DEPARTMENT OF HOMELAND SECURITY 

Office of Inspector General 

FEMA’s Sheltering and Transitional 

Housing Activities After Hurricane 

Katrina

OIG-08-93 September 2008
 

 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

September 12, 2008 

Preface 

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. This is one of a series of audits, inspections, and special reports prepared as part of our 

oversight responsibilities to promote economy, effectiveness, and efficiency within the department. 

This report addresses the Federal Emergency Management Agency’s (FEMA) performance in 

fulfilling its mission to provide housing assistance to victims and evacuees of Hurricanes Katrina, 

Rita, and Wilma. We examined various regulations, policies, procedures, plans, and guidelines, and 

assessed whether resources were sufficient to address FEMA’s management responsibilities with 

respect to providing housing assistance. 

The recommendations herein have been developed to the best knowledge available to our office and 

have been discussed in draft with those responsible for implementation. It is our hope that this 

report will result in a more effective, efficient, and economical housing program. We express our 

appreciation to all who contributed to the preparation of this report. 

Richard L. Skinner 
 

Inspector General 
 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina 
Table of Contents/Abbreviations 

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

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

 Results of Review ...........................................................................................................................5 

Planning for Sheltering and Transitional Housing .................................................................... 5 

Communicating and Coordinating with State and Local Governments 

and Other Organizations..........................................................................................................9 

Planning, Managing, and Monitoring Acquisitions.................................................................12 

FEMA Oversight of Leasing Sites...........................................................................................20 

 Manufacturers’ Warranties ......................................................................................................21 

Alternatives To Status Quo...................................................................................................... 23 

Considerations for Congress....................................................................................................28 

Management Comments and OIG Analysis..............................................................................28 

Appendices 

Appendix A: Purpose, Scope, and Methodology...................................................................35 

Appendix B: Event Decision Timeline..................................................................................36 

Appendix C: Management Responses to Draft Report .........................................................40 

Appendix D: Major Contributors to this Report....................................................................49 

Appendix E: Report Distribution ..........................................................................................50 

 Abbreviations 

COTR Contracting Officer’s Technical Representative 

DHS U.S. Department of Homeland Security 

ESF Emergency Support Function 

FAR Federal Acquisition Regulation 

FEMA Federal Emergency Management Agency 

GAO Government Accountability Office 

HAC Housing Area Command 

HUD U.S. Department of Housing and Urban Development 

IA Individual Assistance 

IHP Individuals and Households Program 

JFO Joint Field Office 

NDHS National Disaster Housing Strategy 

NRF National Response Framework 

OIG Office of Inspector General 

Stafford Act Robert T. Stafford Disaster Relief and Emergency Assistance Act

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina
OIG 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The Federal Emergency Management Agency (FEMA) received widespread 

criticism for its response and recovery efforts to Hurricane Katrina, including 

criticism that focused on FEMA’s ability to transition housing assistance from 

emergency shelters to more permanent forms of temporary housing. This 

review focused on FEMA’s activities in providing housing assistance to 

victims in Louisiana, Mississippi, Texas, Florida, and Alabama, and on 

FEMA’s overall management of the housing program. We also considered 

potential alternatives to fulfilling FEMA’s housing mission. The conclusions 

we reached during this review are based on the objectives, scope, and 

methodology detailed in Appendix A of this report. 

Better planning for catastrophic disasters may have allowed FEMA to 

effectively respond to the housing needs of hurricanes Katrina, Rita, and 

Wilma victims. Before Hurricane Katrina, FEMA did not have plans that 

clearly defined roles, responsibilities, and processes to address housing needs. 

After Hurricane Katrina, FEMA did not (1) coordinate housing needs among 

state and local governments; (2) provide adequate contract management and 

monitoring; or (3) provide oversight of contractors’ performance. 

This review identified a number of alternatives that may be viable solutions to 

remedy the housing problems resulting from catastrophic events such as 

Hurricane Katrina. These solutions include (1) having the states or the U.S. 

