCompensationff

A Commonwealth employee was compensated $97,328 while working on 

multiple grant programs without properly accounting for hours worked on each 

grant. In addition, the organization used a predetermined percentage of hours 

worked to calculate payroll other than for the sole purpose of HSGP. According 

to 2 CFR Part 225, Appendix B, Sections 8.h.(4) and 8.h.(5)(a), “Where employees 

work on multiple activities or cost objectives, a distribution of their salaries or 

wages will be supported by personnel activity reports...” “[that] must reflect an 

after-the-fact distribution of the actual activity of each employee.” 

A county employee administering an SHSP grant was compensated $24,000. The 

employee did not establish a reasonable amount of compensation for 

reimbursement or track time spent administering the grant, per Federal 

requirements. According to 2 CFR Part 225, Appendix B, SelectedfItemsfoffCost:ff

www.oig.dhs.gov 26 OIG-13-10 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Compensationfforfpersonalfservices, employees working solely on a single 

Federal award must support their compensation request with a supervisory 

certification at least twice a year and demonstrate reasonable compensation 

comparable to the pay of similar government activities. 

• ReimbursementfoffExpensesf

A SHSP subgrantee received a total of $427 in funds from a VDEM overpayment. 

We identified this financial discrepancy during our reconciliation of financial 

documentation. Subsequently, the subgrantee reimbursed the Commonwealth 

$427. 

Table 6 presents the total schedule of questioned costs. 

Table 6. Schedule of Questioned Costs

Potential Monetary Benefits 

Finding Rec. No. Questioned Costs 

Full and Open Competition 5 $538,902 

Employee Compensation 5 $121,328

Total $660,230 

Source: OIG. 

www.oig.dhs.gov 27 OIG-13-10 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G 

Major Contributors to This Report 

Donald Bumgardner, Director 

Robert Greene, Audit Manager 

Irene Aultman, Auditor-in-Charge 

Carolyn Floyd, Auditor 

Michael Brunelle, Program Analyst 

Melissa Estrella, Program Analyst 

Kelly Herberger, Communications Analyst

Marisa Coccaro, Independent Referencer 

www.oig.dhs.gov 28 OIG-13-10 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix H 

Report Distribution 

Department of Homeland Security

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs

Assistant Secretary for Office of Legislative Affairs 

Acting Chief Privacy Officer 

Federal Emergency Management Agency

Administrator 

Assistant Administrator, 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 29 OIG-13-10 
 

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

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

at: @dhsoig. 

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

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