Department of Homeland Security
 

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Nebraska's Management of State 


Homeland Security Grant Program Awards for 


Fiscal Years 2009 Through 2011 


OIG-13-109 August 2013
 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

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

AUG 19 2013 

MEMORANDUM FOR: Brian E. Kamoie 

Assistant Administrator 

Grant Programs Directorate 

Federal Emergency Management Agency

FROM: rds 

ector General for Audits 

Anne L. Richa

Assistant Insp

SUBJECT: Nebraska’sfManagementfoffStatefHomelandfSecurityf

GrantfProgramfAwardsfforfFiscalfYearsf2009fThroughf2011ff

Attached for your information is our final report, Nebraska’sfManagementfoffStatef

HomelandfSecurityfGrantfProgramfAwardsfforfFiscalfYearsf2009fThroughf2011.ffWe 

incorporated the formal comments from the Federal Emergency Management Agency 

and the State of Nebraska in the final report. 

The report contains seven recommendations aimed at improving the State of 

Nebraska’s management of State Homeland Security Program grants. Your office 

concurred with six recommendations. Based on information provided in your response 

to the draft report, we consider recommendations #1, #2, #4 through #7 open and 

resolved, and recommendation #3 closed. Once your office has fully implemented the 

open recommendations, please submit a formal closeout request to us within 30 days so 

that we may close the recommendations. The request should be accompanied by 

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

monetary amounts. 

Please email a signed PDF copy of all responses and closeout requests to 

OIGAuditsFollowup@oig.dhs.gov. 

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. 
 

 

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

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

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

Homeland Security Strategy Objectives ................................................................. 3 

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

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

Performance Measurement.................................................................................... 6 

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

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

State Homeland Security Program Allocation Process........................................... 8 

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

Management Comments and OIG Analysis .......................................................... 10 

Timely Obligation of Funds ................................................................................... 10 

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

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

Property Management and Inventory Controls .................................................. 13 

Recommendation.................................................................................................. 14 

Management Comments and OIG Analysis .......................................................... 15 

Compliance with Procurement Requirements ..................................................... 15 

Recommendation ................................................................................................. 17 

Management Comments and OIG Analysis .......................................................... 17 

Monitoring Subgrantee Activities......................................................................... 18 

Recommendation.................................................................................................. 20 

Management Comments and OIG Analysis .......................................................... 20 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Table of Contents 

www.oig.dhs.gov OIG-13-109
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendixes 

Appendix A: Objectives, Scope, and Methodology .......................................... 21 

Appendix B: FEMA Management Comments to the Draft Report .................... 24 

Appendix C: NEMA Management Comments to the Draft Report ................... 30 

Appendix D: Examples of Strategic Goals and Objectives................................. 33 

Appendix E: Homeland Security Grant Program............................................... 34 

Appendix F: Threat and Hazard Identification and Risk Assessment ...... ......... 35 

Appendix G: Major Contributors to This Report ............................................... 37 

Appendix H: Report Distribution ....................................................................... 38 

Abbreviations

CFR Code of Federal Regulations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency

FY fiscal year

GPD Grant Programs Directorate 

HSGP Homeland Security Grant Program 

LEOP Local Emergency Operation Plan 

NEMA Nebraska Emergency Management Agency

OIG Office of Inspector General

OMB Office of Management and Budget 

SAA State Administrative Agency

SHSP State Homeland Security Program 

SPR State Preparedness Report 

THIRA Threat and Hazard Identification and Risk Assessments

UASI Urban Areas Security Initiative 

www.oig.dhs.gov OIG-13-109
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary

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

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

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

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

requirement for the State of Nebraska. 

The audit objectives were to determine whether the State of Nebraska (1) spent grant 

funds effectively and efficiently, and (2) complied with applicable Federal laws and 

regulations and DHS guidelines governing the use of such funding. We also addressed 

the extent to which grant funds enhanced the State’s grantees ability to prevent, 

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

other manmade disasters. The Federal Emergency Management Agency (FEMA) 

awarded the State of Nebraska approximately $19.3 million in State Homeland Security 

Program and Urban Areas Security Initiative grants during fiscal years 2009 through

2011. 

The State of Nebraska developed written procedures for program administration;

ensured that grant expenditures for equipment and planning, training, exercises, and 

administrative activities were allowable; complied with grant reporting requirements; 

and the State’s and Omaha Urban Area’s Homeland Security strategies linked goals and 

objectives to national priorities and DHS mission areas in compliance with applicable

Federal guidance.

However, the State and the Omaha Urban Area can improve their homeland security 

strategies by including specific and time-limited objectives and the means to determine 

progress toward attaining their goals. The State can also improve its grant allocation 

formula, the timeliness of fund obligations, property management and inventory 

controls, compliance with procurement requirements, and the monitoring of its 

subgrantees. 

In addition, FEMA needs to provide its grantees with a method for determining the 

extent to which grant funds enhanced the State’s ability to prevent, prepare for, protect 

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

disasters. 

We made seven recommendations to FEMA, which, if implemented, should strengthen 

program management, performance, and oversight. 

www.oig.dhs.gov 1 OIG-13-109
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background 

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

assist State and local agencies in preventing, preparing for, protecting against, and 

responding to acts of terrorism. The State Homeland Security Program (SHSP) and 

Urban Areas Security Initiative (UASI) grants are two programs included in the HSGP, 

designed to fund a wide range of preparedness needs, including planning, organization, 

equipment, training, and exercises. 

FEMA awarded the State of Nebraska (State) SHSP grant funds during fiscal years (FYs) 

2009, 2010, and 2011, and the State’s Omaha Urban Area UASI grant funds in 2010, 

totaling approximately $19.3 million. The State of Nebraska has 93 counties divided into 

eight regions, with 10 hazardous materials teams that provide all-hazards response to 

manmade and natural disasters across the State. 

The Governor of Nebraska designated the Nebraska Emergency Management Agency 

(NEMA) as the State Administrative Agency (SAA) responsible for administering the 

HSGP. The SAA is responsible for managing the grant program in accordance with 

established Federal guidelines and allocating funds to local, regional, and other 

Nebraska government entities. 

Figure 1 illustrates the level of SHSP funding Nebraska received over a 5-year period. 

SHSP and UASI funding averaged $6.4 million per year during FYs 2009 to 2011, the 

periods covered by our audit. The State received its highest level of SHSP and UASI 

funding in FY 2010, but faces a nearly $4.8 million decline from 2010 levels in FY 2012. 

Figure 1. SHSP and UASI Funding Levels, FYs 2008 to 2012 

$6,170,000 $6,524,500 $6,613,200 

$5,137,205 

$2,801,316 

$0.0 $0.0 

$1,013,087 

$0.0 $0.0 

2008 2009 2010 2011 2012

Nebraska SHSP and UASI Funding 

SHSP

UASI

fSource: Prepared by DHS OIG. 

www.oig.dhs.gov 2 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Public Law 110-53, ImplementingfRecommendationsfoffthef9/11fCommissionfActfoff

2007, as amended, requires DHS OIG to audit individual States’ management of SHSP 

and UASI grants. This report responds to the reporting requirements for the State of 

Nebraska. Appendix A describes the objectives, scope, and methodology of this OIG 

audit. 

Results of Audit 

The State of Nebraska developed written procedures for program administration;

ensured that grant expenditures for equipment and planning, training, exercises, and 

administrative activities were allowable per the grant guidance; and complied with grant 

reporting requirements. Also, the State’s and Omaha Urban Area’s Homeland Security 

strategies linked goals and objectives to national priorities and DHS mission areas in 

compliance with applicable Federal guidance. 

However, the following improvements will enhance Nebraska’s grant management 

practices: 

• Improve strategy objectives; 

• Measure progress and improvements in preparedness; 

• Revise the State Homeland Security Program allocation formula; 

• Obligate grant funds timely; 

• Enforce property management and inventory controls; 

• Document compliance with procurement procedures; and 

• Strengthen monitoring of subgrantee activities. 

Homeland Security Strategy Objectives

The State and Omaha Urban Area linked their Homeland Security Strategy goals 

and objectives to the national priorities and DHS mission areas, as required by 

FEMA guidance. However, the objectives were not always specific, measurable,

and time-limited; objectives to track progress were not always included; and the 

strategies’ evaluation plans were not being implemented. As a result, neither 

the State nor the Omaha Urban Area was able to demonstrate quantifiable 

improvement and accomplishments to reduce their vulnerability to terrorism 

and natural disasters. 

