Verification Review of 

District of Columbia's 

Management of Homeland 

Security Grant Program 

Awards for Fiscal Years 

2010 Through 2012 

October 10, 2017 

OIG-18-02 
 

 

 

 

 

 

 

 

 

 

 

 

 

DHS OIG HIGHLIGHTS
 

Verification Review of the
 

District of Columbia’s Management of 

Homeland Security Grant Program Awards for 

Fiscal Years 2010 Through 2012
 

October 10, 2017 

Why We Did This 

Verification Review 

In September 2014, the Office of 

Inspector General (OIG) issued an 

audit report entitled, District of 

Columbia’s Management of Homeland 

Security Grant Program Awards for 

Fiscal Years 2010 Through 2012 (OIG14-147). We conducted this 

verification review to evaluate whether 

the District of Columbia (DC) 

Homeland Security Emergency 

Management Agency (HSEMA) 

adequately implemented prior 

recommendations and whether those 

recommendations achieved the 

intended results. 

What We Recommend 

We determined that DC HSEMA 

resolved our previously identified 

issues and demonstrated 

improvements to its monitoring and 

oversight of SHSP and UASI grant 

subrecipients. We are not making any 

additional recommendations. 

For Further Information: 

Contact our Office of Public Affairs at 

(202) 254-4100, or email us at 

DHS-OIG.OfficePublicAffairs@oig.dhs.gov 

What We Found 

We determined that DC HSEMA resolved 

previously identified issues and improved its 

monitoring and oversight of State Homeland 

Security Program (SHSP) and Urban Area 

Security Initiative (UASI) grant subrecipients. 

We also confirmed DC HSEMA submitted the 

2016 Threat and Hazard Identification and Risk 

Assessment (THIRA) report required by FEMA. 

DC HSEMA’s implementation of previous OIG 

recommendations achieved the intended results 

of strengthening grant program management, 

performance, and oversight. 

www.oig.dhs.gov OIG-18-02 
 

 

 

 

 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

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

October 10, 2017 

MEMORANDUM FOR: Thomas DiNanno 

Assistant Administrator, Grants Program Directorate 

Federal Emergency Management Agency 

FROM: John E. McCoy II 

Acting Assistant Inspector General for Audits 

SUBJECT:	 Verification Review of District of Columbia’s 

Management of Homeland Security Grant Program 

Awards for Fiscal Years 2010 Through 2012 

In September 2014, we issued an audit report entitled, District of Columbia’s 

Management of Homeland Security Grant Program Awards for Fiscal Years 2010 

Through 2012 (OIG-14-147). In that report, we made 11 recommendations to 

improve both the Federal Emergency Management’s and the District of 

Columbia’s (DC) oversight and management of its Homeland Security Grant 

Program (HSGP) awards. All prior recommendations were closed by December 

2015. 

We conducted this verification review to evaluate whether the DC Homeland 

Security Emergency Management Agency’s (HSEMA) implemented our 

recommendations with the intended results. We evaluated nine of the most 

critical recommendations from our previous report that include procurement 

and sole source contracting, property and inventory management, adequate 

support of personnel time charges, and grant awards management, reporting 

and oversight. 

We determined that DC HSEMA resolved our previously identified issues and 

improved its monitoring and oversight of State Homeland Security Program and 

Urban Area Security Initiative grant subrecipients. DC’s implementation of 

corrective actions addressed the recommendations, achieved the intended 

results of strengthening grant program management, performance, and 

oversight. This report contains no additional recommendations. 

Consistent with our responsibility under the Inspector General Act, we will 

provide copies of our report to congressional committees with oversight and 

appropriation responsibility over the Department of Homeland Security. We will 

also post the report on our website for public dissemination. 

Please call me with any questions, or your staff may contact Paul Wood, Acting 

Deputy Assistant Inspector General for Audits at (202) 254-4283. 

www.oig.dhs.gov 
 

 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Background
 

In 2013 and 2014, we conducted an audit of the District of Columbia’s (DC) 

management of the Homeland Security Grant Program (HSGP) for grants 

awarded from fiscal years 2010 through 2012. In September 22, 2014, we 

issued an audit report entitled, District of Columbia’s Management of Homeland 

Security Grant Program Awards for Fiscal Years 2010 Through 2012 

(OIG-14-147), which included 11 recommendations to improve the overall 

effectiveness of DC’s management of the Homeland Security Emergency 

Management Agency’s (HSEMA) State Homeland Security Program (SHSP) and 

Urban Area Security Initiative (UASI) funds. During the period of our prior 

audit, the Federal Emergency Management Agency (FEMA) awarded DC and 

the National Capital Region (NCR) about $189 million in SHSP and UASI grant 

funds.1 

In our prior audit, we identified several high-level areas of concern. During this 

verification review, we assessed DC HSEMA’s implementation of the previously 

identified corrective actions in these overarching areas. 

