Department of Homeland Security
 

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Brevard County, Florida, Properly Accounted For and 


Expended FEMA Public Assistance Grant Funds 


Received Under Tropical Storm Fay
 

OIG-14-13-D December 2013
 
OFFJCF: OF INSPECTOR (;ENERAL 

Deparhnenl of Homeland Security 

Wa~hington, DC 20528 : ,,.,\·W.Liig.dhs.gL'\' 

DEC l 1 2013 

MEMORANDUM FOR: Major P. (Phil) May 

Regional Administrator, Region IV 

0~er~~g~ment Agency 

FROM: 

r 

/.£h John V. Kelly 

- Assistant Inspector General 

Office of Emergency Management Oversight 

SUBJECT: Brevard County, Florida, Properly Accounted For ond 

Expended FEMA Public Assistance Grant Funds Received 

Under Tropical Storm Fay 

FEMA Disaster Number 178S-DR-Fl 

Audit Report Number OIG-14-13-D 

We audited Public Assistance funds awarded to Brevard County, Florida (County) 

(FIPS Code 009-99009-00). Our audit objective was to determine whether the County 

accounted for and expended Federal Emergency Management Agency (FEMA) grant 

funds according to Federal regulations and FEMA guidelines. 

The County received a Public Assistance award totaling $9.7 million from the Florida 

Division of Emergency Management (FDEM), a FEMA grantee, for damages resulting 

from Tropical Storm Fay, which occurred in August 2008. The award provided 

75 percent FEMA funding for debris removal, emergency protective measures, and 

permanent repairs to buildings and other facilities. The award consisted of 12 large 

projects and 75 small projects.1 

We audited four large projects with awards totaling $1.5 million (see Exhibit, Schedule 

of Projects Audited and Questioned Costs) for debris removal and emergency protective 

measures. The audit covered the period from August 18, 2008, to May 22, 2013, during 

which the County claimed $1.5 million of costs under the projects we reviewed. At the 

time of our audit, the County had completed work on three projects included in our 

scope and had submitted final claims to FDEM for expenditures under those projects. 

We conducted this performance audit between January and July 2013 pursuant to the 

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

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

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

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

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

1 Federal regulations in <?ffect at the tim(' of the disaster set the large project threshold at $50,900. 
 

 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

audit objective. To conduct this audit, we applied the statutes, regulations, and FEMA 

policies and guidelines in effect at the time of the disaster. 

We judgmentally selected and reviewed project costs (generally based on dollar value); 

interviewed County and FEMA personnel; reviewed the County’s procurement policies 

and procedures; reviewed applicable Federal regulations and FEMA guidelines; and 

performed other procedures considered necessary to accomplish our audit objective. 

We did not assess the adequacy of the County’s internal controls applicable to its grant 

activities because it was not necessary to accomplish our audit objective. However, we 

gained an understanding of the County’s method of accounting for disaster-related 

costs and its policies and procedures for administering activities provided for under the 

FEMA award. 

RESULTS OF AUDIT 

For the projects we reviewed, the County generally accounted for FEMA grant funds 

according to Federal regulations and FEMA guidelines. However, the County claimed 

$43,631 of ineligible costs for straight-time force account labor.2

 

The County claimed $43,631 under Project 631 for straight-time labor costs of solid 

waste department employees performing debris removal activities. The County elected 

to participate in the Public Assistance Pilot Program under several, but not all, projects 

for various departments.3

 Under the pilot program, FEMA will pay the County for 

straight- or regular-time salaries and benefits of permanently employed personnel 

engaged in debris removal activities. Typically, FEMA does not pay for straight- or 

regular-time salaries and benefits of permanent employees engaged in emergency work 

(debris removal and emergency protective measures) (44 CFR 206.228). However, the 

County did not include its solid waste department in the pilot program. Consequently, 

the County should not have charged the FEMA project for the $43,631 of straight-time 

labor it incurred for solid waste department personnel who performed debris removal 

activities under the project. Therefore, we question the $43,631. 

 

2 Force account refers to the County’s personnel and equipment.
 3 FEMA implemented the Public Assistance Pilot Program from June 1, 2007, through December 31, 2008. 

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

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

RECOMMENDATION 

We recommend that the Regional Administrator, FEMA Region IV: 

Recommendation #1: Disallow $43,631 (Federal share $32,732) of ineligible straighttime labor costs the County claimed under Project 631. 

DISCUSSION WITH MANAGEMENT AND AUDIT FOLLOWUP 

We discussed the results of our audit with County, FDEM, and FEMA officials during our 

audit. We also provided a draft report in advance to these officials and discussed it at 

the exit conference held on July 31, 2013. County officials disagreed with the audit 

finding. 

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 contact information for responsible parties and any other supporting 

documentation necessary to inform us about the current status of the recommendation. 

Until we receive and evaluate your response, we will consider the recommendation 

open and unresolved. 

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

copies of our report to appropriate congressional committees with oversight and 

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

the report on our website for public dissemination.

Major contributions to this report are David Kimble, Director; Adrianne Bryant, Audit 

Manager; Oscar Andino, Auditor-in-charge; Nadine Ramjohn, Senior Auditor; and 

Calbert Flowers, Auditor. 

Please call me with any questions at (202) 254-4100, or your staff may contact 

David Kimble, Director, Eastern Regional Office, at (404) 832-6702. 

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

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Exhibit 

Schedule of Projects Audited and Questioned Costs 

Project 

Number Project Scope

FEMA 

Category 

of Work 

Amount

Awarded 

Amount

Questioned

Federal 

Share Finding

1745

Emergency Protective 

Measures B $ 94,748 $ 0 $ 0 

1581

Emergency Protective 

Measures B 74,539 0 0 

1101

Emergency Protective 

Measures B 489,000 0 0 

631 Debris Removal A 870,006 43,631 32,723 A

TOTAL $1,528,293 $43,631 $32,723

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

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 OFFICE OF INSPECTOR GENERAL 

 Department of Homeland Security 

Appendix
 

Report Distribution 

Department of Homeland Security

Secretary 

Chief Financial Officer 

Under Secretary for Management 

Chief Privacy Officer 

Audit Liaison, DHS 

Federal Emergency Management Agency

Administrator 

Chief of Staff 

Chief Financial Officer 

Chief Counsel

Director, Risk Management and Compliance 

Audit Liaison, FEMA Region IV 

Audit Liaison, FEMA (Job Code G-13-012)

State

Executive Director, Florida Division of Emergency Management 

State Auditor, Florida 

Office of Management and Budget

Chief, Homeland Security Branch

DHS OIG Budget Examiner

Recovery Accountability and Transparency Board

Director, Investigations, Recovery Accountability and Transparency Board

Sub grantee

Audit Liaison, Brevard County 

Congress

Senate Committee on Appropriations, Subcommittee on Homeland Security 

Senate Committee on Homeland Security and Governmental Affairs 

House Committee on Appropriations, Subcommittee on Homeland Security 

House Committee on Homeland Security 

House Committee on Oversight and Government Reform

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

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ADDITIONAL INFORMATION AND COPIES 

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

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

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

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

at: @dhsoig. 

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

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Attention: Office of Investigations Hotline 


245 Murray Drive, SW 


Washington, DC 20528-0305 


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