In July 2005, FEMA released guidance to the States and Urban Areas on how to 

align their Homeland Security Strategies with the National Preparedness Goal. 

www.oig.dhs.gov 3 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

ThefDepartmentfoffHomelandfSecurityfStatefandfUrbanfAreafHomelandfSecurityf

Strategy:fGuidancefonfAligningfStrategiesfwithfthefNationalfPreparednessfGoal

(Guidance) requires States to include goals and measurable objectives in their 

strategies, and mandates that an objective should be— 

 

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

be achieved and accomplished; 

•	 Measurable—quantifiable, providing a standard for comparison, and 

identifying a specific achievable result; 

•	 Achievable—the objective is not beyond a State, region, jurisdiction, or 

locality’s ability; 

•	 Results-oriented—identifies a specific outcome; and 

•	 Time-limited—a target date exists to identify when the objective will be 

achieved.

We reviewed the 50 objectives in the FYs 2009–2011 State Strategies and the 49 

objectives in the FY 2010 Omaha Urban Area Strategy. Of the 50 State 

objectives, 56 percent were not specific, 48 percent were not measurable, 18 

percent were not results-oriented, and 90 percent were not time-limited. Of the 

49 Omaha Urban Area objectives, 10 percent were not specific, 29 percent were 

not measurable, 12 percent were not results-oriented, and 90 percent were not 

time-limited. 

Forty-three of the 50 State objectives had “ongoing 2012” or “ongoing August 

2014” as the target date for completing the objectives. These dates represented 

the end dates of the grants and not the target date for achieving the objectives. 

Similarly, the Omaha Urban Area Strategy contained target dates for 5 out of 49 

objectives, and provided no time limits for the other 44 objectives. Examples of 

these goals and objectives are provided in appendix D. 

According to NEMA officials, the Strategies contain objectives that are not 

specific enough to be completed during the grant period. These activities will 

continue past the grant period; therefore, no specific date can be provided. 

Objectives are made nonspecific to accommodate constant changes in priorities 

and direction provided by FEMA. 

FEMA’s Guidance indicates that Strategic goals should have at least one objective

or performance measure to track progress for achieving the goal. In the FYs

2009–2011 State Strategies, 5 of the 11 goals do not include objectives to track 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

progress toward achieving the goal and 6 of the 15 goals in the Omaha Urban 

Area Strategy do not have these objectives. 

FEMA Guidance also requires that States and urban areas develop evaluation 

plans for monitoring progress, compiling key management information, tracking 

trends, and keeping the strategy on track. The State and Omaha Urban Area 

strategies included plans to evaluate progress on stated objectives; however, 

both NEMA and Omaha Urban Area officials confirmed that the plans have not 

been implemented.

The State believed its strategies were in compliance with all requirements 

because they had been approved by FEMA without comment. The FY 2010 

Omaha Urban Area Strategy was also approved by FEMA without comment. 

Without objectives that are specific, measurable, results-oriented, and timelimited, or that contain methods for evaluating progress toward completion of 

goals and objectives, it is difficult for the State and Omaha Urban Area to

measure and report on improvements in preparedness and for FEMA to make 

informed funding decisions.

Recommendation 

We recommend that the Assistant Administrator, Grants Programs Directorate:

Recommendation #1:

Assist the Nebraska Emergency Management Agency in preparing future 

strategies with: 

•	 Objectives that are specific, measurable, results-oriented, and timelimited; 

•	 Goals that contain at least one objective to track progress toward 

achievement of the goal; and 

•	 Implementation of the evaluation plans for monitoring progress, 

compiling key management information, tracking trends, and keeping the 

strategy on track.

www.oig.dhs.gov 5	 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendations 1 and 2: FEMA and the 

State concurred with these recommendations. FEMA provided a consolidated 

response to recommendations 1 and 2. FEMA developed and is implementing a 

process to measure progress. The new process includes a Threat and Hazard 

Identification and Risk Assessment (THIRA) and State Preparedness Reports 

(SPR). The THIRA and the SPR results highlight gaps in capability and the 

progress of grantees in closing those gaps over time. 

FEMA stated that strategy updates to establish SMART goals and objectives are 

encouraged but not required as the new THIRA, SPR, and Investment 

Justification methodology provide the goals and assessment of progress against 

those goals. The THIRA also provides capability targets that serve as specific 

metrics and the SPR tool provides standards measurement against the targets. 

Lastly the THIRA, SPR, and Investment Justifications will serve as the basis for 

statewide assessment and reporting. FEMA believes the intent of the 

recommendations has been satisfied with their actions and requested that the 

recommendations be closed. 

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

recommendation 1. This recommendation is open and resolved pending 

evaluation of the State’s first THIRA and SPR results. 

Performance Measurement 

NEMA and UASI officials could not demonstrate the extent to which FYs 2009–

2011 SHSP and UASI grant funds enhanced the State’s ability to prevent, prepare 

for, protect against, and respond to natural disasters, acts of terrorism, and 

other manmade disasters. The State and UASI could not demonstrate 

quantifiable preparedness improvements and accomplishments, because FEMA 

had not provided them with a system with measurable target performance levels 

that could be compared to actual achievement. Without standards and metrics 

against which to measure progress, the State and the UASI cannot demonstrate 

the effect of grant expenditures on its level of preparedness. 

Congressional legislation called for FEMA to establish a comprehensive system to 

assess the Nation’s prevention capabilities and overall preparedness and use 

clear and quantifiable metrics, measures, and outcomes. FEMA has made efforts 

to establish standards and metrics for measuring preparedness, but at the time 

of our review a comprehensive measurement system had not been 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

implemented. As a result, Nebraska’s SAA and UASI officials were uncertain how 

to measure their performance or level of preparedness. 

The GovernmentfPerformancefandfResultsfActfoff1993 holds agencies 

accountable for setting goals, measuring program performance against the goals, 

and reporting publicly on their progress. The Post-KatrinafEmergencyf

ManagementfReformfActfoff2006 called on the FEMA Administrator to establish 

a comprehensive system to assess the Nation’s prevention capabilities and 

overall preparedness. Because FEMA did not establish such a system, the

RedundancyfEliminationfandfEnhancedfPerformancefforfPreparednessfGrantsfActf

off2010 required FEMA to contract with the National Academy of Public 

Administration (the Academy) to develop quantifiable performance measures 

and metrics to assess the effectiveness of grant programs. 

In October 2011, the Academy issued its report, ImprovingfthefNationalf

PreparednessfSystem:ffDevelopingfMorefMeaningfulfGrantfPerformancef

Measures. The Academy recommended certain measures, but acknowledged 

that FEMA needed to develop additional quantitative and qualitative program 

and activity level measures. In FEMA’s undated, unsigned report to the 

Academy’s study, ThefReportfonfthefGrantsfProgramfMeasurementfStudy, the 

FEMA Administrator said “a variety of implementation issues would need to be 

addressed before FEMA can implement many of the recommended measures.” 

The Administrator also said that FEMA was reviewing the recommendations and 

developing an implementation timeline for some of the recommendations. 

In April 2012, FEMA required State and local governments receiving FEMA 

preparedness grants to complete Threat and Hazard Identification and Risk 

Assessments (THIRAs) by December 31, 2012. The THIRA provides a 

comprehensive approach for identifying and assessing risks and associated 

impacts, using the core capabilities identified in the National Preparedness Goal. 

In addition to the THIRA, States and territories receiving FEMA preparedness 

grants are required to annually submit a State Preparedness Report (SPR). FEMA 

officials state that THIRA results and the SPR will provide a quantitative summary 

of preparedness. However, we did not review the THIRA process because it was 

not within the scope of our review. Appendix F presents more information 

about the THIRA. 

Until FEMA provides grantees with a system for measuring performance and 

preparedness, it will be difficult to determine the extent to which SHSP and UASI 

grant funds have enhanced the ability of States, cities, and the Nation to 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

prevent, prepare for, protect against, and respond to manmade and natural 

disasters. 

Recommendation

We recommend that the Assistant Administrator, Grant Program Directorate:

Recommendation #2:

Develop and provide States and urban areas with a comprehensive 

measurement system that includes baselines for measuring and demonstrating 

progress toward enhancing their level of preparedness through the use of State 

Homeland Security Program and Urban Areas Security Initiative grants funds. 