1. Homeland Security Strategies, Performance Goals and Assessments 

(Recommendations 1 and 2); 

2. Contracting Policies and Procedures (Sole Source) 

(Recommendations 3, 4, and 5); 

3. Inventory Monitoring (Recommendations 6 and 7); 

4. Personnel Costs (Recommendations 8 and 9); 

5. Project Management Plans (Recommendations 10 and 11); and 

6. Sub-recipient Monitoring and Oversight (Recommendation 11). 

We noted that, in most instances, DC HSEMA awarded its grant subrecipients 

and spent its own grant awards in compliance with applicable Federal laws and 

regulations.2 However, we recommended potential improvements in its grant 

management practices, including: (1) developing homeland security strategies 

with defined objectives to measure performance; (2) developing a formal 

process to measure progress and improvements in preparedness and its ability 

to respond to disasters; (3) monitoring its subrecipients to ensure full 

compliance with Federal and state procurement requirements; (4) enforcing 

property management and inventory control requirements; (5) ensuring that 

1 The NCR encompasses DC and parts of Maryland and Virginia, including the cities of 

Alexandria, Fairfax, Falls Church, Manassas, and Manassas Park and the counties of 

Arlington, Fairfax, Loudoun, and Prince William in Virginia, and Frederick, Montgomery, and 

Prince George’s in Maryland, which include the municipalities of Bowie, College Park, City of 

Frederick, Gaithersburg, Greenbelt, Rockville, and Takoma Park. 

2 As the State Administrative Agency for DC and the NCR, DC HSEMA is responsible for 

managing the SHSP and UASI grants. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

personnel time charges are adequately supported; and (6) improving oversight 

of grant awards management and reporting. According to the audit, 

improvements in these areas would enhance DC’s “effectiveness in the overall 

use of grant funds to improve preparedness and response capabilities, as well 

as reduce the risk associated with managing FEMA grant funds.” 

FEMA’s Assistant Administrator of the Grant Programs Directorate concurred 

with all 11 recommendations and provided us with a proposed corrective action 

plan (CAP) dated November 25, 2014. The CAP included an explanation of 

additional information we needed to resolve recommendations 3–11.3 FEMA 

subsequently delivered two CAP updates, one dated May 6, 2015, and the other 

dated October 6, 2015. By December 9, 2015, the Office of Inspector General 

(OIG) had closed all 11 recommendations in the report. 

During this review, we evaluated about $57 million in SHSP and UASI grants 

that DC received in FY 2016. We reviewed a select number of subrecipients in 

DC and the NCR, including Maryland and Virginia. We verified actions taken as 

a result of the prior audit and determined whether the recommendations 

achieved the intended results. A list of subrecipients is detailed in the 

Objective, Scope, and Methodology section, and appendix A contains a 

complete list of recommendations made during our prior audit. 

Verification Review Results 

We determined that DC HSEMA met the intent of our prior recommendations 

and demonstrated improvements in its SHSP and UASI subrecipient 

monitoring and oversight. We also confirmed DC HSEMA submitted required 

THIRA reports to FEMA. Overall, FEMA and DC HSEMA’s implementation of 

our prior recommendations achieved the intended results of strengthening 

grant program management, performance, and oversight. 

Implementing a SharePoint Comprehensive Grants Management System 

(CGMS) is the most significant improvement DC HSEMA made in 2015. The 

CGMS enhanced DC HSEMA’s monitoring of subrecipient procurements, 

financial management of grant awards, equipment inventory management, and 

grant closeouts. Additionally, DC HSEMA updated its subrecipient handbooks 

in 2015 and 2016. The handbooks include references to 2 Code of Federal 

Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for Federal Awards. DC HSEMA also revised 

and updated its grant terms and agreements, monitoring protocols and 

frequency of monitoring visits, including desk reviews and site visits. 

3 Recommendations 1 and 2 in the report were closed on September 22, 2014. 

www.oig.dhs.gov 3 OIG-18-02 
 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

FEMA’s Actions and OIG Verification 

For this review, we identified several high-level areas of concern from our prior 

audit and verified DC HSEMA’s implementation of reported corrective actions. 