Department of Housing and Urban Development (HUD) assume more 

responsibility, and (2) having FEMA use more permanent types of housing or 

make lump sum payments to victims in lieu of providing emergency housing 

such as travel trailers and mobile homes. 

We are making 13 recommendations to the Administrator, Federal Emergency 

Management Agency. We also are offering suggestions that Congress may 

wish to consider. Collectively, FEMA should develop plans that define roles, 

responsibilities, and processes to address housing needs resulting from 

catastrophic disaster events. Also, FEMA should develop an acquisition 

strategy that will provide the housing assets, supplies, and services needed to 

meet the short- and long-term needs of disaster victims. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 1 
 

Background 

Devastation from Three Hurricanes 

The 2005 Atlantic hurricane season was the most active season on record 

producing 15 hurricanes, 4 of which hit the United States. Most notable of 

these storms was Hurricane Katrina, one of the strongest storms to strike the 

coast of the United States during the past 100 years. Figure 1 shows the path 

of the three hurricanes. 

Figure 1. Path of Hurricanes Rita, Katrina, and Wilma 

Source: NOAA 

On August 29, 2005, Hurricane Katrina made landfall along the Gulf Coast as 

a strong Category 3 hurricane1

 with sustained winds of 125 miles per hour and 

storm surges of up to 27 feet. It caused catastrophic devastation in Alabama, 

Mississippi, and Louisiana, with some areas losing all or large portions of 

critical infrastructure. Even after the storm passed, the destruction continued 

when the levees and floodwalls surrounding the City of New Orleans were 

breached in several places resulting in approximately 80% of the city being 

submerged, in some places by as much as 20 feet of water. In total, the storm 

destroyed an estimated 300,000 homes, displaced approximately 700,000 

individuals, and resulted in the deaths of more than 1,300 individuals. Within 

2 months of Hurricane Katrina making landfall, hurricanes Rita and Wilma 

1

 The Saffir-Simpson Hurricane Scale is a 1-5 rating based on the hurricane's current intensity and is used to give an 

estimate of the potential property damage and flooding expected along the coast from a hurricane landfall. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 2 
 

struck land areas in Texas, Louisiana, and Florida, placing additional 

pressures on FEMA’s already thinly stretched capabilities. 

FEMA initiated Section 403 (Essential Assistance 42 USC § 5170b) of the 

Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford 

Act), Public Law 93-288, as amended, providing Public Assistance Program 

funding to states for meeting immediate but temporary sheltering (churches, 

schools, non-essential government buildings) needs for individuals who 

evacuated from their homes. Public Assistance funding expanded further to 

include hotels, motels, and apartments (transitional housing) since the storms’ 

devastation prevented individuals from returning to their homes after the 

storm had passed. 

FEMA also initiated its Direct Housing Assistance Program under the 

authority of Section 408 of the Stafford Act. Under the program and after all 

other temporary housing sources in the area have been exhausted, FEMA can 

procure and install manufactured housing units (travel trailers, mobile homes, 

and other types of prefabricated housing) on private sites, commercial parks, 

or other temporary sites developed by FEMA. To qualify for placement, 

applicants must have lived in the affected area at the time the disaster 

occurred, and been displaced from their primary dwelling as a result of the 

disaster. 

As of August 2006, FEMA had procured 143,699 travel trailers and mobile 

homes, and 1,755 modular homes. Due to purchases from prior seasons, 

FEMA had approximately 203,000 travel trailers and mobile homes in its 

inventory. Responding to housing needs in affected states, FEMA issued a 

mission assignment2 to the U.S. Army Corps of Engineers requesting it to: 

• Provide coordination, planning and technical support; 

• Conduct site inspections and design or develop group sites to include 

the installation of utilities; 

• Contract for the hauling, installing, and recovering of mobile homes, 

travel trailers, and other readily fabricated dwellings; 

• Perform associated environmental assess

• Manage staging area operations; and 

• Perform site restoration. 

ments; 