Management Comments and OIG Analysis 

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

concurred with this recommendation. FEMA provided a consolidated response 

for recommendations 1 and 2 (see above). 

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

recommendation 2. This recommendation is open and resolved pending 

evaluation of the State’s first THIRA and SPR results. 

State Homeland Security Program Allocation Process 

NEMA’s allocation formula for SHSP funds includes population and land mass, 

but it does not consider other factors that may significantly contribute to the risk 

of terrorism, such as critical infrastructure and population density. As a result, 

grant funds may not be distributed where the risk of terrorism is greatest. 

When the SHSP grants were created, Congress called on the FEMA Administrator 

to consider States’ and cities’ relative threat, vulnerability, and consequence of 

its population, population density, as well as degree of threat, vulnerability, and 

consequences to critical infrastructure or key resources when allocating funding. 

According to FEMA’s grant guidance, in order to be eligible the activities 

implemented under SHSP must support terrorism preparedness by building or 

enhancing capabilities that relate to the prevention of, protection from, 

response to, and recovery from terrorism. SHSP funds were allocated to States 

and urban areas based on a risk assessment that considered the potential risk of 

terrorism to people, critical infrastructure, and economic security. 

www.oig.dhs.gov 8 OIG-13-109
 
 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

According to NEMA officials, the State initially had planned to distribute SHSP 

funds based solely on population, but it was decided that such an allocation 

ignored risks to the State’s agricultural industry. The State then added land mass 

to address the agricultural risk. 

The NEMA formula treated population and land mass equally. This allocation of 

available SHSP grant funds resulted in the Omaha Urban Area, which contains 

more than 300 critical infrastructures or key assets, receiving a similar amount of

grant funds as the North Central region, as shown in table 1. 1

Table 1. Allocation of SHSP Grant Funds in FY 2011 

Omaha Urban Area North Central Region 

Population - 683,421 (38% of 

State) 

Population - 59,542 (3% of 

State) 

Land Mass (Square Miles) – 981 

(1% of State) 

Land Mass (Square Miles) – 24,623 

(32% of State) 

Grant Funds -

19.65%

Grant Funds -

17.57%

Source:f Prepared by DHS OIG. 

It is important that Nebraska considers including in its allocation formula 

additional factors contributing to the risk of terrorism, such as critical 

infrastructure and population density, to ensure SHSP grant funds are distributed 

to areas where the potential risk of terrorism to people, critical infrastructure, 

and economic security is the greatest. The Omaha Urban Area may not qualify 

for future UASI funds; therefore, it is important that the State reassess its SHSP 

allocation process to ensure adequate consideration is given to areas with the 

highest risk of terrorism. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate:

Recommendation #3:

Direct the Nebraska Emergency Management Agency to consider the benefits of 

including additional contributors of terrorism risk, such as population density 

and critical infrastructure, in its State Homeland Security Program allocation 

1

 The State has not identified non-Omaha Urban Area critical infrastructures. 

www.oig.dhs.gov 9 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

formula to ensure grant funds are distributed where the risk of terrorism is 

greatest.

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendation 3: Although FEMA did not 

concur with this recommendation, we consider the State’s action responsive to 

the intent of the recommendation. FEMA officials stated that for them to 

require States to use risk assessment factors that were never designed to be 

used at the State or local level would be contrary to both the letter and the spirit 

of the Homeland Security Act and would undermine Congress’ expressed intent 

that States play a significant and primary role in assessing their own risk and 

security needs. 

OIG Analysis: The intent of our recommendation is to ensure the State has the 

best possible allocation plan that mitigates the highest risk of terrorism. We 

agree that the use of factors in 6 U.S.C. § 608 is not required of the State; we 

recommended they consider the benefits of including additional contributors of 

terrorism risk as a way to improve their allocation methodology. FEMA relies on 

the State to make the most informed decision for funds allocation. The State’s 

response to our report indicated that it understands the basis for considering 

additional factors contributing to the risk of terrorism in their allocation formula 

and will include a totality of such factors; therefore, we consider this 

recommendation closed. 

Timely Obligation of Funds 

NEMA did not obligate grant funds on a timely basis. For FYs 2009–2011, the 

State did not obligate 80 percent of funds awarded under the SHSP and UASI 

grant programs to local units of government within 45 days of receipt of funds, 

as required by FEMA’s grant guidance. The guidance states that four 

requirements must be met to obligate grant funds: 

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

the awarding entity; 

•	 The action must be unconditional on the part of the awarding entity (i.e., 

no contingencies for availability of NEMA funds); 

•	 There must be documentary evidence of the commitment; and 

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

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

NEMA did not meet the grant requirements because of its lengthy obligation and 

approval process. First, NEMA sends award letters to each of the eight regional 

subgrantees, who have 30 days to sign and return the award letter to NEMA. 

Once notified, the eight regional subgrantees have up to 6 months to submit 

work plans to NEMA on prioritized projects that will be funded by the grant. Each 

work plan can contain up to 12 projects. NEMA’s Grant Administrator reviews 

and approves the subgrantee’s work plan to ensure the following: 

•	 Project needs are documented; 

•	 Project benefits the region; 

•	 Work plan includes the estimated cost of the investment and deliverable

milestones; 

•	 Desired equipment is listed in FEMA Authorized Equipment List; 

•	 Projects are aligned with National and State Priorities and with 

Investment Justification Plan; and 

•	 Environmental assessments have been completed if necessary, which 

entails a lengthy review prior to approval of the project. 

Once the work plans are approved, NEMA enters the projects into the Nebraska 

Grant Management System and the regional subgrantees allocate the funds to 

each project based on planned expenditures. Once NEMA approves the projects’

planned expenditures, it sends a Grant Adjustment Notice to regional 

subgrantees for signature to finalize the grant agreement. 

Although the regions were notified of their award amount based on an allocation 

formula, reimbursements could not be requested until the Grant Adjustment 

Notices were signed and returned by the subgrantees. Special Condition #4 of 

the HSGP Sub-Recipient Agreement, reads Sub-recipientfagreesftofmakefnof

requestfforfreimbursementfpriorftofthefreturnfoffthefGrantfAdjustmentfNotice.

In FYs 2009 and 2010, Grant Adjustment Notices for selected subgrantees were 

executed (signed by both parties) approximately halfway through their grant 

performance periods. The performance period for FY 2009 was 1,064 days; the 

performance period for FY 2010 was 1,034 days. From the time FEMA granted 

the awards, it took an average of 594 days in FY 2009 and 434 days in FY 2010 to 

process the Grant Adjustment Notices. As a result, the subgrantees’ 

performance period was limited to 53 percent of the total award period. In FY 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

2009, this may have contributed to the deobligation of unspent SHSP grant funds 

of about $55,000 when the FEMA grant agreement expired. 

In FY 2011, NEMA shortened the performance period for awards, which further 

limited subgrantees’ performance period. With the exception of the National 

Council of Regions and the Tri-County subgrantees, NEMA shortened the grant 

performance period of selected subgrantees by 6 months compared to previous 

years, so that it now ends on January 31, 2014. As a result of the shortened time 

period, subgrantees may not be able to use grant funds to meet their approved 

needs, and more funds may have to be deobligated when the FY 2011 FEMA 

grant agreement expires. As of September 30, 2012, FY 2011 Grant Adjustment 

Notices had not been processed for two of our selected subgrantees, and two 

other subgrantees had not yet requested reimbursement. In summary, four 

subgrantees’ performance periods had been reduced by 43 percent, with 488 

days remaining until the award expiration date of January 31, 2014. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate:

Recommendation #4: 

Require the Nebraska Emergency Management Agency to review and update its 

obligation and approval process to identify ways to shorten the process so 

subgrantees have sufficient time to procure and spend their grant funds. 

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendation 4: FEMA and the State 

concurred with this recommendation. The Assistant Administrator, Grant 

Programs Directorate (GPD) shall require NEMA to assess and streamline (where 

possible) processes and procedures for obligating funds to subgrantees. NEMA 

shall report to GPD the results of the assessment and steps to be taken to 

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

issuance of this OIG final report and shall update written policy to reflect the 

changes within 180 days of the issuance of this OIG final report. 