In each area, we reviewed our original recommendation; confirmed the actions 

FEMA and DC HSEMA took to close the original recommendation; and 

assessed any subsequent actions taken as of the FY 2016 subrecipient’s 

awards. 

Homeland Security Strategies, Performance Goals, and Assessments 

(Recommendations 1 and 2) 

We previously recommended that FEMA require DC HSEMA and the NCR to: 

(1) develop a comprehensive performance measurement system for SHSP and 

UASI homeland security goals and objectives, including target levels of 

performance and the means to measure progress toward enhancing 

preparedness. This system should include Specific, Measurable, Achievable, 

Realistic, and Timely (SMART) objectives; and (2) develop and provide 

subrecipients with consistent and comprehensive measurement tools that 

include baselines for measuring and demonstrating progress toward enhancing 

their level of preparedness through the use of SHSP and UASI grant funds. 

Subsequent to our audit, FEMA developed and implemented performance 

assessments that measure progress toward achieving the National 

Preparedness Goals. FEMA released a consistent methodology for determining 

risks in the THIRA Comprehensive Preparedness Guide 201, Second Edition, in 

August 2013. The guidance details a four-step process based on risk that a 

jurisdiction can use to achieve desired outcomes and capability targets for each 

of the core capabilities. States, territories, and major urban areas receiving 

HSGP funds were required to submit their THIRA reports to FEMA by 

December 31, 2013. States and territories were also required to submit a State 

Preparedness Report (SPR) to FEMA. THIRA and SPR results highlight gaps in 

capability as well as grantee progress in closing those gaps over time. 

During this review, we assessed and confirmed that DC HSEMA submitted the 

required FEMA reports for DC and the NCR, but did not assess whether the 

overall THIRA program was achieving its intended results. We have prepared a 

separate audit proposal to review the THIRA program 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Contracting Policies and Procedures (Sole Source) 

(Recommendations 3, 4, and 5) 

We previously recommended that FEMA ensure DC HSEMA and the NCR: (3) 

review and remove the outdated DHS sole source requirement included in its 

subrecipient program terms and conditions; (4) ensure that a cost analysis is 

performed and included in sole source procurement justifications, according to 

Federal regulations; and (5) ensure that subrecipients review and justify any 

sole source contract each grant award performance period to ensure selection 

of the best and most effective goods and services. 

In FYs 2015 and 2016, DC HSEMA updated subrecipient handbooks and 

removed an outdated DHS sole source requirement from its subrecipient terms 

and conditions. DC HSEMA's standard terms and conditions require its 

subrecipient to notify DC HSEMA when it executes a procurement of more than 

$100,000 by noncompetitive proposal. DC HSEMA’s updated handbook and 

terms and conditions include 2 CFR 200.317 and 200.318(a) for procurements 

by states and general procurement standards. 

In November 2014, DC HSEMA modified and implemented its updated 

monitoring protocols policy. The modifications specifically changed the 

subrecipient monitoring report form to include additional questions specific to 

procurement. In particular, DC HSEMA added a question to the checklist to 

verify whether a subrecipient performs a cost and price analysis for its sole 

source procurements. 

According to DC HSEMA officials, this provides them with a monitoring 

mechanism to verify and evaluate a subrecipient’s use of cost-price-analysis 

and sole source contract justification. We confirmed DC HSEMA also tracks 

subrecipient required cost analysis for sole source contracts in its monitoring 

protocols and reports. 

Inventory Monitoring (Recommendations 6 and 7) 

We previously recommended that FEMA ensure DC HSEMA and the NCR: 

(6) direct subrecipients to establish and maintain property management 

records and policies in accordance with Federal requirements; and conduct 2 

year inventory inspections, plus reconcile inventory inspection results with 

property records; and (7) monitor subrecipients to ensure compliance with 

property management requirements. 

We confirmed that DC HSEMA revised its subrecipient monitoring protocols to 

provide additional safeguards and tools for its grant managers to use during 

onsite and desk-monitoring visits. According to DC HSEMA officials these 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

protocols strengthen management controls and subrecipient management and 

oversight of property records. For example, officials said, they can query the 

CGMS for the specific date of the last inventory performed on equipment items 

purchased and then use the results to develop a corrective action plan as 

needed to assist subrecipients with their property and inventory management. 