2

 A mission assignment is a work order issued by FEMA to another federal agency directing completion of a specific 

task in support of the state or the overall federal response and recovery operation. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Appendix B to this report describes key events and decisions regarding 

hurricanes Katrina, Rita, and Wilma (Gulf Coast hurricanes) from 

August 25, 2005 through December 12, 2006. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Results of Review 

Better planning may have allowed FEMA to respond more effectively to the 

housing needs of the victims of the Gulf Coast hurricanes that struck in 

August and September 2005. Prior to the 2005 hurricane season, FEMA did 

not have plans that clearly defined roles, responsibilities, and processes to 

address catastrophic disaster housing needs. After Hurricane Katrina, FEMA 

did not (1) coordinate housing needs among state and local governments; or 

(2) provide adequate contract management, monitoring, and oversight of 

contractors’ performance. 

Planning for Sheltering and Transitional Housing 

When Hurricane Katrina struck, FEMA did not have a plan and was not fully 

prepared to provide sheltering or transitional housing to victims of a 

catastrophic disaster. FEMA began assisting states in catastrophic disaster 

planning in 1998, but could not follow through due to a lack of funding. 

Further, the National Response Plan had been developed just prior to 

Hurricane Katrina, but it had not been implemented or tested and did not 

address catastrophic disaster housing plans at the state and local level. 

FEMA’s Lack of a Catastrophic Disaster Housing Plan 

After Hurricane Georges in 1998, Louisiana realized that more planning was 

needed to prepare for the consequences of a major hurricane striking the state. 

In 1999, the state’s Office of Emergency Preparedness requested FEMA’s 

assistance in developing such a plan. After its second request in August 2001, 

the state entered into a contract to assist it in the planning process. However, 

planning was interrupted by disasters, and attempts to revive the process were 

unsuccessful due to funding shortfalls. 

In July 2004, an exercise scenario named “Hurricane Pam” was conducted. It 

involved over 350 participants from more than 15 federal agencies; 

30 Louisiana state agencies and 13 parishes; FEMA headquarters; FEMA 

Regions I, II, IV, and VI; the Louisiana Office of Homeland Security and 

Emergency Preparedness; Mississippi and Arkansas; and numerous voluntary 

agencies. Follow-up sessions were delayed after the initial exercise due to 

funding shortfalls, and a catastrophic disaster housing plan was never 

completed. The Government Accountability Office (GAO) reported that 

requests from FEMA for $100 million for catastrophic planning and an 

additional $20 million for catastrophic disaster housing planning in fiscal 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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years 2004 and 2005, respectively, were denied by the Department of 

Homeland Security (DHS).3 

The National Response Plan was issued in December 2004 to align federal 

coordination structures, capabilities, and resources into a unified, all 

discipline, and all-hazards approach to domestic incident management. The 

purpose of the plan was to tie together incident management to include the 

prevention of, preparedness for, response to, and recovery from terrorism, 

major natural disasters, and other major emergencies. While the plan 

provided basic guidelines, a clear understanding of roles and responsibilities 

was not apparent after Hurricane Katrina struck because the plan had not been 

tested and standard operating procedures had not been developed. 

Further, the plan did not contain a housing annex addressing sheltering and 

transitional housing needs that occur after a catastrophic event. The lack of a 

fully developed and exercised plan led to many management shortfalls and 

inefficiencies in responding to the housing needs of the victims of the Gulf 

Coast hurricanes. 

The Effect of Not Having a Plan 

In the absence of catastrophic disaster housing plans and in anticipation of 

Hurricane Katrina making landfall, FEMA established a Housing Area 

Command (HAC) in Baton Rouge, Louisiana on August 28, 2005. The HAC 

concept was developed in the spring 2005 to respond to large-scale disasters 

where housing needs became overwhelming and involved multiple states. 

The HAC was ineffective in fulfilling its mission primarily because of the 

need for more planning, communication, and coordination between the HAC, 

FEMA headquarters, and the Joint Field Offices (JFOs). While this concept 

was new and untested, FEMA envisioned that the HAC would plan housing 

strategies and find ways to meet the immediate housing needs of disaster 

victims in Louisiana, Mississippi, and Alabama. FEMA recognized that a 

catastrophic disaster would necessitate unconventional approaches to meeting 

housing needs. The concept called for the HAC to use contractors to 

coordinate and oversee the implementation of housing solutions to satisfy 

these needs. 

