Department of Homeland Security
 

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The Commonwealth of the Northern Mariana Islands’ 


Management of Homeland Security Grant Program 


Awards for Fiscal Years 2009 Through 2011
 

OIG-14-05 November 2013
 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

November 7 2013 

MEMORANDUM FOR:	 Brian E. Kamoie 

Assistant Administrator 

Grant Programs Directorate 

Federal Emergency Management Agency 

FROM:	 Anne L. Richards 

Assistant Inspector General for Audits 

SUBJECT:	 The Commonwealth of the Northern Mariana Islands’

Management of Homeland Security Grant Program Awards for 

Fiscal Years 2009 Through 2011 

Attached for your action is our final report, The Commonwealth of the Northern Mariana 

Islands’ Management of Homeland Security Grant Program Awards for Fiscal Years 2009 

Through 2011. We incorporated the formal comments from the Office of Policy, Program 

Analysis and International Affairs and the Commonwealth of the Northern Mariana Islands 

in the final report. 

The report contains nine recommendations aimed at improving the overall effectiveness of 

the Commonwealth of the Northern Mariana Islands’ management of State Homeland 

Security Program grants. Your office concurred with all of the recommendations. Based on 

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

2 through 5 closed, and recommendations 7 and 8 resolved and open. Once your office has 

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

within 30 days so that we may close the recommendation(s). The memorandum should be 

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

disposition of any monetary amounts. 

Recommendations 1, 6, and 9 remain unresolved. As prescribed by the Department of 

Homeland Security Directive 077-01, Follow-Up and Resolutions for Office of Inspector 

General Report Recommendations, within 90 days of the date of this memorandum, please 

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

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

please include responsible parties and any other supporting documentation necessary to 

inform us about the current status of the recommendation. 
 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

OIGAuditsFollowup@oig.dhs.gov. Until your response is received and evaluated, 

recommendations 1 and 6 will be considered open and unresolved.

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

of our report to appropriate congressional committees with oversight and appropriation 

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

website for public dissemination. 

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

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

Attachment 

2
 
 

 

September 23, 2013 

Ms. Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General

U.S. Department of Homeland Security 

245 Murray Drive, S.W., Building 410 

Washington, DC 20528 

Dear Ms. Richards, 

Williams, Adley & Company, LLP performed an audit of the Commonwealth of the 

Northern Mariana Islands’ (CNMI) management of the Department of Homeland 

Security’s State Homeland Security Program grants for fiscal years 2009 through 2011. 

The audit was performed in accordance with our Task Order No. TPDFIGBPA100008, 

dated September 24, 2012. This report presents the results of the audit, and includes 

recommendations to help improve the CNMI’s management of the audited State 

Homeland Security Program grants. 

Our audit was conducted in accordance with applicable Government Auditing Standards, 

2011 revision. The audit was a performance audit, as defined by Chapter 2 of the 

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

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

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

CNMI’s financial statements, or the funds claimed in the Financial Status Reports 

submitted to the Department of Homeland Security. 

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

questions or need further assistance, please contact us at (202) 371-1397. 

Sincerely, 

Charbet M. Duckett, CPA, CGFM 

Partner

WILLIAMS, ADLEY & COMPANY-DC, LLP 

Certified Public Accountants / Management Consultants 

1030 15th Street, NW, Suite 350 West • Washington, DC 20005 • (202) 371-1397 • Fax: (202) 371-9161 

www.williamsadley.com 
 

 

 

 

 

Table of Contents 

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

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

Results of Audit .................................................................................................................. 2
 

State Homeland Security Program Strategic Planning and Performance 

Measurement ................................................................................................... 3 

Recommendations ................................................................................................. 9 

Management Comments and Auditor Analysis ................................................... 10 

Financial and Progress Reporting ........................................................................ 11 

Recommendations ............................................................................................... 12 

Management Comments and Auditor Analysis ................................................... 12 

Travel Expense Documentation ........................................................................... 13 

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

Management Comments and Auditor Analysis ................................................... 14 

Appendixes 

Appendix A: Objectives, Scope, and Methodology .......................................... 15 

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

Appendix C: Description of the Homeland Security Grant Program ................ 24 

Appendix D: CNMI Homeland Security and Emergency Management 

Organization Chart ....................................................................... 25 

Appendix E: Threat and Hazard Identification and Risk Assessment ............... 26 

Appendix F: Report Distribution ...................................................................... 27 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Abbreviations 

BSIR Biannual Strategy Implementation Report 

CBRNE Chemical, Biological, Radiological, Nuclear, and Explosive 

CNMI Commonwealth of the Northern Mariana Islands 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency

FY fiscal year

HSEM Homeland Security and Emergency Management 

HSGP Homeland Security Grant Program 

OIG Office of Inspector General

SAA State Administrative Agency

SHSP State Homeland Security Program 

SPR State Preparedness Report 

SOP standard operating procedures

THIRA Threat and Hazard Identification and Risk Assessment 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Executive Summary 

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

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

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

Security Program grants. This report responds to the reporting requirement for the 

Commonwealth of the Northern Mariana Islands and its State Homeland Security 

Program grants. 

The objectives of the audit were to determine if the Commonwealth of the Northern

Mariana Islands distributed and spent State Homeland Security Program 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 of the Northern Mariana Islands’ ability to prevent, prepare for, protect 

against, and respond to natural disasters, acts of terrorism, and other man-made 

disasters. The audit included a review of approximately $4.1 million in State Homeland 

Security Program grants awarded to the Commonwealth of the Northern Mariana 

Islands during fiscal years 2009 through 2011. 

In most instances, the Commonwealth of the Northern Mariana Islands spent grant 

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

identified several areas in which the Federal Emergency Management Agency (FEMA) 

and the Commonwealth of the Northern Mariana Islands can improve its management 

of State Homeland Security Program grants. Specifically, the Commonwealth of the 

Northern Mariana Islands needs to revise its State homeland security strategy to include 

measurable objectives with realistic target dates for completion, perform periodic 

assessments of improved preparedness, and retain documentation for its vulnerability 

assessments. The Commonwealth of the Northern Mariana Islands also needs to 

maintain supporting documentation for travel expenses and to report financial and 

performance information timely.