DC HSEMA conducts periodic monitoring of subrecipients’ physical inventory 

reviews to ensure they meet the Federal guidelines related to 2-year inventory 

inspections, plus reconciling inventory inspection results with property records 

for equipment $5,000 and over purchased with SHSP or UASI grants. 

We selected and reviewed three subrecipients that purchased equipment using 

SHSP and UASI grants: Montgomery County Office of Emergency Management 

Homeland Security, DC Office of Unified Communications, and Fairfax County 

Police. We verified that all are following Federal property management and 

inventory guidelines in accordance with 2 CFR 200.313(b) and (d). Each 

subrecipient’s equipment management policies were in compliance with 2 CFR 

200.33 and 200.313(d). For FYs 2015–2016 we specifically reviewed each 

subrecipient’s: 

x equipment purchases; 

x last physical inventory; 

x oversight and corrective actions; and 

x equipment management policies. 

We concluded that the subrecipients established and maintained property 

management records and policies in accordance with Federal requirements. 

Personnel Costs (Recommendations 8 and 9) 

We previously recommended, that FEMA ensure DC HSEMA and the NCR: 

(8) implement procedures to ensure compliance with Federal requirements for 

personnel costs charged to Federal awards by requiring employees to prepare 

activity reports or timesheets signed by employees, and (9) verify the personnel 

costs claimed against the FY 2011 UASI grant award were expended on 

inauguration activities by providing documentation that adequately supported 

the questioned $1.3 million as valid charges to the FEMA award, or return to 

FEMA the amount not supported. 

We determined that recommendation 8 was superseded by a new law that 

eliminates the need for employee-signed personnel activity reports. Specifically, 

2 CFR 200.430(i) requires that charges to Federal awards for salaries and 

wages be based on records that accurately reflect the work performed. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

In terms of recommendation 9, DC HSEMA provided documentation related to 

a Virginia Department of Emergency Management (VDEM) award package, 

which authorized reimbursement for overtime expenditures incurred during the 

2015 World Police and Fire Games. VDEM’s request for grant funding to cover 

these expenses was approved by FEMA on June 4, 2015, and designated for 

reimbursement under the FY 2014 UASI grant. The DC HSEMA and FEMA 

approval package includes a letter addressed to VDEM itemizing exact 

requirements for reimbursement of personnel costs charged to Federal awards. 

We met with VDEM and discussed their procedures for ensuring compliance 

with the Federal reimbursement regulations for personnel costs. We reviewed 

the reimbursement packages VDEM submitted to DC HSEMA to verify such 

compliance as well as to determine the adequacy of DC HSEMA’s oversight 

efforts. We determined that the reimbursement documentation submitted by 

VDEM was adequately supported and in accordance with Federal regulations. 

In addition, we determined that DC HSEMA’s oversight and monitoring efforts 

were effectively administered. 

Project Management Plans and Subrecipient Monitoring and Oversight 

(Recommendations 10 and 11) 

We previously recommended that DC HSEMA: (10) establish effective internal 

controls for documenting the review and approval of revisions made to Project 

Management Plans (PMP) submitted by subrecipients; and (11) reevaluate its 

monitoring and oversight efforts to ensure subrecipients are submitting valid 

information in reports and adhering to internal policies and procedures. 

To address these recommendations, DC HSEMA established internal controls 

for documenting the review and approval of subrecipient revisions submitted to 

PMPs. HSEMA implemented and updated its Quarterly Status Report (QSR) 

form and instructional guide. 2 CFR 200.331(d) requires all pass-through 

entities to monitor the activities of subrecipients as necessary to ensure that 

the sub-award is used for authorized purposes, in compliance with Federal 

statutes, regulations, and the terms and conditions of the sub-award and that 

sub-award performance goals are achieved. Pass-through entity monitoring of 

the subrecipient must include reviewing financial and performance reports 

required. DC HSEMA uses PMPs and QSRs to monitor grant awards and 

ensure compliance with Federal requirements and performance expectations. 

We reviewed select subrecipient grant files in the CGMS. We also analyzed DC 

HSEMA’s FY 2016 Sub-Recipient Handbook and DC HSEMA’s Monitoring 

Protocols, along with their FYs 2015–2017 completed Monitoring Reports, to 

ensure related oversight and monitoring is an ongoing process and is 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

communicated to subrecipients. We conclude that DC HSEMA’s CGMS vastly 

improved its grant program management and oversight. 