The HAC did not have clearly defined roles, responsibilities, and expectations 

of deliverables or established performance measures for contractors. Many 

problems ensued because some FEMA officials viewed the HAC as an 

3 Hurricanes Katrina and Rita: Unprecedented Challenges Exposed the Individuals and Households Program to Fraud 

and Abuse; Actions Needed to Reduce Such Problems in the Future, GAO-06-1013, dated September 2006. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 6 
 

 

 

operational element working parallel to JFO operations, while others viewed it 

as working in disregard to JFO operations. 

The organization structure depicted below in Figure 2 envisioned that the 

HAC, working with the Joint Housing Solutions Center,4 would identify and 

coordinate housing resources and that housing operations would remain the 

responsibility of the JFOs. 

Figure 2. Organization Structure of Housing Area Command 

Housing Area Command (Structure) 

Housing 

Area 

Command 

Logistics 

And 

SCM 

Section 

Housing 

Operations 

Section 

Finance 

Coordination 

Section 

HAC 

Support 

Team 

Joint 

Housing 

Solution 

Center 

Planning 

Section 

Long-Term 

Community 

Recovery 

Section 

Florida 

Long Term 

Recovery 

Office 

Alabama 

Joint Field 

Office 

Mississippi 

Joint Field 

Office 

Louisiana 

Joint Field 

Office 

Source: FEMA: Closer to Home-Housing Strategy Solutions in Response to Hurricane 

Katrina, September 12, 2005 

In concept and according to a FEMA policy document, the HAC was to 

identify resources and develop a plan for where and what type of housing was 

needed. The JFOs would implement the plan by developing emergency, 

group, and commercial sites; hauling and installing mobile homes and travel 

trailers; and constructing modular homes. However, the HAC retained 

operational control of housing decisions and operations. Because there was 

4

 The Joint Housing Solutions Center, co-chaired by FEMA and HUD, worked with other federal agencies, volunteer 

groups, and private companies, and developed housing options and identified housing resources. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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no clear understanding of the roles and responsibilities between the HAC and 

the JFOs, the chain of command remained unclear and both entities made 

decisions on housing strategies resulting in duplication of effort. For 

example, as we noted in a previous report,5

 the HAC identified a need for a 

1,400-unit group site in Alabama even though the JFO had not requested this 

site because other housing alternatives had been identified. 

The HAC and its contractors directed most efforts in identifying large, group 

travel trailer sites requiring considerable preparation before trailers could be 

placed on those sites. Some FEMA officials believed that the HAC should 

have spent more time identifying smaller sites or single sites where utility 

hook-ups already existed and that experienced FEMA personnel should have 

been working with the HAC’s “strike teams”6

 that included contract personnel 

who had little or no FEMA experience. At the same time, the JFOs were 

performing housing functions and operations because they believed housing 

needs were unique to each state and the HAC was not in a position to make 

effective decisions without understanding these specific and unique needs. As 

indicated, there was little coordination and communication between FEMA 

headquarters, the JFOs, and the HAC. While HAC officials said that disaster 

circumstances required them to make decisions independently, the lack of a 

clear chain of command and assigned roles and responsibilities contributed to 

the ineffectiveness of the housing strategy and its actual implementation. 

As a result of the lack of coordination and communication among those within 

FEMA making housing decisions, FEMA deactivated the HAC in 

October 2005. The Housing Management Group was established shortly 

thereafter to serve as an interagency, intergovernmental organization to 

facilitate all related disaster-housing concerns. The Housing Management 

Group was organizationally placed within the Individual Assistance Branch of 

the Operations Section at the JFO, and FEMA officials agreed they were 

necessary and effective. 