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

recommendation 4. This recommendation is resolved and open until GDP 

provides evidence that NEMA completed these actions.

www.oig.dhs.gov 12 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Property Management and Inventory Controls
 

The State subgrantees did not comply with grant inventory and property record 

requirements for the equipment we reviewed. Property records for equipment 

bought with FYs 2009–2011 SHSP and UASI grants did not contain all required 

elements and physical inventories of property were not taken every 2 years as 

required by the Code of Federal Regulations (CFR). 

44 CFR 13.32(d), Managementfrequirements, and the NEMAfGrantfManagementf

Handbook (Handbook) established procedures for managing equipment acquired 

with grant funds, and include the following requirements for subgrantees: 

•	 Property records must be maintained and include the property’s 

description, identification number, source of the property, titleholder, 

acquisition date, cost, location, use and condition, and ultimate 

disposition; and 

•	 A physical inventory of the property must be taken and the results 

reconciled with the property records at least every 2 years. 

We reviewed seven property records for our selected SHSP equipment 

expenditures. None of these records included all the information required by 

Federal regulations. The records did not contain columns for all required data, 

many columns were empty, and some of the locations provided were vague. 

Additionally, only one region official reported that he conducted physical 

inventories of equipment annually, but no evidence was provided. Three other 

selected subgrantees reported that they did not conduct periodic physical 

inventories. 

These conditions existed because NEMA control processes did not ensure the 

subgrantees maintained up-to-date records that conformed to Federal 

requirements and did not ensure the subgrantees conducted physical 

inventories of equipment purchased with FYs 2009–2011 SHSP and FY 2010 UASI 

funds. For example: 

•	 The only process to verify inventory and review property records for 

equipment purchased with SHSP grant funds was NEMA’s monitoring of 

subgrantees. However, at the time of our review, NEMA had only 

monitored one FY 2009 subgrantee. For this subgrantee, NEMA’s 

monitoring process did not ensure that property records included all the

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

federally required elements. No other monitoring reviews of subgrantees 

for FYs 2009–2011 SHSP funds had been performed during our review.

•	 NEMA’s Handbook included an Equipment Inventory template, but this 

template was used in only two of the seven property records we 

reviewed. Additionally, NEMA’s template did not provide for use and 

condition, titleholder, and ultimate disposition data elements required by 

the CFR.

•	 The Handbook also required the documentation of acceptance of 

equipment purchased with HSGP funds to ensure accountability, and that 

entities receiving the equipment are eligible and agree to respond in 

support of their corresponding regions. Equipment acceptance 

documentation must be signed by the regional subgrantee and the entity 

receiving the equipment. Of 34 expenditures of equipment items we 

tested, only 2 had signed documents certifying that equipment was 

received. However, only the regional subgrantee representative signed 

the document and not the equipment recipient, as required. We asked a 

NEMA official whether NEMA verified evidence of equipment receipt 

prior to reimbursing the subgrantees for equipment purchases. The 

official said that subgrantees are required to submit an invoice for 

equipment purchased, but currently no separate equipment receipt 

document was required.

Without adherence to inventory and property management requirements, the

State cannot ensure assets procured with grant funds are properly safeguarded, 

in good condition, and available when needed to prevent, prepare for, protect 

against, and respond to all-hazards incidents. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate:

Recommendation #5: 

Require the Nebraska Emergency Management Agency to: 

•	 Develop and implement controls to require and ensure its subgrantees 

maintain up-to-date property records that include all data required by 

Federal regulations and conduct physical inventories of equipment 

pursuant to Federal regulations; 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

•	 Revise its GrantfManagementfHandbook Equipment Inventory template

to include all required data elements; and 

•	 Require documentation of equipment receipt to ensure proper 

accountability of equipment bought with State Homeland Security 

Program and Urban Areas Security Initiative grant funds. 

Management Comments and OIG Analysis 

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

concurred with this recommendation. Within 180 days after the issuance of this 

OIG final report, the Assistant Administrator, Grants Programs Directorate will 

require NEMA to update its policies and procedures to reflect the requirements 

of 44 CFR. §13.32 concerning how property records and equipment purchases 

are managed, including the use of NEMA’s updated Grants Management and 

Equipment Inventory Standard Operating Procedure templates to log in these 

records. 

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

recommendation 5. This recommendation is resolved and open until GDP 

provides evidence that NEMA completed these actions. 

Compliance with Procurement Requirements 

State subgrantees did not always comply with Federal procurement 

requirements. Procurement records did not show evidence that the subgrantees 

allowed vendor competition or documentation explaining why only one vendor 

was considered, and did not show cost or price analyses. This occurred because

NEMA’s control processes did not verify that selected subgrantees’ expenditures 

complied with Federal procurement requirements. As a result, NEMA cannot 

ensure that the amounts paid are justified, fair, and reasonable, or whether the 

contract could have been awarded to an equally competent contractor at a 

lesser cost. 

44 CFR 13.36(b), Procurementfstandards, requires that subgrantees’ 

procurement procedures conform to applicable Federal requirements, which 

include— 

•	 All procurement transactions will be conducted in a manner providing full 

and open competition. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

•	 Subgrantees must perform a cost or price analysis in connection with 

every procurement action. 

•	 Subgrantees are required to maintain records detailing the method of 

procurement, contractor selection or rejection, and the basis for the 

contract price. 

Of 35 subgrantees’ procurements tested, 21 (60 percent) did not comply with 

Federal requirements. Eight procurements had no evidence that the 

subgrantees allowed vendor competition or documentation explaining why only 

one vendor was considered and had no cost or price analyses. An additional 

seven procurements had documentation justifying why only one vendor was 

considered, but no cost analyses were conducted to support that costs were 

reasonable. Also, a subgrantee did not use competition for two procurements 

because they did not exceed the dollar threshold established in local 

procurement procedures requiring competitive quotes. For the remaining four 

procurements, documentation was insufficient to determine that the purchases 

corresponded to the contracts provided by the subgrantees; therefore, we could 

not determine if adequate procurement practices were used. 

Examples of the issues noted for the 21 procurements are—

•	 A $75,639 contract for the development of a continuity of operations and 

debris development plan for counties within a region. According to 

NEMA, it had a contract for this type of service with the same vendor, 

and notified regions that they could use the contracts at the local level 

with the expectation that the subgrantees would follow the local 

procurement procedures. However, no sole source justification or cost

analysis was documented for this procurement. 

•	 There was no evidence that a subgrantee allowed vendor competition for 

two procurements of portable generators and lighting units costing 

$15,405 and $3,586, respectively. The subgrantee said that each 

procurement had two vendor quotes, but the documentation was not 

maintained. 

•	 A subgrantee did not use competitive procedures for a printer costing 

$10,038. A NEMA official recognized the subgrantee did not obtain “an 

adequate number of quotes” and said that, going forward, they will be 

requiring subgrantees to attach all quotes to the Grant Management 

System regardless of the applicable county’s procurement policies. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

NEMA’s only process to review subgrantees’ compliance with procurement 

practices is its monitoring of subgrantees. At the time of our review, NEMA had 

completed monitoring of only one subgrantee for the FYs 2009–2011 SHSP 

grants. A NEMA official said that NEMA will not perform any more monitoring of 

FY 2009 SHSP grants and had not yet started to monitor FYs 2010–2011

subgrantees. 

Additionally, NEMA’s monitoring processes included review of compliance with 

State and local procurement practices, but not with Federal procurement 

practices. For selected subgrantees, local procurement practices included less 

stringent requirements than the Federal procurement requirements. 

Without ensuring vendor competition, sole source justifications, and cost or 

price analyses, NEMA does not have assurance that amounts paid are justified, 

fair, and reasonable, or whether the contract could have been awarded to an 

equally competent contractor at a lesser cost. 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate:

Recommendation #6: 

Require the Nebraska Emergency Management Agency to develop and 

implement controls to ensure that all subgrantee procurements are conducted 

using competitive procedures or are supported by written sole source 

justifications and cost analyses in accordance with Federal procurement 

regulations.

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendation 6: FEMA and the State 

concurred with this recommendation. Within 180 days after the issuance of this 

OIG final report, the Assistant Administrator, Grants Programs Directorate will 

require NEMA to develop and provide an updated procurement policy that 

complies with 44 CFR. §13.36 for subgrantees and local jurisdictions to follow. 