As a result of the issues discussed in the report, the Commonwealth of the Northern 

Mariana Islands could not fully assess whether State Homeland Security Program 

funding enhanced its preparedness and security. These issues existed because FEMA 

and the Commonwealth of the Northern Mariana Islands did not provide sufficient 

guidance, written policies and procedures, and oversight of the grant process. Our nine 

recommendations call for FEMA to initiate improvements which, when implemented, 

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

the Commonwealth concurred with all of the recommendations. Written comments to 

the draft report are incorporated as appropriate and are included in appendix B. 

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Department of Homeland Security 

Background 

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

help State and local agencies enhance capabilities to prevent, protect against, respond 

to, and recover from terrorist attacks and major disasters. Within DHS, FEMA is 

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

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

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

synchronizes preparedness efforts throughout the Nation. The State Homeland Security 

Program (SHSP) grant is one element of the HSGP, designed to fund a wide range of 

preparedness activities, including planning, organization, equipment purchase, training, 

exercises, and management and administration costs. Appendix C contains a detailed 

description of the interrelated grant programs that constitute the HSGP. 

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

Administrative Agency (SAA) to apply for and administer grant funding awarded under 

the HSGP. The SAA is the only entity eligible to apply for HSGP funds. The SAA is 

responsible for managing the grant programs in accordance with established Federal 

guidelines. The Governor of the Commonwealth of the Northern Mariana Islands (CNMI) 

designated the CNMI Office of Homeland Security as the State Administrative Agency. 

The SAA has recently merged with the Office of Emergency Management and is now 

called Homeland Security and Emergency Management (HSEM). TheHSEM organization 

is depicted in Appendix D.

During fiscal years (FY) 2009, 2010, and 2011, FEMA awarded the CNMI SHSP grant 

funds totaling approximately $4.1 million. Due to the relatively small size of the 

Territory, CNMI was not required to subgrant funds to local jurisdictions.

Appendix A contains details on the audit’s objectives, scope, and methodology. 

Results of Audit 

In most instances, the CNMI spent SHSP grant funds in compliance with applicable 

Federal laws and regulations. However, we identified areas in which FEMA and 

CNMI can improve management of SHSP grant programs:

• Strategic planning, 

• Financial and progress reporting, and 

• Travel expense documentation. 

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Department of Homeland Security 

As a result, CNMI (1) could not fully assess whether SHSP funding enhanced its 

preparedness and security; and (2) may have hampered its and FEMA’s ability to 

effectively and efficiently monitor the grant expenditures. Also, we question 

travel costs amounting to $17,002. 

State Homeland Security Program Strategic Planning and Performance 

Measurement 

CNMI’s process for strategic planning contains weaknesses that minimize the 

program’s effectiveness. Specifically: 

•	 State Homeland Security Strategy is not current; 

•	 Strategic goals and objectives are not specific or measurable; 

•	 Effectiveness of the State Homeland Security Grant Program was not 

measured; and 

•	 Insufficient support for threats, risks, and vulnerabilities data was not 

retained. 

Consequently, CNMI was unable to demonstrate improvements to its approach 

to hazards of all types as funded by Federal grant funds, and did not have a basis 

for measuring improvements in its preparedness and response capabilities. 

State Homeland Security Strategy Is Not Current 

CNMI does not have a current State Homeland Security Strategy. HSEM has not 

updated the CNMI State Homeland Security Strategy since February 6, 2009. The 

strategy was developed with the assistance of a contractor and approved by the 

CNMI Homeland Security Advisor in FY 2009. The strategy contains outdated 

objectives and a Plan of Action and Milestones process that is not currently in 

use. Because the strategy was not revised, the objectives and steps in the 

strategy do not necessarily reflect the current objectives of CNMI’s Homeland 

Security Grant Program, which are focused on sustainment. 

The State Homeland Security Strategy serves as the basis for requesting funds. 

Funds received as part of the SHSP were provided for the purpose of 

implementing the goals, objectives, and steps contained within the approved 

strategy. The DHS State and Urban Area Homeland Security Strategy Guidance on 

Aligning Strategies with the National Preparedness Goal (2005) states that the 

State and Urban Areas Homeland Security Strategies should have strong 

foundations that support an ongoing process of review and refinement as new 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

lessons are learned, new priorities are realized, and new homeland security 

guidance is released. 

Also the Homeland Security Grant Program Guidance and Application Kit 

recommends revising the State Homeland Security Strategy once every two 

years. This will ensure that existing goals and objectives reflect all FEMA mission 

areas and the National Priorities, implement the whole community approach to 

emergency planning and management to address the concerns and needs of 

local government, and reflect existing citizen preparedness efforts. In order to 

ensure that spending is congruent with national goals and current threats to and 

needs of the Territory, CNMI should have a process in place to review, revise, 

and update the State Homeland Security Strategy regularly. 

The Strategy--unchanged since FY 2009--was approved by FEMA in FY 2012 with 

no changes and including references to meetings held in 2007 and an upcoming 

2009 assessment of critical infrastructure. FEMA stated that they obtain 

information about updates in CNMI’s HSGP through annual investment 

justifications that describe the equipment, trainings, and programs for which the 

grant funds are to be used. However, this methodology had shortcomings. The 

investment justifications for FY 2009 and FY 2011 are tied to objectives in the 

Strategy, but the investment justifications for FY 2010 are not. While annual 

investment justifications may provide some important information regarding the 

strategy of CNMI, they do not provide a cohesive plan and measurable objectives 

like the Strategy is designed to do. 