The lack of a unified federal, state, and local catastrophic disaster housing 

plan and associated exercises, along with an ineffective HAC concept, 

contributed to many of the planning shortfalls in meeting disaster victims’ 

housing needs. FEMA is currently developing a National Disaster Housing 

Strategy (NDHS), as mandated in the Post Katrina Emergency Management 

Reform Act of 2006, to address many of the disaster housing shortfalls 

identified in the aftermath of Hurricane Katrina. 

5 A Performance Review of FEMA’s Disaster Management Activities in Response to Hurricane Katrina, OIG-06-32,

dated March 2006. 6

 A strike team is an inter-agency, multi-disciplinary team of engineers, planners, data analysts and building code / 

regulatory specialists who work closely with local government to deliver housing solutions. The teams also include 

representatives from federal agencies such as HUD, SBA, USDA, and the U.S. Army Corps of Engineers as well as state 

and local representatives as appropriate.

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 8 
Recommendations 

We recommend that the Administrator, Federal Emergency Management 

Agency: 

Recommendation #1: Expedite the completion of the National Disaster 

Housing Strategy and develop, implement, test, and exercise a housing plan 

for meeting the needs of individuals displaced by catastrophic disasters. 

Recommendation #2: Develop a command and control structure over 

housing decisions that clearly defines all roles and responsibilities and 

identifies the chain of command needed to ensure timely decision-making. 

Communicating and Coordinating with State and Local Governments 

and Other Organizations 

Better communication and coordination by FEMA with state and local 

governments, other agencies, and volunteer organizations regarding the 

eligibility criteria for housing assistance may have (1) eliminated the need to 

provide essential, but temporary housing assistance for extended periods of 

time, and (2) resulted in identifying ineligible applicants who were housed for 

extended periods of time. In addition, coordination with these governments, 

other federal agencies, and volunteer organizations could result in improved 

methods for identification of disaster victims and avoid duplication of 

benefits. 

Communication with State and Local Governments 

Meeting the immediate and longer-term housing needs of individuals 

impacted by the Gulf Coast hurricanes required an unprecedented “national” 

response and extensive communication with state and local governments. In 

the past, the American Red Cross and other volunteer organizations met the 

immediate sheltering needs of those requiring assistance as a result of a major 

disaster declaration. FEMA assisted those individuals requiring additional 

longer-term housing assistance. However, hurricanes Katrina and Rita 

destroyed or made uninhabitable thousands of properties, made it impossible 

for the victims to return to their homes, and created additional sheltering 

requirements beyond what has ever been experienced in the past. Better 

communication between FEMA and state and local governments regarding 

how to best meet and pay for short- and longer-term housing would have 

made it easier for disaster victims to transition from short-term essential 

housing assistance to longer-term assistance. 

Public Assistance Program funding for meeting immediate but temporary 

sheltering needs (hotels, motels, and apartments) is provided to the states 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 9 
under the authority of Section 403 of the Stafford Act (Essential Assistance). 

Longer-term assistance is authorized under Section 408 of the Stafford Act 

(Federal Assistance to Individuals and Households 42 USC § 5174) with 

payments made by FEMA going directly to individuals or landlords, generally 

for a period of up to 18 months. 

To provide a more permanent type of housing to disaster victims in hotels and 

motels, several states rented apartments under their Section 403 authority. 

However, when it became apparent that longer-term housing solutions were 

needed and the states were using Section 403 assistance to meet these 

longer-term needs, FEMA issued disaster specific guidance for hurricanes 

Katrina and Rita on November 14, 2005. This guidance established FEMA, 

state, and local procedures for transitioning victims from Section 403 to 

Section 408 assistance. Working with states and local governments, FEMA 

attempted to contact evacuees, outline their responsibilities and options, and 

register those applicants who had not yet registered for Section 408 assistance. 

While FEMA hoped to have this process completed by December 1, 2005, it 

had not received enough information from the states to identify all individuals 

receiving state assistance under Section 403, and in January 2006, FEMA 

again requested the states to provide data in a specified format. 