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

recommendation 6. This recommendation is resolved and open until GDP 

provides evidence that NEMA completed these actions.

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Monitoring Subgrantee Activities 

NEMA’s monitoring efforts did not ensure subgrantees complied with Federal 

requirements and achieved program performance goals for the FYs 2009–2011 

SHSP and FY 2010 UASI grants. NEMA’s monitoring processes did not ensure 

performance goals were being achieved, and NEMA officials stated that they did 

not have sufficient staff to conduct the required onsite monitoring visits. As a 

result, the State cannot ensure subgrantees are administering FYs 2009–2011 

SHSP and UASI grants funds in compliance with applicable Federal requirements 

and are achieving performance goals. 

The CFR, Office of Management and Budget (OMB), FEMA, and NEMA have 

specific guidance on grantee monitoring requirements: 

•	 44 CFR §13.40, MonitoringfandfReportingfProgramfPerformance: 

Grantees are responsible for managing the day-to-day operations of 

grant-and subgrantee-supported activities and ensuring grant recipients 

comply with applicable Federal requirements and achieve program 

performance goals. This regulation also specifies grantees’ monitoring 

programs must cover each program, function, or activity.

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

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

responsible for monitoring subgrantees’ use of Federal awards through 

reporting, site visits, regular contact, or other means. Grantee 

monitoring should provide reasonable assurance the subgrantee 

administers Federal awards in compliance with laws and regulations, as 

well as the provisions of contracts or grant agreements and that 

performance goals are achieved. 

•	 FEMA, HomelandfSecurityfGrantfProgramfGuidancefandfApplicationfKit: 

Grant recipients are responsible for monitoring award activities, including 

subawards, to provide reasonable assurance that the Federal award is 

administered in compliance with requirements. 

•	 NEMA, Directive 1601, Subrecipient GrantfMonitoring: NEMA is 

responsible for monitoring the performance of projects to ensure 

adherence to performance goals and to track progress against strategies. 

Office-based and onsite monitoring is conducted using a Monitoring 

Report Form, and results documented in a Monitoring Memorandum. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

NEMA has one person conducting site visit monitoring for all SHSP, UASI, and 

Emergency Management Preparedness Grants. According to NEMA officials, 

staff shortages have prevented NEMA from conducting the desired number of 

onsite monitoring visits. As a result, NEMA did not conduct its first (and only) 

onsite monitoring of FY 2009 SHSP subgrantees until November 2012, almost 4 

months after the FY 2009 grant period expired. As of February 2013, no onsite 

monitoring of FYs 2010 or 2011 SHSP subgrantees had occurred and NEMA 

monitoring staff said that they will not conduct any more FY 2009 monitoring 

because the FY 2009 grant period had expired. 

The infrequency of onsite monitoring increased the importance of the “OfficeBased Monitoring” (desk reviews). According to NEMA’s monitoring directive, 

the majority of monitoring would occur through desk reviews. Two NEMA 

officials performed the desk reviews, one monitoring the FY 2010 grant and the 

other monitoring the FY 2011 grant. The focus was on progress in spending 

funds, and review documentation (emails) was generated only if issues with 

subgrantee actions were uncovered. 

NEMA monitoring policy requires both desk reviewers and onsite monitors to 

document their reviews and report the outcome to management. Because desk 

reviewers did not document review results or report results to management, 

there was no subgrantee monitoring record or review results to determine 

Federal compliance and achievement of performance goals. In addition, desk 

reviews provided no insight on the condition or availability of equipment. As a 

result, desk reviews were not a substitute for onsite monitoring.

Additionally, the monitor’s documentation of the one site visit provided no 

information on the subgrantee’s adherence to performance goals or progress 

against the homeland security strategy. None of the monitoring documentation 

or forms used to document the review referred to performance or progress, 

even though the monitoring directive included the requirement for NEMA to 

determine the status of both. Because the current desk monitoring process 

resulted in no documentation, NEMA had no method of determining the

progress of its subgrantees in achieving the State’s goals and objectives. 

When subgrantees are not adequately monitored, FEMA and the State cannot be 

sure that grant funds are being spent in compliance with Federal regulations, 

performance goals and objectives are being achieved, and noncompliant 

activities are being identified and corrected. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation 

We recommend that the Assistant Administrator, Grant Programs Directorate:

Recommendation #7:

Require the Nebraska Emergency Management Agency to— 

•	 Monitor grant and subgrant supported programs, functions, and activities 

for the State Homeland Security Program and Urban Areas Security 

Initiative grants to assure compliance with Federal requirements and that 

performance goals are being achieved, and 

•	 Require its monitors to document their reviews. 

Management Comments and OIG Analysis 

FEMA and the State’s Response to Recommendation 7: FEMA and the State 

concurred with this recommendation. Within 180 days of the issuance of the 

OIG final report, the Assistant Administrator, Grants Programs Directorate will 

require NEMA to establish a subgrantee monitoring program that will ensure 

compliance with all applicable State and Federal laws and regulations and grant 

program guidance. FEMA also suggested we revise the first bullet of the 

recommendation in the report to make it less broad. The State indicated that 

they implemented a schedule to complete monitoring visits for FYs 2010, 2011 

and 2012 during their period of performances and that it will ensure future 

grants are monitored at least once during the period of performance. NEMA will 

implement a process to document both on-site visits and desk monitoring of 

subgrantees and keep the documentation in the grant files. 

OIG Analysis: We consider FEMA’s and the State’s responses responsive to the 

intent of recommendation 7. We revised the first bullet of the recommendation 

to make it less broad. This recommendation is resolved and open until GDP 

provides evidence that NEMA completed these actions.

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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. 

Public Law 110-53, ImplementingfRecommendationsfoffthef9/11fCommissionfActfoff

2007, requires DHS OIG to audit individual States’ management of SHSP and UASI 

grants. This report responds to the reporting requirement for the State of Nebraska. 

The audit objectives were to determine whether the State of Nebraska (1) spent grant 

funds effectively and efficiently and (2) complied with applicable Federal laws and 

regulations and DHS guidelines governing the use of such funding. We also addressed 

the extent to which grant funds enhanced the State’s grantees 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 plans developed by the State 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. 

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, we reviewed only SHSP and UASI 

funding, equipment, and supported programs for compliance. 

The scope of the audit included the SHSP and UASI grant awards for FYs 2009, 2010, and 

2011, as shown in table 2. 

Table 2. State of Nebraska’s SHSP and UASI Awards (FYs 2009 through 2011) 

Grant Program FY 2009 FY 2010 FY 2011 Total

State Homeland Security Program $6,524,500 $6,613,200 $5,137,205 $18,274,905

Urban Areas Security Initiative 0 1,013,087 0 1,013,087

Total $6,524,500 $7,626,287 $5,137,205 $19,287,992

Source: FEMA. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The audit methodology included work at FEMA headquarters, State of Nebraska offices, 

and various subgrantee locations in the northern, central, and southern regions of the 

State that received grants. To achieve our audit objective, we analyzed data, reviewed 

documentation, and interviewed key State and local officials directly involved in State 

HSGP management and administration. 

We sampled grant award files from State agencies, regional subgrantees, and county 

hazardous materials teams that received SHSP and UASI grant allocations in FYs 2009, 

2010, or 2011, as shown in table 2 and table 3. We judgmentally selected 45 percent of 

grant expenditures from NEMA and selected subgrantees as of September 30, 2012 (as 

listed in the third column of table 3). To ensure the completeness of expenditures, we 

reconciled data in the Grant Management System to SHSP and UASI grant balances per 

the General Ledger as of September 30, 2012. 

Table 3. Subgrantee Sample Selection (FYs 2009 through 2011) 

Subgrantees Grant 

Allocation 

Expenditures as 

of 9/30/2012

Subgrantee 

Type

Board of Regents University of Nebraska $535,500 $418,267.55 State

East Central Region 652,020 300,547.35 Region 

Nebraska Council of Regions 5,423,978 * Region 

Nebraska Emergency Management Agency 2,259,985 1,486,155.59 State

Nebraska State Patrol 622,908 906,656.25 State

North Central Region 1,487,006 924,427.03 Region 

Omaha UASI/Tri County Region 2,383,862 1,392,467.74 Region 

Platte County Hazmat Team 75,000 49,736.14 

Local First 

Responder

South East Region 1,600,768 463,003.60 Region 

Total NEMA and Selected Subgrantee 

Allocations and Expenditures $ 15,041,027 $5,941,261.25

* Nebraska Council of Regions’ expenditures are included in NEMA’s expenditures.