For example, in the FY 2010 Investment Justification, there are 13 investments 

each with its own description, funding request, and milestones. However, there 

is no overview that ties the investments together in a cohesive package, nor do 

the investments provide measurable objectives. 

To its credit, the CNMI State Homeland Security Strategy provided for an 

evaluation plan to conduct periodic organizational reviews, and updates, on 

State Homeland Security Strategy objectives and goals, as well as the State 

Preparedness Report, Investment Justification Package initiatives, Emergency 

Operation Plan, and other Preparedness documents. 

However, because the evaluation plan was not implemented, there are no 

current, relevant goals and objectives, and implementation steps to accomplish 

those objectives. In addition, CNMI cannot be assured that actual steps 

performed are in line with the objectives, goals, and vision of the HSGP. 

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Department of Homeland Security 

Strategic Goals and Objectives are not Specific or Measurable 

The CNMI State Homeland Security Strategy contains many objectives that are 

not specific, are non-measurable, and are outdated or missing target completion 

dates. Consequently, the strategic goals and objectives in CNMI’s State 

Homeland Security Strategy do not provide an adequate basis for measuring 

progress. 

The DHS State and Urban Area Homeland Security Strategy Guidance on Aligning 

Strategies with the National Preparedness Goal, dated July 22, 2005, states that 

a comprehensive strategy should contain both broad based, long term goals and 

corresponding short term objectives that address areas of prevention, 

protection, response, and recovery enhancements within the State or Urban 

Area. The guidance also states that 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. 

An objective should be: 

•	 Specific, detailed, and focused - helping to identify what was 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.

Table 1 includes examples where CNMI’s Strategy contained objectives that did 

not specifically identify what was to be achieved or accomplished, did not 

include a timeline, or did not provide a standard for comparison or 

measurement. 

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Department of Homeland Security 

Table 1: Examples of State Homeland Security Strategy Shortcomings
 

Goal 2: Improve current Regional Preparedness planning. 

Objective 2.A: Include, as part of the CNMI Preparedness Plan review and update, 

potential Jurisdictional Regional Collaboration.

Step 2.A.1: The CNMI Office of Homeland Security will lead and coordinate this 

effort. 

Step 2.A.2: The Office of Homeland Security Project Manager will coordinate with 

various CNMI Department/Agency, stakeholders, and appropriate 

private sector entity, and other organizations to identify potential

jurisdictional regional collaboration issues. 

Step 2.A.3: Integrate this process into the overall Preparedness plans, policies, and 

procedures Plan of Action and Milestones. 

Step 2.A.4: Start small; identify and test regional collaboration for one or two 

specific issues. Build on the success of these initial issues until full, 

realistic jurisdictional regional collaboration is realized. 

Goal 6: Enhance CNMI Exercise Program

Objective 6.A: Update, enhance, implement, and manage CNMI exercise program

Step 6.B.1: The CNMI Office of Homeland Security Exercise Director will lead and 

coordinate this effort. 

Step 6.B.2: The Exercise Director will develop a Plan of Action and Milestones to 

address all issues related with this initiative. 

Step 6.B.3: Ensure Homeland Security Exercise and Evaluation Program (HSEEP) 

compliance.

Step 6.B.4: Implement the updated CNMI Exercise Program. 

Source: CNMI Homeland Security Strategy FY 2009 

FEMA officials have not required the HSEM to update its strategy regularly 

because they do not believe this is a requirement of the HSGP, but rather a 

suggestion. Additionally, FEMA officials obtain their updates on the CNMI’s 

strategy through annual submission of investment justifications. Although the 

investment justification can provide useful information regarding CNMI’s 

proposed strategy, they do not provide the cohesive and measurable objectives 

that the State Homeland Security Strategy is designed to provide. Although the 

investment justifications for each year do provide anticipated completion dates 

for milestones for each project, the investment justifications submitted by HSEM 

do not contain specific objectives that can be used to measure improved 

preparedness and the success of the program. 

Effectiveness of the State Homeland Security Grant Program Was Not 

Measured

HSEM does not track improved preparedness, gaps, deficiencies, or excesses of 

the Homeland Security Grant Program. This occurred because HSEM did not 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

establish baselines in the State Homeland Security Strategy from which to 

measure improved preparedness. As illustrated in the examples above, the 

Strategy does not provide the current level or what CNMI wants to achieve in an 

identified timeframe. For example Objective 6A should have indicated the 

number or percentage of CNMI first responder personnel already trained as of 

2009 and the training goal in terms of number or percentage of personnel and 

the estimated completion date. 

Also, although HSEM regularly discusses preparedness, risks, and needs of CNMI, 

it does not have measurable metrics to track or document the improved 

preparedness. The HSEM’s Chemical, Biological, Radiological, Nuclear, and 

Explosive (CBRNE) Weapons task force meets quarterly to discuss risks and 

preparedness. The task force has also met to prepare documents such as the 

Multi-Year Training and Exercise Plan and the State Preparedness Report in 2012 

as a way to discuss preparedness with stakeholders. However, HSEM does not 

track nor document its improved preparedness discussions nor compare its 

preparedness versus a baseline.

Measuring improved preparedness allows HSEM, FEMA, and DHS to obtain an 

accurate view of the outcomes of the program. Without these measurements, 

FEMA and DHS may not have enough meaningful information to determine the 

impact of the program, which may affect their ability to report outcomes under 

the Government Performance and Results Act of 1993 and submit its National 

Preparedness Report as required under Presidential Policy Directive/PPD-8. 

Although HSEM prepared after-action reports as a result of exercises and

provided some level of assessment, no training statistics were collected and 

analyzed to determine the level or impact on preparedness. Training is discussed 

informally and anecdotal responses are provided by participants as part of trip 

reports, but this information is not compiled in a comprehensive manner. 