Data received from the states were not always transmitted in the required 

format or were missing critical data required to accomplish the applicant 

transition to Section 408 assistance. FEMA’s review of data submitted by the 

states as of February 2006 showed the following: 

• 63% of apartment leases had no end date, 

• 28% did not include the phone number of the landlord, 

• 16% did not include the landlord’s name, 

• 49% did not have a street address for the rental property, and 

• 4% had no information as to how to contact the landlord. 

Additional disaster specific guidance was issued on March 26, 2006. The 

guidance contained significantly more detailed requirements for the transition 

of applicants still being housed and funded under Section 403 assistance. 

Some transition delays, such as legal actions or applicants’ refusals to vacate, 

were out of FEMA’s control. However, the need for clear guidance, and 

timely coordination and communication between FEMA and state and local 

officials resulted in the extended use of Section 403 funding and in possible 

housing of ineligible applicants for extended periods of time. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Coordination with Other Agencies 

Beyond coordinating and communicating with state and local governments, 

working with other organizations and agencies could help expedite the process 

of validating disaster victims as legitimate evacuees and potentially avoid 

duplication of benefits. For example, other organizations and agencies 

include the American Red Cross, HUD, and staff in FEMA’s Public 

Assistance and Individual Assistance Programs. 

Since there was no single system that tracked individuals receiving housing 

assistance from FEMA and other organizations and agencies, state officials 

said that authorization codes that validated the evacuees’ eligibility could have 

been assigned prior to providing the evacuees temporary housing. According 

to FEMA, an authorization code would be provided at the time of registration 

to eligible applicants to be used to obtain an Individuals and Households 

Program (IHP) subsidized hotel/motel room for up to 7 calendar days. This 

period of assistance can be extended if necessary. Assigning these codes 

would allow FEMA to identify evacuees eligible for Section 408 assistance, 

and provide a more reliable basis in which hotels and motels can validate that 

only eligible applicants receive IHP-subsidized rooms to prevent duplication 

of benefits. 

At the time of our review, FEMA was formulating a recovery strategy that, 

among other things, calls for a unique authorization code to be assigned to 

applicants to validate their eligibility for transitional sheltering. FEMA plans 

to assign authorization codes only for individuals/households that have 

registered for FEMA assistance and have been verified through FEMA’s 

identity verification process. 

Recommendations 

We recommend that the Administrator, Federal Emergency Management 

Agency: 

Recommendation #3: Develop policies, procedures, and guidelines that 

address roles and responsibilities of FEMA and state and local governments 

articulating how housing needs of victims will be met in catastrophic events. 

Recommendation #4: Finalize and implement its strategy for developing a 

system that authorizes eligible applicants to obtain an IHP-subsidized 

hotel/motel room for temporary sheltering. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Planning, Managing, and Monitoring Acquisitions 

FEMA needs to improve how it plans, manages, and monitors disaster 

housing acquisitions. Specifically, FEMA needs to (1) develop a formal 

acquisition planning process, including standby contracts, to meet transitional 

housing needs after catastrophic disasters; (2) base contract awards, to the 

extent possible, on full and open competition to assure reasonable prices; and 

(3) provide the resources necessary to monitor contractor performance. 

Pre-Disaster Acquisition Planning 

FEMA did not have a formal acquisition planning strategy for the majority of 

transitional housing contracts awarded after Hurricane Katrina. While the 

Federal Acquisition Regulation (FAR) requires agencies to perform 

acquisition planning and conduct market research to the maximum extent 

practicable, the Homeland Security Acquisition Manual and the FAR do not 

require formal plans for emergency acquisitions.7 However, FEMA’s core 

mission is to respond to emergencies, and on a recurring basis, procure 

emergency supplies and equipment such as transitional housing units. 