Source: NEMA Initial Strategy Implementation Plans. 

At each location, we interviewed officials and reviewed documentation supporting State 

and subgrantee management of grant funds (see figure 2). In addition, we verified the 

existence of selected equipment subgrantees procured with grant funds. 

We conducted this performance audit between October 2012 and April 2013 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 

www.oig.dhs.gov 22 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

audit objectives.

Figure 2. Nebraska Regional Map
 

*Subgrantees selected are located within regions marked with star* 
 

Source:ffNEMAfGrantfManagementfHandbook
 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

I •• lltf1Rr1mtnl ~r llQmtiiUtd S~C\Irif)' 

\~aJh!n~l . DC :!IH12 

JUL 0 9 2013 

ME.J\10RANDUM FOR: Anne L. Richards 

AssaslUnt Jn~pc<.:tur Gcneml for Audit:. (010) 

Department of Homeland Security 

FROM. David J. Kaufman 

Associate Administrator 

QV 

for 

Policy, Program Analysis and International Affairs 

Fcdernl Emergency Management Agency (FEMA) 

SUBJECT. PEM/\ ~ Response to OIG-1 2-IOS-/\UD-FI:!MA Daa!l Report: 

·'The Stale of Nebraska's Management of Homeland Security 

GrMI Pmgrnm Awards for Fi:;cal Years2009 Lbruugh 201 I''. 

TI1ank you for the opportunity to review and comment on OIG-1 2-1 05-/\UD-FEMI\ Draft 

Report: "The Stutc o f 'c.br:tSka ·s Management n f I Iomehind Security (jrant Program Awards fl'lr 

Fiscal Years 2009 through 2011 ''. 

OIG Recommendation I: We recommend Lbat the Assistant Administrator. Grants Program$ 

l)irectorate !ISSi$t the Nebraska Emergency Management Agency in preparing future sU11tcgic9 

with: 

• Objectives that are specific. measurable. results-oriented. and time-limited: 

• Goals that contnin tttleast one objective to track progress toward ach..iewment of the goal: 

and 

• Implementation of the evaluation plans for monitoring progress, compiling key 

management infonnation. tracking. trends, and keeping the strategy on track. 

FBMA cs on~c to Rccoollno.nrlntion 1' ConL'ltr. (Se~ ctmsolidulion response for 

recommendations I & 2 below.) 

OIG Recommenda tion 2: We recommend that the Assistant Administrator, GranL~ Programs 

DirectoratL' develop and provide States and urban areas with a comprehensive measurement 

w~1cm th;n include!> baselines for megsurinJ!, and demonstrating progress tow11rd enhancing their 

level ofprepan:dncas through the usc of Slate Homeland Security Progrum and Urbtm ru cus 

Security Initiative grants funds. 

n. ww r~rna 10\ 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA Response to Recommendations 1 & 2: Concur. The OIG has recommended that 

FEMA help states, territories and urban areas establish measurable goals and objectives that will 

enable them to systematically measure improvements in first responder capabilities and 

statewide preparedness. FEMA has established and implemented a system to do exactly that, as 

described below. 

FEMA has made substantial progress in measuring the effectiveness of DHS preparedness 

grants. The National Preparedness Goal (the Goal) and the National Preparedness System serve 

as the framework for assessing grant effectiveness. FEMA's strategy for developing metrics and 

assessing grant performance begins with the Goal. The Goal defines the core capabilities 

necessary to prepare for the threats and hazards that pose the greatest risk to the security of the 

Nation, and it includes concrete, measurable objectives to manage that risk. The Goal's 

capability targets provide concrete statements of the Nation's requirements in each core 

capability. 

Measuring Grant Effediveness 

As part of the National Preparedness System, FEMA has developed and is implementing 

performance assessments that measure progress toward achieving the Goal. FEMA's strategy is 

to base assessments on the principles that the Nation needs to understand the risks it faces, use 

those risks to determine the capabilities it needs, assess its current capability levels against those 

requirements, and track its progress in closing capability gaps. 

In 2012, FEMA released a consistent methodology for determining risks in the Comprehensive 

Preparedness Guide 201: Threat and Hazard Identification and Risk Assessment (THIRA} Guide 

(CPG-201}. CPG-201 details the five-step process jurisdictions can use to generate desired 

outcomes and capability targets for each of the core capabilities. Diverging from past efforts to 

establish measures and metrics for a capability that would be applied uniformly, this approach 

allows a jurisdiction to establish its own capability targets based on the risks it faces. On 

December 31, 2012, states, territories, and major urban areas receiving Homeland Security Grant 

Program (HSGP) funds, of which the State Homeland Security Program and the Urban Area 

Security Initiative are subprograms, were required to submit their THIRAs to FEMA. 

Once each jurisdiction has determined capability targets through the TillRA process, it estimates 

its current capability levels against those targets. On December 31, 20 12, states and territories 

were required to submit State Preparedness Reports (SPRs) to FEMA that estimate current 

preparedness levels against the targets set in their THIRAs. The THIRA and SPR processes are 

scalable to allow sub-jurisdictions, sub-grantees and subject matter experts to provide input to 

the state or territory. Taken together, the THIRA results and the SPR identify capability needs 

and gaps. The THIRA and SPR results highlight gaps in capability and the progress of grantees 

in closing those gaps over time. FEMA reports the results of the capability assessments annually 

in the National Preparedness Report (NPR). 

Sustaining, Building and Delivering Capabilities 

Having estimated capability requirements, the next component of the National Preparedness 

System is to build and sustain capabilities. This step ties grant investments directly to needs and 

shortfalls. Grantees address documented capability requirements and gaps in their grant 

2 

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Department of Homeland Security 

applications. In the investment justifications (IJ) submitted in the grant application, grantees 

must specifically identify the core capability or capabilities, the priority of the core capability as 

well as the capability gaps noted in their SPR that investment intends to address. In addition, the 

grantee must identify the specific outcome(s) that the investment will yield. FEMA verifies 

completion of the investment/project through its programmatic monitoring and spending on the 

investment through the Biannual Strategy Implementation Report (BSIR), also a tool used in the 

monitoring process. Since the period of performance for the HSGP is two years, a time limit is 

set for completion of the project once it is funded. 

FEMA addressed the OIG recommendation for States to establish SMART goals and objectives 

that will enable States and Territories to systematically measure improvements in first responder 

capabilities and statewide preparedness by requiring states to use a set of tools including the 

THIRA, SPR, and Investment Justifications (IJs). Strategy updates are encouraged but not 

required as the THIRA, SPR and lJ methodology provide the goals and assessment of progress 

against those goals. 

FEMA addressed recommendation for development of performance metrics by requiring States 

and Territories to use the THIRA, which provides capability targets that serve as specific 

metrics, and the SPR tool, which provides standard measurement against the targets. 

FEMA addressed the recommendation for assessment and reporting systems by requiring States 

and Territories to use the THIRA, SPR, and Us as the basis for statewide assessment and 

reporting. The methodology and tools for THIRA and SPR are scalable and available to local 

jurisdictions and sub-grantees. 

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

recommendation be closed. 

OIG Recommendation 3: We recommend that the Assistant Administrator, Grants Programs 

Directorate direct the Nebraska Emergency Management Agency to consider the benefits of 

including additional contributors of terrorism risk. such as population density and critical 

infrastructure, in its State Homeland Security Program allocation formula to ensure grant funds 

are distributed where the risk of terrorism is greatest. 

FEMA Response to Recommendation 3: Non-concur. This recommendation is based on an 

OIG finding that Nebraska is not utilizing a variety offactors, all of which are set out in 6 U.S.C. 

§ 608, to prioritize its SHSP subawards based on risk. FEMA is statutorily required to use the 

factors set forth in 6 U.S.C. § 608 to prioritize SHSP and UASI awards based on risk. The 6 

U.S.C. § 608 factors do not apply to States or other grantees. For this reason, States are not 

required to use the 6 U.S.C. § 608 factors to prioritize SHSP or UASI subawards and it would be 

contrary to the language of the Homeland Security Act and the intent of Congress to require or 

suggest that the States do so. 