Insufficient Support Not Retained for Threats, Risks, and Vulnerabilities Data 

HSEM appears to have evaluated the threat and vulnerabilities to measure the 

needs of CNMI. However, HSEM does not have a proper retention policy to 

maintain documentation that supports the source of the threat, risks, and 

vulnerability data. As a result, not having proper documentation could make the 

evaluation process more difficult in the event of turnover of HSEM staff. 

The members of the HSEM’s CBRNE task force meet quarterly to go over threats, 

risks, vulnerabilities, and the preparedness of CNMI. HSEM’s threat and 

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Department of Homeland Security 

vulnerability reports were compiled by the various CBRNE members representing 

several agencies within the government of CNMI, Federal entities and 

community stakeholders. Based on the conclusions reached in the meetings and 

any additional research performed, the HSEM Planner updated critical 

documents such as the State Preparedness Report, and the Emergency 

Operations Plan. HSEM was unable to produce documentation of the CBRNE task 

force meetings or the sources of their data. Per HSEM, the meetings usually 

resulted in direct edits to the documents which were later sent to the 

participants for concurrence.

Although HSEM appears to have evaluated the threat and vulnerabilities to 

measure the needs of CNMI, HSEM does not have a proper retention policy to 

maintain documentation that supports the source of this data. Not having 

proper documentation could make the evaluation process more difficult in the 

event of turnover of HSEM staff. Proper documentation would allow for

continuity and would clarify areas of responsibility within HSEM. 

Not having written policies and procedures, as well as high turnover within 

HSEM, contributes to issues in its grant management practices. HSEM currently 

does not have policies and procedures for the strategic planning, measurement, 

and documentation processes, which negatively impacts its ability to update its 

State Homeland Security Strategy and to assess improved preparedness, gaps, 

excesses, and deficiencies of its implementation of the State Homeland Security 

Grant Program. 

Insufficient documentation limits FEMA’s ability to determine the accuracy of 

reported risk and vulnerability data and could make the evaluation process more 

difficult in the event of turnover of HSEM staff. 

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

preparedness grants to complete a Threat and Hazard Identification and Risk 

Assessment (THIRA) 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. FEMA 

officials state that THIRA results and the State Preparedness Report 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. See appendix E for 

more information about the THIRA. 

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Department of Homeland Security 

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate:

Recommendation #1:

Advise HSEM to develop formal written policies and procedures for: 

•	 Updating its strategy to reflect current objectives of CNMI’s grant 

program, and 

•	 Establishing goals, objectives, and implementation steps. 

Recommendation #2:

Require HSEM to implement procedures to regularly evaluate, assess, and revise 

the State Homeland Security Strategy. 

Recommendation #3: 

Require HSEM to update the State Homeland Security Strategy to: 

•	 Reflect current goals, objectives, steps, timeframes, and measurements; 

and 

•	 Contain specific, measurable, and time-limited goals and objectives that 

would serve as the baseline to measure improved preparedness. 

Recommendation #4: 

Require HSEM to develop and implement a system of internal controls that 

would allow HSEM to routinely gather quantitative and qualitative performance 

data. 

Recommendation #5: 

Require HSEM to perform regular analysis of the gaps, excesses, and deficiencies 

of the CNMI’s strategy and preparedness. 

Recommendation #6: 

Require HSEM to retain sources of information and documentation used to 

develop and compile threat and hazard information. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Management Comments and Auditor Analysis 

Management comments to recommendation 1. At our exit conference with 

FEMA to discuss the findings and recommendations as presented in the draft 

report, we agreed to separate the third bullet in recommendation 1 into a

distinct recommendation. This newly created recommendation 6 will permit 

FEMA to effectively address potential corrective actions. We have also relabeled 

the subsequent recommendations 6 through 8 as 7 through 9. 

FEMA and CNMI concurred with the recommendations. FEMA did not specifically 

address recommendations 1 or 6. These recommendations were intended to 

ensure policies and procedures were in place to assist HSEM in executing its 

grant management functions and retain supporting documentation. The 

recommendations will remain unresolved and open until FEMA provides suitable 

corrective action plans and target completion dates. 

Regarding recommendations 2 through 5, according to FEMA, it has established 

and implemented a system to help states, territories, and urban areas establish 

measurable goals and objectives that will enable them to systematically measure 

improvements in capabilities and preparedness. The National Preparedness Goal 

and the National Preparedness System serves as the framework for assessing 

grant effectiveness. FEMA has developed and is implementing performance 

assessments that measure progress toward achieving the Goal. The THIRA will be 

used to create a baseline and targets for FY 2013 and beyond. FEMA has also 

redesigned the State Preparedness Report (SPR) to help states demonstrate and 

track preparedness improvement over time. The SPR is a standardized capability 

assessment that compares the THIRA targets to current capability, and 

documents any gaps that exist. Finally, the use of the THIRA, SPR and the 

investment justifications methodology provides the goals and assessment of 

progress against those goals. 

According to FEMA, CNMI has submitted its FY 2012 THIRA and SPR, and 

indicated in its FY 2013 application that its investments target a wide range of 

activities that align with the gaps outlined in the FY 2012 THIRA and SPR. 

We consider FEMA’s and CNMI’s actions responsive to the intent of 

recommendations 2 through 5. These recommendations are considered resolved 

and closed. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Financial and Progress Reporting 

CNMI did not always submit quarterly Federal Financial Reports or Biannual 

Strategy Implementation Reports timely as required by the grant award and 

financial grant guidance. Consequently, the ability to effectively and efficiently 

monitor the grant expenditures for CNMI could be hampered by the untimely 

submission of the financial and progress reporting. 

The CNMI is required by the grant award and grant guidance to submit quarterly

Federal Financial Reports and biannual progress reports (Biannual Strategy 

Implementation Reports, or “BSIR”). These reports are due within 30 days of the 

end of the reporting period. 