Conclusion 

DC HSEMA took corrective actions and satisfied the intent of recommendations 

3–7 and 9–11 from our prior audit report (OIG-14-147). The underlying basis 

for recommendation 8 was eliminated by law. We also determined that DC 

HSEMA timely submitted its required 2016 THIRA. Therefore, we are not 

making any further recommendations as a result of this review. 

Objective, Scope, and Methodology 

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

was established by the Homeland Security Act of 2002 (Public Law 107−296) by 

amendment to the Inspector General Act of 1978. 

We conducted this review to follow up on select audit recommendations as part 

of our responsibility under Office of Management and Budget Circular A-50. We 

verified whether prior audit corrective actions were implemented and achieved 

the intended results. We conducted the verification review between January 

and June 2017 under the authority of the Inspector General Act of 1978, as 

amended, and according to the Quality Standards for Inspections issued by the 

Council of the Inspectors General on Integrity and Efficiency. 

We identified high-level areas of concern (recommendations 3–11) from the 

prior audit work and assessed DC HSEMA’s implementation of reported 

corrective actions. The areas included: contracting policies and procedures, 

specifically sole source contracts; inventory monitoring; personnel costs related 

specifically to extraordinary use of UASI funding for overtime; project 

management plans; and subrecipient monitoring and oversight. 

Recommendations 1 and 2 are related to the implementation of the Threat and 

Hazard Identification and Risk Assessment (THIRA), initial completion required 

by December 31, 2012, intended to be a global and consistent 

methodology/approach for conducting risk assessments and determining 

capability gaps and resources needed to fill those gaps. We believe an in-depth 

review of whether the HSGP improved DC’s preparedness for a disaster would 

require more time and resources than a verification review. Therefore, we 

limited our assessment of recommendations 1 and 2 to confirming DC 

HSEMA’s 2016 THIRA submission for DC and the NCR. 

DC HSEMA’s received more than $57 million in SHSP and UASI grant funds in 

FY 2016. We reviewed more than $11 million for the following subrecipients: 

www.oig.dhs.gov 8 OIG-18-02 
 

 

 

OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

x DC’s Metropolitan Police Department 

x DC’s Office of Unified Communications 

x Fairfax County Police Department 

x Montgomery County Office of Emergency Management for Homeland 

Security 

x Virginia Department of Emergency Management 

x DC HSEMA – monitoring and oversight of -

o Northern Virginia Emergency Response System 

o Northern Virginia Hospital Alliance 

o Maryland Emergency Management Agency 

We also analyzed DC HSEMA’s FY 2016 Sub-Recipient Handbook, and DC 

HSEMA’s Monitoring Protocols, along with their FYs 2015–2017 completed 

Monitoring Reports to ensure equipment management policy updates complied 

with 2 CFR 200.331, that subrecipients used the property standards for 

equipment and management checklist to establish and maintain property 

management records and policies in accordance with Federal requirements. 

We evaluated prior OIG and Government Accountability Office audit reports for 

related work and open recommendations. We researched and reviewed 

applicable Federal guidelines, including: 2 CFR Part 200, Uniform 

Administrative Requirements, Cost Principles, and Audit Requirements for 

Federal Awards; DHS Standard Administrative Terms and Conditions; 

Homeland Security Grant Program Notice of Funding Opportunities; DC HSEMA’s 

Comprehensive Grants Management System (Guide); DC HSEMA’s Sub-Recipient 

Handbook; and DC HSEMA’s Standard Sub-award Terms and Conditions. 

We interviewed FEMA officials, grant managers, financial personnel, and 

program analysts responsible for the administration, monitoring, and oversight 

related to SHSP and UASI grants. We visited FEMA HQ; DC HSEMA; 

Montgomery County Office of Emergency Management, Homeland Security; 

Fairfax County Police Department; DC’s Office of Unified Communications and 

the DC Metropolitan Police Department. 

We reviewed and verified local and Federal procurement and sole source 

policies and documents; equipment management procedures, inventory 

accountability systems and audits; personnel overtime records; agreements 

and approval documents; monitoring protocols; and checklists and final 

monitoring reports. We received a demonstration of the CGMS and conducted a 

limited data reliability test observing DC HSEMA approvals and changes to 

subrecipient grant records. We did not identify any significant discrepancies 

and believe the CGMS data was sufficiently reliable to meet our audit 

objectives. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

The Offices of Emergency Management Oversight and Audits’ major 

contributors to this report are Brooke Bebow, Director; Cecilia Carroll, Audit 

Manager; John Woo, Auditor-in-Charge, Nancy Pergolizzi, Auditor-in-Charge; 

Kalimuddin Ahmad, Auditor, Toni Johnson, Auditor, Ellen Gallagher, 

Communication Analyst, and John Skrmetti, Independent Referencer. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix A 

Prior Audit Report (OIG-14-147) 

Findings and Recommendations 

Recommendations 1 and 2 – Performance Goals and Assessments 

Findings: 

FEMA did not develop and implement performance assessments to measure 

progress toward achieving the National Preparedness Goal. 