While FEMA understands the intent of this recommendation, the intent of Congress is clear in 

that the States and urban areas are best equipped to assess their own unique threats and 

vulnerabilities to potential terrorist attack. For this reason, the Homeland Security Act of 2002, 

3 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

as amended, gives States the responsibility to assess their own risk and vulnerabilities by 

developing a State homeland security plan that can be used to help the States develop effective 

funding priorities for SHSP and UASI grants. See 6 U.S.C. § 6ll(b). Congress, recognizing that 

States and local governments are more fully aware of their own security needs, intentionally 

designed the Homeland Security Act to give States and other locals primary responsibility for 

assessing their own risk. Congress is fully aware that the relative risk factors States use to 

validate risk are unique to individual States and the urban areas within each State. For FEMA to 

require States to use risk assessment factors that were never designed to be used at the State or 

local level would be contrary to both the letter and the spirit of the Homeland Security Act and 

would undermine Congress express intent that States play a significant and primary role in 

assessing their own risk and security needs. 

FEMA requests this recommendation be considered resolved and closed. 

Recommendation 4: We recommend that the Assistant Administrator, Grants Programs 

Directorate require the Nebraska Emergency Management Agency to review and update its 

obligation and approval process to identify ways to shorten the process so subgrantees have 

sufficient time to procure and spend their grant funds. 

FEMA Response to Recommendation 4: Concur. The Homeland Security Act of2002, as 

amended, and FEMA grant guidance require states receiving SHSP funds to make at least 80% 

of those funds available to local and tribal governments within 45 days of receiving those funds. 

The Assistant Administrator, Grants Programs Directorate shall require NEMA to assess and 

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

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

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

OIG fmal report. FEMA will also require NEMA to develop an updated written policy that 

describes its sub award approval and obligation processes, and that includes any identified steps 

that can be used to streamline the process of obligating funds to subgrantees, within 180 days of 

the issuance of the OIG final report. 

FEMA requests this recommendation be considered resolved and open. 

OIG Recommendation 5: We recommend that the Assistant Administrator, Grants Programs 

Directorate require the Nebraska Emergency Management Agency to: 

• Develop and implement controls to require and ensure its subgrantees maintain up-todate property records that include all data required by Federal regulations and conduct 

physical inventories of equipment pursuant to Federal regulations; 

• Revise its Grant Management Handbook Equipment Inventory template to include all 

required data elements; and 

• Require documentation of equipment receipt to ensure proper accountability of 

equipment bought with State Homeland Security Program and Urban Areas Security 

Initiative funds. 

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FEMA Response to Recommendation 5: Concur. FEMA requires SHSP and UASI grantees 

and subgrantees to comply with the equipment management requirements set forth in 44 C.F .R. § 

13.32. Within 180 days after the issuance of the OIG final report, the Assistant Administrator, 

Grants Programs Directorate will require NEMA to update its policies and procedures to reflect 

the requirements of 44 C.F.R. § 13.32 concerning how property records and equipment 

purchases are managed, including the use ofNEMA's updated Grants Management and 

Equipment Inventory Standard Operating Procedure (SOP) templates to log in these records. 

FEMA requests this recommendation be considered resolved and open. 

Recommendation 6: We recommend that the Assistant Administrator, Grants Programs 

Directorate require Nebraska Emergency Management Agency to develop and implement 

controls to ensure that all sub-grantee procurements are conducted using competitive procedures 

or are supported by written sole source justifications and cost analyses in accordance with 

Federal procurement regulations. 

FEMA Response to Recommendation 6: Concur. SHSP and UASI grantees and subgrantees 

are required to comply with the procurement procedures set forth in 44 C.F.R. § 13.36, as well as 

procurement procedures required by state and local law. Within 180 days of the issuance of the 

OIG final report, the Assistant Administrator, Grants Programs Directorate will require NEMA 

to develop and provide and updated procurement policy that complies with 44 C.P.R.§ 13.36 for 

subgrantees and local jurisdictions to follow. In the event that State law prohibits NEMA from 

requiring local jurisdictions to comply with a state authored procurement policy, NEMA will 

have to explain or justify the reasons why this is not possible. In the event that Home Rule laws 

prohibit NEMA from developing a procurement policy that applies to local governments, FEMA 

will require NEMA to require local jurisdictions, as a condition of receiving a subgrant, to 

develop their own local procurement policies that fully comply with 44 C.F.R. § 13.36. 

FEMA requests this recommendation be considered resolved and open. 

Recommendation 7: We recommend that the Assistant Administrator, Grants Programs 

Directorate require the Nebraska Emergency Management Agency to-

• Monitor each program, function, and activitY for State Homeland Security Program and 

Urban Areas Security Initiative grants; and 

• Require its monitors to document their reviews for compliance with Federal regulations 

and progress toward achieving performance goals. 

FEMA Response to Recommendation 7: Concur. FEMA concurs with the intent of 

recommendation 7, but believes that the first bullet related to program monitoring is too broad 

and will be difficult to implement Instead, FEMA recommends that the recommendation be 

changed to read: 

• Establish a monitoring program that ensures subgrantees are compliant with both State 

and Federal rules and regulations, and the intent of the grant program. 

5 

www.oig.dhs.gov 28 OIG-13-109
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Within 180 days of the issuance of the OIG final report, the Assistant Administrator, Grants 

Programs Directorate will require NEMA to establish a sub grantee monitoring program that will 

ensure compliance with all applicable State and Federal laws and regulations and grant program 

guidance. 

Thank you again for the opportunity to comment on FEMA's Response to OIG-12-105-AUDFEMA Draft Report: "The State ofNebraska's Management of Homeland Security Grant 

Program Awards for Fiscal Years 2009 through 2011 ~and for the work that you and your team 

have done to better inform us throughout this audit so that we may enhance the program's overall 

effectiveness. We look forward to your fmal report for this audit. Please direct any questions 

regarding this response to Gary McKeon, FEMA's Chief Audit Liaison, at 202-6%-1308. 

6 

www.oig.dhs.gov 29 OIG-13-109
 
O

l)$t \ ' P Heineman 

FFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

State of Nebraska Comments to the Draft Report

STATE OF NEBRASKA EMERGENCY MAl'iA GEMENT ACE'IC 

Judd II. Lyons 

Drrec1or 

2433 N.W 24°' Street 

L•ncoln. Nebraska 68524-1801 

Phone (402) 47 1-7471 

r •nverrnr 

June 12, 2013 

Anne L. Richard 

Assistant Inspector General for Audits 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Dear Ms Richards 

Please accept this letter as official response to your Draft Report: Nebraska 's Management of 

Homeland Security Grant Program Awards Fiscal Years 2009 through 2011 . We have reviewed 

the report and have no reservation in publicly releasing this d ocument upon inclusion of the 

following response to the listed recommendations: 

Recommendation #1 : 

The Nebraska Emergency Management Agency (N EMA) concurs with this 

recommendalion. 

The NEMA has initiated a process to update its' Homeland Security Strategy for FY2013 

with specific, measurable, achievable. results-oriented, and time-limited objectives with 

goals that contain at least one objective and implementation of an evaluation program for 

monitonng progress. 

Recommendation #2: 

The Nebraska Emergency Management Agency concurs with this recommendation. 

The NEMA will comply with any comprehensive measurement system that will be 

established by the Federal Emergency Management Agency. 

Recommendation #3: 

The State of Nebraska allocates its grant dollars according to risk. including economic risk. 

Nebraska's number one industry is agriculture which puts it in our high risk category for 

critical infrastructure. key resources. and economy. Critical infrastructure and key 

resources includes the livestock industry, grain and chemical storage facilities, rail lines and 

terminals. If any of these were destroyed by a terrorist attack, it would be catastrophic to 

the State's economy as well as the Nation's food supply. Nebraska will allocate grant 

dollars based on the utilization of the current FY2012 THIRA for threats and risks. 

An Equal O;JportunftyiA.'fNmiJtive Actioa EmploytK 

www.oig.dhs.gov 30 OIG-13-109
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The NEMA understands the basis for considering including additional factors contributing to 

the risk of terrorism in our allocation formula and will include a totality of factors such as 

risk, threat, consequence, infrastructure, monetary impact and also likelihood. 