Of the 27 Federal Financial Reports submitted by HSEM through September 30, 

2012 for HSGP grants for FYs 2009 through 2011, four were submitted late as 

summarized in table 2: 

Table 2: Late Submission of Federal Financial Reports 

Grant Year To 

Submission Due 

Date

Actual Submission 

Date

Days 

Overdue

2009 9/30/2009 10/30/09 1/20/10 82 

9/30/2011 10/30/11 11/2/11 3

2010 9/30/2011 10/30/11 11/2/11 3

2011 9/30/2011 10/30/11 1/23/12 85 

Source: DHS OIG Analysis of Federal Financial Reports

According to the CNMI Department of Finance, the Federal Financial Reports for 

the HSGP 2009 and 2010 for the reporting period of July 1 to September 30, 

2011 were submitted three days late due to no available staff to process the 

reports. For the initial reports for HSGP 2009 and HSGP 2011, the grant had not 

been uploaded in the Payment and Reporting System. The grant was not 

established until January 20, 2010 and January 23, 2012, respectively.

Many BSIRs were not submitted at all. Out of the 12 BSIRs that should have been 

submitted for HSGP FYs 2009 through 2011, only 6 were submitted. The missing 

BSIRs are as follows: 

• Grant Year 2009 – December 2011 

• Grant Year 2010 – June 2011, December 2011, and June 2012 

• Grant Year 2011 – December 2011, and June 2012 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

HSEM did not have a proper system or policies and procedures in place to ensure 

that BSIRs were submitted within the 30 day requirement. In addition, we noted 

that FEMA officials have not emphasized the submission of missing or late BSIRs. 

The quarterly Federal Financial Reports and biannual BSIRs are designed to 

provide DHS and FEMA with financial and programmatic information about the 

grant program that can be used to monitor the implementation of the program. 

Therefore, the ability to effectively and efficiently monitor the grant 

expenditures for CNMI could be hampered by the untimely submission of the 

Federal Financial Reports and non-submission of the BSIRs. Also, when Federal 

Financial Reports and BSIRs are not submitted timely, the grant award states 

that CNMI could be prevented from drawing down funds while those Federal 

Financial Reports and BSIRs are delinquent. This could impact CNMI’s ability to 

procure goods and services necessary for its SHSP operations. 

Recommendations 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate:

Recommendation #7:

Require HSEM to develop and update, as necessary, policies, procedures and 

controls to ensure timely submission of all reports in accordance with the grant 

guidelines in conjunction with Department of Administration. 

Recommendation #8: 

Obtain all late BSIR submissions, enforce the Federal Financial Report and BSIR 

submission requirements, and provide technical assistance as needed to 

facilitate timely submission. 

Management Comments and Auditor Analysis 

FEMA and CNMI concurred with the recommendations. FEMA will require HSEM 

to develop a handbook or standard operating procedures (SOP) within 180 days, 

will work with HSEM on the SOP’s design and development, and will ensure that 

reporting requirements are included in the financial and programmatic SOP. 

FEMA will require HSEM to submit all outstanding BSIR submissions within 90 

days. 

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 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

We consider FEMA’s actions responsive to the intent of recommendations 7 and 

8. These recommendations are considered resolved and will remain open until 

FEMA provides evidence of receipt of all BSIRs and development and 

implementation of a new SOP and staff guidance. 

Travel Expense Documentation 

HSEM was not able to provide adequate support for the per diem and other 

travel costs totaling $17,002 that were reimbursed from SHSP grant funds. 

Therefore, we question these disbursements. 

The CNMI did not have supporting documents for several travel disbursements 

reimbursed by the SHSP grant. The CNMI could not support costs claimed for 15 

travel disbursements that totaled $17,002. Additionally, there were no 

documents supporting costs for per diem, housing allowance claimed, nor the 

refund of per diem provided when course registration included housing and 

meals. 

Table 3: Travel Disbursements Without Sufficient Documentation 

Grant Year

Total

Disbursements 

Tested

Disbursements 

with Insufficient 

Support 

Unsupported 

Amount 

2009 25 5 $6,593

2010 32 1 $1,160

2011 28 9 $9,249

Totals 85 15 $17,002

Source: DHS OIG Disbursement Testing 

Code of Federal Regulations Title 44 Part 13.20(b)(6), Source documentation,

requires that accounting records must be supported by such source 

documentation as cancelled checks, paid bills, payrolls, time and attendance 

records, contract and subgrant award documents, etc. 

Although HSEM provided travel authorizations, they were not able to locate the 

support for the per diem and other costs totaling $17,002 that were reimbursed 

from SHSP grant funds. Therefore, we question these disbursements in the 

amount of $17,002. 

www.oig.dhs.gov 13 OIG-14-05
 
 

 

 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendation 

We recommend that the FEMA Assistant Administrator, Grant Programs 

Directorate:

Recommendation #9:

Require HSEM to either provide support for, or repay, the SHSP disbursements in 

the amount of $17,002. 

Management Comments and Auditor Analysis 

FEMA and CNMI concurred with the recommendation. FEMA will require HSEM 

to provide all related source documentation for the questioned travel and will 

review to ensure they meet allowability criteria.

We consider FEMA’s actions responsive to the intent of recommendation 9. 

However, this recommendation will remain unresolved and open until FEMA 

provides a timetable for completion. 

www.oig.dhs.gov 14 OIG-14-05
 
 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Objectives, Scope, and Methodology 

DHS OIG was established by the Homeland Security Act of 2002 (Public Law 107-296) by 

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

inspection, and special reports prepared as part of our oversight responsibilities to 

promote economy, efficiency, and effectiveness within the Department. 

This report provides the results of our work to determine the plans developed by CNMI 

to improve preparedness and response to hazards of all types, the goals set within those 

plans, the measurement of progress towards the goals, and the assessments of 

performance improvement that result from this activity. Further, the scope included the 

assessment of these activities within the context of risk to determine if CNMI’s plans 

produced strategic performance improvements related to the highest areas of risk 

rather than merely producing improvements in a broader sense. 