Recommendation: for the Assistant Administrator, Grant Programs 

Directorate, require DC HSEMA and the NCR to: 

x Develop a comprehensive performance measurement system for SHSP 

and UASI homeland security goals and objectives that include target 

levels of performance and the means to measure progress toward 

enhancing preparedness. This system should include SMART objectives. 

x Develop and provide subgrantees with consistent and comprehensive 

measurement tools that include baselines for measuring and 

demonstrating progress toward enhancing their level of preparedness 

through the use of SHSP and UASI grant funds. 

Recommendations 3, 4, and 5 – Procurement, Sole Source Contracts, and 

Cost Analysis 

Finding: DC did not effectively monitor its subrecipients to ensure full 

compliance with Federal and state procurement requirements. 

Recommendation: for the Assistant Administrator, Grant Programs 

Directorate, require DC HSEMA and the NCR to: 

x Review and remove the outdated DHS sole source requirement included 

in its subgrantee terms and conditions. 

x Ensure that a cost analysis is performed and included in sole source 

procurement justifications, according to Federal regulations. 

x	 Ensure that subgrantees review and justify any sole source contract each 

grant award performance period to ensure selection of the best and most 

effective goods and services. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 6 and 7 – Property Management and Inventory 

Controls 

Finding: DC HSEMA did not ensure that SHSP and UASI subgrantees adhered 

to inventory control polices for grant-funded equipment. Additionally, 

subgrantees did not include all required information on inventory lists and did 

not provide evidence that they conducted physical inventories and 

reconciliations as required. 

Recommendation: for the Assistant Administrator, Grant Programs 

Directorate, require DC HSEMA and the NCR to: 

x	 Direct subgrantees to establish and maintain property management 

records and policies in accordance with Federal requirements, conduct 

the required 2-year inventory inspections, and reconcile inventory 

inspection results with property records. Ensure that a cost analysis is 

performed and included in sole source procurement justifications, 

according to Federal regulations. 

x	 Monitor subgrantees to ensure compliance with property management 

requirements. 

Recommendations 8 and 9 – Personnel Time Charges 

Finding: Personnel tie charges for UASI funds were not supported by adequate 

activity reports or timesheets. The NCR used the FY 2011 UASI Grant to fund 

officers from several state police departments to provide security at the 2013 

presidential inauguration. 

Recommendation: for the Assistant Administrator, Grant Programs 

Directorate, require DC HSEMA to: 

x	 Implement procedures to ensure compliance with Federal requirements 

for personnel costs charged to Federal awards by requiring employees to 

prepare activity reports or timesheets signed by employees. 

x	 Verify the personnel costs claimed against the FY 2011 UASI grant award 

were expended on inauguration activities by providing documentation 

that adequately supports the questioned $1.3 million as valid charges to 

the FEMA award, or return to FEMA the amount not supported. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Recommendations 10 and 11 – Grants Management Monitoring/Oversight 

- Project Management Plans 

Finding: DC HSEMA and its subgrantees did not always follow grant 

administration and reporting procedures. Additionally, DC HSEMA did not 

have a formal process for documenting the review and approval of changes to 

the project management plans. 

Recommendation: for the Assistant Administrator, Grant Programs 

Directorate, require DC HSEMA to: 

x Establish effective internal controls for documenting the review and 

approval of revisions made to Project Management Plans submitted by 

subgrantees. 

x Reevaluate its monitoring and oversight efforts to ensure subgrantees are 

submitting valid information in reports and adhering to internal policies 

and procedures. 

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OFFICE OF INSPECTOR GENERAL 

Department of Homeland Security 

Appendix B 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

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 

FEMA’s Assistant Administrator, Grants Program Directorate 

FEMA’s GAO-OIG Liaison 

DHS GAO-OIG Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees 

External 

The District of Columbia’s Homeland Security Emergency Management Agency 

www.oig.dhs.gov 14 OIG-18-02 
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www.oig.dhs.gov. 

For further information or questions, please contact Office of Inspector General 

Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov. 

Follow us on Twitter at: @dhsoig. 

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