Recommendation #4: 

• The Nebraska Emergency Management Agency concurs with this recommendation. 

The Nebraska Emergency Management Agency is cognizant of the language of the grant 

for the 45 day obligation period. We recognized the intent of the guidance and felt we had 

put together a program that met the mtent. The system we put into place, while the auditors 

did not think it met the 45 day obligation, was predicated on the sub-grantees willmgness to 

meet timelines as a participant within the program. Nothing within the NEMA grant 

management process precluded a sub-recipient from submitting their requests and budgets 

in a timely manner to be approved within the 45 day timeframe. There is also the question 

of what is meant by "unconditional" within the context of a sub-recipients ability to have 

access to the funds. Without a clear definition and frame of reference from DHS, it 1s 

virtually unobtainable as a goal to meet the 45 day timeframe. 

The NEMA will implement a pilot program to begin the sub-grantee application process 

prior to FEMA issuing the State's award. With the cooperation of the sub-grantees 

following program guidelines and submission of their applications, they will have their 

awards within 45 day timeframe. 

Recommendation #5: 

• The Nebraska Emergency Management Agency concurs with this recommendation. 

The NEMA will reaffirm and enforce the property management requirements for equipment 

purchased with federal funds in individual sub-grantee contracts. 

The NEMA will require and ensure its sub-grantees, (1) maintain up-to-date property 

records that include all data required and conduct physical inventories of equipment, (2) 

revise our Grant Management Handbook Inventory template to include all required data 

elements and (3) require and ensure documented equipment receipt certification. Further 

the NEMA will require non-compliant sub-grantees to provide a plan to the NEMA to 

become compliant within 30 days of the finding. 

Recommendation #6: 

• The Nebraska Emergency Management Agency concurs with the findings and 

recommendations. 

The NEMA has already instituted a requirement that all sub-grantee procurements are 

conducted using competitive procedures or are supported by written sole source 

justifications and cosUprice analyses, in accordance with Federal procurement regulations. 

The NEMA will update its Grant Management Handbook to reflect these requirements. 

Purchases are now being reviewed with a desk audit to ensure compliance and will be 

monitored on site VISits with the NEMA program inspector. 

www.oig.dhs.gov 31 OIG-13-109
 
OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation #7: 

• The Nebraska Emergency Management Agency concurred with the findings and 

recommendations. 

The NEMA has implemented a schedule to complete monitoring visits for FY2010, 2011 & 

201 2 during their period of performances. It will also ensure future grants are monitored at 

least once during the period of performance. 

NEMA staff will implement a process to document both on-site visits and desk monitoring of 

sub-grantees and keep the documentation in the grant files. 

Sincerely, 

An Equal OpeorrunitYfAffirmartve Acrt'n Employer 

www.oig.dhs.gov 32 OIG-13-109
 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

Examples of Strategic Goals and Objectives Goal 

State Goal A: Emergency 

Operations Plans will be used as 

the basis for planning, training, and 

exercise activities at the State and 

local levels. 

State Goal H: Improve 

the State’s ability, at the 

local/regional level, to 

recognize, detect, 

identify, respond to, and 

recover from an 

agricultural terrorism 

incident. 

UASI Goal 7: Enhance the capabilities of 

the Tri-County Specialized Teams to 

respond regionally to all-hazards 

incidents, including Chemical, Biological, 

Radiological, Nuclear & Explosive 

incidents or act of terrorism. These 

teams include Bomb Squad, HAZMAT 

teams, Community Emergency Response 

Teams, Incident Dispatch Teams, Medical 

Reserve Corps, Air Support Unit, Crime 

Scene Investigation Evidence Collection 

Team, SWAT, River Response Teams, and 

Public Health Emergency Response Team.

Objective 

A.2: Local jurisdictions will use 

their Local Emergency Operation 

Plans (LEOP) to formulate a 

comprehensive and progressive 

planning, training, and exercise 

program. Ongoing July 2010 

H.2: Increase the 

capability of 

local/regional officials to 

plan for agricultural and 

food events. Ongoing 

August 2012

7.1: The Tri-County Urban Area will seek 

to strengthen regional capabilities,

coordination, and cooperation beyond 

the Tri-County Urban Area geographical 

boundaries, including the development 

of a multijurisdictional prevention and 

response plan based on the Improvised 

Explosive Devices Scenario.

Implementation Steps • Establish a local LEOP review 

group.

• Conduct a LEOP orientation 2 

months before the born-on date 

for the LEOP.

• Make necessary annual updates 

and submit to NEMA.

• Annual update complete on the 

born-on date for the LEOP. 

• Complete a full revision of the 

LEOP every 5 years. 

• Maintain curriculum 

for delivery to county 

officials and 

responders. 

• Schedule delivery of 

training to 

local/regional officials 

and responders. 

• Establish relationships with jurisdictions 

outside our geographical boundaries 

and encourage shared projects among 

the parties. 

• Develop a coordinated and 

comprehensive response plan to 

support Nebraska’s Strategy for 

Homeland Security.

• Regional Exercise Design Team has 

been established. 

Deficiencies• Not specific or focused 

• Not measurable 

• Not results-oriented 

• Not time-limited 

• Not specific or focused 

• Not measurable 

• Not results-oriented 

• Not time-limited 

• Not specific or focused 

• Not measurable 

• Not time-limited 

Source: OIG analysis of Nebraska 2009 State and 2010 UASI Homeland Security Strategies.
 

www.oig.dhs.gov 33 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

Homeland Security Grant Program 

State Homeland Security Program Grant 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.

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 augmenting existing local operational 

response systems before an incident occurs.

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 U.S. 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 

2009 HSGP. 

www.oig.dhs.gov 34 OIG-13-109
 
 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

Threat and Hazard Identification and Risk Assessment 

The National Preparedness System establishes the process to define and achieve specific 

capability targets and meet the National Preparedness Goal. One of the six components 

of the National Preparedness System includes identifying and assessing risk. The Threat 

and Hazard Identification and Risk Assessment (THIRA) provides a comprehensive 

approach for identifying and assessing risks and associated effects, using the core 

capabilities identified in the National Preparedness Goal and employing the following

five-step process: 

1.	 Identify threats and hazards; 

2.	 Give threats and hazards context (assess vulnerability, how they affect the 

community);

3.	 Examine core capabilities using the threats and hazards (estimate consequences, 

impacts to the community); 

4.	 Set capability targets; and 

5.	 Apply the results (use results for planning and preparedness activities, identify 

means to deliver target level of capability).

THIRA submission is required of all 56 States and Territories receiving HSGP and 

Emergency Management Performance Grant funds and 31 eligible UASIs. The first 

THIRA submission was due December 31, 2012. Subsequent submissions will be an 

annual performance requirement for FEMA preparedness grant awards. 

In addition to the THIRA, States and Territories receiving FEMA preparedness grants are 

required to annually submit a State Preparedness Report (SPR). FEMA officials state 

that THIRA results and the SPR will provide a quantitative summary of preparedness, 

document current capabilities and potential shortfalls, and set priorities for addressing 

shortfalls. FEMA officials also state that the SPR results will be used by the States to 

identify funding requirements and set priorities for subgrantee project applications. The 

grant application (investment justification) must demonstrate how proposed projects 

address gaps and deficiencies in delivering one or more core capabilities outlined in the 

National Preparedness Goal and, as FEMA officials state, address capability gaps 

reported in the SPR. 

FEMA officials said that the FY 2013 HSGP funding announcement will require applicants 

to map proposed investments to specific core capabilities and capability gaps identified 

in the SPRs, linking investments to actions that build and sustain capabilities aligned 

www.oig.dhs.gov 35 	 OIG-13-109
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

with the National Preparedness Goal. We have not had the opportunity to audit this 

process or the outcomes for this State. 

www.oig.dhs.gov 36 OIG-13-109
 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix G 

Major Contributors to This Report 

Donald Bumgardner, Director 

Yeseira Diaz, Audit Manager 

Gloria Medina-Ortiz, Auditor 

Polin Cohanne, Program Analyst 

Jose R. Benitez-Rexach, Auditor 

Enrique Leal, Auditor 

Kevin Dolloson, Communications Analyst 

Ralleisha Dean, Referencer

www.oig.dhs.gov 37 OIG-13-109
 
 

 

 

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 38 OIG-13-109
 
 

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