Together, the entire Homeland Security Grant Program and its five interrelated grant 

programs fund a range of preparedness activities, including planning, organization, 

equipment purchase, training, exercises, and management and administration costs. 

Because of the interrelationship of these grant programs, all were considered when 

evaluating the planning cycle and the effectiveness of the overall grant program. 

However, only State Homeland Security Program funding, and equipment and programs 

supported by the grant funding, were reviewed for compliance. The scope of the audit 

included the State Homeland Security Program grant awards for FYs 2009, 2010, and 

2011, as shown in table 4: 

Table 4: SHSP Awards to CNMI FYs 2009 through 2011 

Grant Program FY 2009 FY 2011 FY 2011 Total

SHSP $1,430,000 $1,469,600 $1,157,680 $4,057,280 

Source: FEMA 

We visited the State Administrative Agency, the Homeland Security and Emergency 

Management. The team reviewed a statistical sample of the State Homeland Security 

Program grant’s expenditures representing 43 percent of the dollar value expended for 

all grant years to determine the sufficiency of internal controls. CNMI did not subgrant 

any funds. 

We conducted this performance audit between October 2012 and April 2013, pursuant 

to the Inspector General Act of 1978, as amended, and according to generally accepted 

www.oig.dhs.gov 15 OIG-14-05
 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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. 

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

audit of those costs. This was a performance audit as defined by Chapter 2 of the 

Government Auditing Standards, and included a review and report of program activities 

with a compliance element. 

www.oig.dhs.gov 16 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Management Comments to the Draft Report 

U.S. Depanmcnt or llomclaml Security 

Wa:;hington. DC 20472. 

FEMA 

AUG 0 t 2013 

MEMORANDUM FOR: Anne L. Richards 

Assistant Inspector General for Audits (010) 

IJepartment of Homeland Security 

FROM: / �L[A� David J. Kaufman ��-· \) Associate Administrator for 

Policy, Program Analysis and International Affairs 

f-ederal Emergency Management Agency (f-EMA) 

SUBJECT: FEMA's Response to OIG-12-123-AUD-FEMA Draft Report: 

"The Commonwealth of the Northern Mariana Island's [sic] 

Management (CNM!) of State Homeland Security Program 

(SHSP) Grdnts Awarded During Fiscal Years 2009-2011··. 

Thank you for the opportunity to n::vit:w and comment on O!G-12-123-AUD-FEMA Draft 

Report: "The Commonwealth of the Northern Mariana Island's [sic] Management of State 

Homeland Security Program Grants Awarded During Fiscal Years 2009-20 II". The draft report 

contains eight (8) recommendations for which FEMA concurs with all 8 recommendations. 

FEMA has provided a consolidated response for recommendations 1-5. 

OJG Recommendation 1; We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate advise Office of Homeland Security and bmergency Management 

(OHSEM) lo develop formal written policies and procedures for: 

• Updating its strategy to reflect current objectives of CNMI's grant program. 

Establishing goals, objcctiYcs. and implementation steps; and 

• Retaining sources of information and documentation used to develop and compile 

threat and ha7�rd information. 

FEMA Response to Recommendations I: Concur. (See consolidaled response below for 

recommendalions 1�5) 

OIG Recommendation 2: We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate require 01-lSEM to implement procedures · 

to regularly evaluate, asses.._, and 

reYise the State Homeland Security Strategy. 

FEMA Response to Recommendations 2: Concur. (See consolidated response below jiu· 

recommendalions 1-5) 

www.fema.gov 

www.oig.dhs.gov 17 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

OIG Recommendation 3: We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate require OHSEM to update the State Homeland Security Strategy to: 

• Reflect current goals, objectives, steps, timeframes, and measurements; 

• Contain specific, measurable, and time-limited goals and objectives that would serve 

as the baseline to measute improved preparedness 

FEMA Response to Recommendations 3: Concur. (See consolidated response below .for 

recommendations 1-5) 

OIG Recommendation 4: We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate require OHSEM to develop and implement a system of internal controls 

that would allow OHSEM to routinely gather quantitative and qualitative performance data. 

FEMA Response to Recommendations 4: Concur. (See consolidated response below for 

recommendations 1-5) 

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

Programs Directorate require OHSEM to perform tcgular analysis of the gaps, excesses, and 

defiCiencies of the CNMI' s strategy and preparedness. 

FEMA Consolidated Response to Recommendations 1, 2, 3, 4 and 5: 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 since the issuance ofOIG-12-123-FEMA Draft Report 

"The Commonwealth of the Northern Mariana Island's [sic] Management of State Homeland 

Security Program Grants Awarded During Fiscal Years 2009- 2011". Among other changes, the 

National Preparedness Goal (the Goal) and the National Preparedness System now 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; this includes concrete, measurable objectives to 

manage those risks. The Goal's capability targets provide concrete statements of the Nation's 

requirements in each core capability. 

Measuring Grant Effeetiveness 

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 existing risks, use those 

risks to determine required capabilities, assess current capability levels against those 

requirements, and track its progress in closing identified capability gaps. 

2 

www.oig.dhs.gov 18 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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 a five-step process jurisdictions can use to achieve desired 

outcomes and capability targets for each of the core capabilities. This approach allows a 

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

On December 31, 20 12, states, territories, and major urban areas receiving Homeland Security 

Grant Program (HSGP) funds were required to submit their THIRAs to FEMA. Once each 

jurisdiction ha~ determined capability targets through the THIRA process, it. estimates its current 

capability levels against those targets. 

Also in 2012, states and territories were required to submit State Preparedness Reports (SPRs) to 

FEMA. The THIRA and SPR processes are scalable to allow sub-jurisdictions, sub-grantees and 

subject matter ex:perts 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 clo~-ing those gaps over time. .FEMA reports 

the results of the capability assessments annually in the National Preparedness RePQrt (NPR). 

Sustaining, Building and Dell,•erlng Capabilities 

Having estimated capability requirements, the nex:t 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 

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 Homeland Security 

Grant Program 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 f~rst responder 

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

THIRA, SPR, and IJ's. Strategy updates are encouraged but not required as the THIRA, SPR and 

IJ methodology provide the goals and assessment of progress against those goals. 

Finally, CPG 201: Threat and Hazard Identification and Risk Assessment Guide 

Supplement 1: Toolkit provides all the required templates to complete the THIRA process 

including information and documentation used to develop and compile threat and hazard 

information. As the THIRA will be an annual iterative process, subsequent iterations will build 

on the documents from previous years. 

3 

www.oig.dhs.gov 19 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

CNMl has submitted their FY 2012 THIRA and SPR In their FY 2013 Homeland Security Grant 

Program application, CNMT indicated that their investments target a wide range of activities 

from equipment purchases to full scale exercises that align with gaps outlined in the FY 20 12 

THIRA and SPR. Further, in their Law Enforcement and First Responder Enhancement 

investment, CNMl stated that vulnerabilities documented in the latest TIDRA and SPR will be 

the guiding documents for prioritizing projects under this investment. 

FEMA believes that use of the THIRA, SPR and IJ satisfies the intent of these recommendations 

and requests that they be closed. 

OIG Recommendation 6: We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate require OHSEM to develop and update, as necessary, policies, procedures 

and controls to ensure timely submission of all reports in accordance with the grant guidelines in 

conjunction with Department of Administration. 

FEMA Response to Recommendation 6: Concur. FEMA will require within 180 days of the 

date of the final report that the OHSEM develop a handbook for staff that can be used as a guide 

or Standard Operating Procedure (SOP), which will include policies and procedures to ensure all 

required reports are submitted on time. The guide ?till be designed as a hand off document new 

staff or existing staff can use to guide them through the various financial and programmatic 

reporting requirements. The FEMA Program Analyst (P A) will work closely with CNMI in its 

design and development. 

FEMA believes this action will satisfy the intent of the recommendation and the 

recommendation should remain resolved and open pending the submission of a CNMI Homeland 

Security Grant Program financial and programmatic reporting SOP. 

OIG Recommendation 7: We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate obtain all late BSIR submissions, enforce the Federal Financial Report and 

BSIR submission requirements and provide technical assistance as needed to facilitate timely 

submission. 

FEMA Response to Recommendation 7: Concur. FEMA will ensure that CNMI completes 

this task by requiring the State Administrative Agency (SAA) to submit all outstanding BSJR 

submissions to GPD within 90 days of the date of the final report The P A will also ensure that 

the SAA includes specific reporting requirements for the BSIR reports in the proposed, CNMI 

Homeland Security Grant Program financial and programmatic reporting SOP. 

FEMA believes these steps will satisfy the intent of the recommendation and the 

recommendation should remain resolved and open pending implementation of new SOP and staff 

written guidance. 

OJG Recommendation 8: We recommend that the FEMA Assistant Administrator, Grant 

Programs Directorate require OI-ISEM to either provide support for, or repay, the SHSP 

disbursements in the amount of$ 1 7 ,002. 

4 

www.oig.dhs.gov 20 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA Response to RecommeodatioD 8: Conc:ur. FEMA will request and review all related 

source documentation for the questioned traYel to ensure it meets the allow ability criteria for 

staff to attend required trainings or planning meetings where travel is necessary. If it is 

determined the travel was not allowed, was unauthorized, or no source documentation exists, 

FEMA will initiate a debt collection for the amounts determined to be disallowed. 

FEMA believes this satisfies the intent of the recommendation and it should remain open and 

resolved pending FEMA's final review and determination based on the source documentation 

CNMI provides. 

Thank you again for the opportunity to comment on OIG-12-123-AUD-FEMA Draft Report: 

"The Cmnmonwealth of the Northern Mariana Island's [sic] Management (CNMI) of State 

Homeland Security Program Grants Awarded During Fiscal Years 2009-2011" 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 final report for this audit. 

Please direct any questions regarding this response to Gary McKeon, FEMA' s Chief Audit 

Liaison, at 202-646-13 08. 

5 

www.oig.dhs.gov 21 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

COMMONWEALTH OF THE ~ORTHERN MARIANA ISLANDS 

HOMELAND SECURITY AND EMERGENCY MANAGEMENT 

OFFICE OF THE GOVERNOR Honorable Governor Eloy S. hlos Marvin K. Seman, SAHSEM 

Honorable Lt. Governor Jude U. Hofsdmeider 

July 18, 2013 

Charbet Duckett 

Partner 

Williams-Adley 

1030 15th Street, NW, Suite 350 West 

Washington, DC 20005 

From: Marvin K. Seman, Special Assistant for HSEM 

Subject: OIG Audit FY 2009-2011 Draft Report Comments 

\1s. Duckett: 

On behalfofmyselfand the staff ofCNMI Homeland Security and Emergency \1anagement, I would 

like to extend sincere appreciation to you and the Williams Adley team for the valuable information and 

guidance gleaned throughout the course of your work with us. The draft report provided to us has been 

informative and will certainly play an importantin role in the improvement of our programs and 

processes, particularly as HSEM moves forward with its responsibility as the CNMI's all-hazards 

preparedness entity. 

HSEM has completed review of the draft report of the C:t\MI's Office of the Inspector General audit 

findings dated Jnne 2013 and finds no significant errors or omissions in the report. The findings were 

outlined as follows: 

1. Strategic Planning and Performance Management- NO COMME!\T 

o State Homeland Security Strategy is not current; 

o Strategic goals and objectives are not specific or measurable; 

o Effectiveness ofthe State Homeland Security Grant Program was not measured; and 

o Support for threats, risks, and vulnerabilities data was not retained. 

2. Performance and Financial Reporting- NO COMMENT 

o 6 of 12 BS IRs were late 

o 4 of27 FSRs were late 

3. Travel Expense Documentation- NO COMMENT 

HSEM has begun to address the programmatic and financial findings documented in the report by 

improving existing internal processes and controls and creating them where there were none. 

Recommendations noted in the report and discussed during site visits are taken into acconnt when 

refining our program. 

$fARe can~ Hox 10007, Capttol ffill, Satpan, MP 96950 

Teley a dhoYn.e' (670) 664-2216 (m.Unlino), (670) 322-9572.927418001-3 Fa,>imile (670) 664-2118 (mainline), 322-7743 A # J 

CNMIDISPATCHCENTER(2417i Tel. No. (670) 237-8000/3Fax:'<o. (570)322-9500 - e • _ 

Community Lg~_t!,.!Q1f Ready" 

www.oig.dhs.gov 22 OIG-14-05
 
 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

COMMONWEALTH OF THE NORT HERN MARIANA ISLANDS 

HOMELAND SECURITY AND EMERGENCY MANAGEMENT 

OFFICE OF THE GOVERNOR Honorable Governor Eloy S. Inos Marvin K. Seman, SAHSEI\.1 

Honorable Lt. Governor Jude U. Hofschneider 

HSEM has identified two minor points of clarification that should be incorporated into the final dmft. 

First. the use of the abbreviation "OHSEM" and its expanded title should be revised to read "HSEM" or 

"Homeland Security and Emergency Management." Secondly, the organization chart included as 

Appendix D does not accurately reflect the HSEM structure. An updated copy ofthe chart will be 

provided immediately. 

HSEM acknowledges that the report is a draft and looks forward to receiving a final version for review. 

Once completed, HSEM ¥~ill formally document its corrective actions for the identified findings and 

provide copies to DHS/FEMA and your organization. 

Should you have any questions, please contact me at marvin.seman@gmail.com or at (670) 664-2216. 

Thank you. 

Marvin K. Seman 

Special Assistant for HSEM 

$fARe

Caner Ycx 10007, Capitol ffill, §alp an, MP 96§50 

Telep a dhoVn.•' (670) 664-2216 (mainline), (670) 322-9572.'9274/8001-3 Faorunil" (670) 664-2218 (mainlme), 322-7743 A . 

CNMIDISPATCH CENTER (24/7) Tel. No. (670) 237-8000/3FaxNo. (610) 322-9500 - 0 4 _ 

Community Lg~~mf Ready~ 

www.oig.dhs.gov 23 OIG-14-05
 
 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix C 

Description of the Homeland Security Grant Program 

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

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

other emergencies. The HSGP encompasses several interrelated Federal grant programs 

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

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

costs. Programs include the following: 

•	 The State Homeland Security Program provides financial assistance directly to each 

of the States and Territories to prevent, respond to, and recover from acts of 

terrorism and other catastrophic events. The program supports the implementation 

of the State Homeland Security Strategy to address identified planning, equipment, 

training, and exercise needs. 

•	 The Urban Areas Security Initiative provides financial assistance to address the 

unique planning, equipment, training, and exercise needs of high-risk urban areas, 

and to assist in building an enhanced and sustainable capacity to prevent, respond 

to, and recover from threats or acts of terrorism and other disasters. Allowable costs 

for the urban areas are consistent with the SHSP. Funding is expended based on the 

Urban Area Homeland Security Strategies. 

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

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

•	 Metropolitan Medical Response System

•	 Citizen Corps Program 

•	 Operation Stonegarden (beginning FY 2010)

www.oig.dhs.gov 24 	 OIG-14-05
 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix D 

CNMI Homeland Security and Emergency Management 

Organization Chart 

Special Assistant for Homeland Security 

and Emergency Management 

HSEM Representative HSEM Representative

Emergency Management 

Division

Resource, Tech. and Comm. 

Division

Program Analyst 

CERT Program 

Manager 

Procurement 

Specialist

Financial Analyst

Assistant Training

Coordinator

Resource Section

Communications Section

Hazard 

Mitigation 

Coordinator

Resource Manager

Technical Financial

Analyst

Administration Officer

EMPG Planner

CERT Section

Communications

Manager 

Federal Programs 

Coordinator

Technology Section

Administrative 

Assistant 

Exercise Section

State Exercise 

Coordinator

Assistant Exercise

Coordinator

Grants Program Division

Grants Manager

State Training 

Coordinator

Training Section

Administration & Accounting Division

Resource 

Specialist

EMPG

Planner

Training and Exercise Program Division

Information 

Technology 

Technician

Communications

Technician

Deputy Special Assistant for Homeland 

Security and Emergency Management

Rota Field Office Tinian Field Office

Source: CNMI HSEM 

www.oig.dhs.gov 25 OIG-14-05
 
 

 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix E 

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 impacts, 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. FEMA officials state that 

THIRA results and the State Preparedness Report 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 State Preparedness Report 

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 State Preparedness Report. 

FEMA officials said that the FY 2013 Homeland Security Grant Program funding 

announcement will require applicants to map proposed investments to specific core 

capabilities and capability gaps identified in the State Preparedness Reports, linking 

investments to actions that build and sustain capabilities aligned 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 26 	 OIG-14-05
 
 

 OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix F 

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 27 OIG-14-05
 
 

ADDITIONAL INFORMATION AND COPIES 

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

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

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

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

at: @dhsoig. 

OIG HOTLINE 

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

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

Security (DHS) programs and operations, please visit our website at www.oig.dhs.gov 

and click on the red tab titled "Hotline" to report. You will be directed to complete and 

submit an automated DHS OIG Investigative Referral Submission Form. Submission 

through our website ensures that your complaint will be promptly received and 

reviewed by DHS OIG. 

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

to: 

Department of Homeland Security 


Office of Inspector General, Mail Stop 0305 


Attention: Office of Investigations Hotline 


245 Murray Drive, SW 


Washington, DC 20528-0305 


You may also call 1(800) 323-8603 or fax the complaint directly to us at 

(202) 254-4297. 

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