Therefore, acquisition planning represents a sound business practice FEMA 

should follow for these types of procurements. The unpredictable nature of 

emergency operations could limit FEMA’s ability to select specific sources in 

advance of a disaster. However, advance planning could: 

• Lay out source selection procedures for each type of procurement; 

• Identify prospective sources of supplies or services, including sources 

identifiable through government-wide and industry association 

databases using market survey approaches; 

• Establish communication systems and processes and publicize them so 

that prospective sources know how to contact FEMA procurement 

personnel; 

• Delineate how competition will be sought, promoted, and sustained 

during and after emergency operations; 

• Describe how Stafford Act requirements for preferences of firms 

affected by the disaster will be met; 

7

 Emergency acquisitions occur when the need for the supplies or services is of such an unusual and compelling urgency 

that the government would be seriously injured if the supplies or services were not immediately acquired. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 12 
• Establish within DHS an assessment process to monitor planning 

efforts for disaster-related procurement needs; and 

• Provide adequate funding devoted to acquisition oversight in order to 

help prevent fraud, waste, and abuse in disaster contracts. 

At the time of our review, FEMA had no apparent source selection process in 

place or standard templates with contract specifications for transitional 

housing acquisitions, even though these products were procured on a regular 

basis. For example, while some large contracts were awarded to 

well-established leaders in the industry, other large contracts were awarded to 

firms with little or no housing experience. 

FEMA purchased over 27,000 travel trailers “off the lot” from 300 local firms 

in its effort to provide temporary housing to victims quickly. While in this 

case the immediate need for housing overshadowed the need for detailed 

planning, FEMA either did not identify minimum government specifications 

or requirements for “off the lot” purchases, or did not clearly state the 

government's minimum needs. For example, a number of procurements did 

not identify minimum government requirements other than the vendor 

providing travel trailer vehicle identification numbers. In other purchases, the 

only specifications listed were, “Must have furniture, AC/Heat and 

Microwaves (basic amenities only)” and “No toy haulers, 5th wheels or pop 

ups.” With no government specifications or specifications that were too 

broad, vendors could provide trailers that may or may not meet the minimum 

needs of evacuees occupying those travel trailers, e.g., units with or without 

bathroom, beds, dinettes, refrigeration, electrical outlets, water heaters, 

ranges, etc. 

In addition to travel trailers, FEMA purchased 24,967 mobile homes at a cost 

of $852 million and 1,755 modular homes at a cost of $52.4 million in 

response to the transitional housing needs of evacuees. FEMA had no plans 

for how the homes would be used before they were purchased. Due to the 

large number of homes purchased and the need to prepare sites before 

distributing the homes, FEMA issued a mission assignment to the United 

States Forest Service to assist with setting up four emergency housing storage 

sites in Hope, Arkansas; Red River Army Depot in Texarkana, Texas; Purvis, 

Mississippi; and Baton Rouge, Louisiana. As of July 2006, there were 

approximately 12,870 mobiles homes and 600 modular homes staged at 

emergency housing sites waiting to be used, refurbished, or sold. 

Travel trailers, mobile homes, and modular homes were purchased that were 

not needed or used. As part of its future planning process, FEMA needs to 

consider acquisition strategies that (1) meet emergent transitional housing 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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needs, (2) result in obtaining housing units that can be stored for extended 

periods if not in use, and (3) consider where to store unused housing units. 

We previously reported that modular homes deteriorated because they were 

not designed to be stored for long periods. We recommended that FEMA 

develop written policies and procedures that address modular home 

acquisition planning to ensure that units acquired are designed to be stored 

and that adequate storage locations have been identified in advance of a 

disaster.8

 Similar planning for all types of transitional housing is needed to 

ensure that emergency and transitional needs are met while at the same time 

considering the costs to develop or acquire housing sites, and providing sites 

to store returned or unused units. 

Table 1 shows per unit costs developed by FEMA to deploy mobile homes 

and travel trailers to private, commercial, and group sites. The costs reflect an 

18-month period of time and include the cost of the unit, hauling and 

installing fees, pad leasing fees for units in commercial sites, and the cost for 

developing sites when the unit is placed in a group site. This information is a 

good step in making strategic decisions in future disasters. 

Table 1. Mobile Home and Travel Trailer Per Unit Costs Breakdown 

Mobile Home and Travel Trailer Per Unit Costs Breakdown 

$51,455 

$43,455 

$17,558 

$26,558 

$61,970 

$69,970 

$29,348 

$38,348 

$105,770 

$113,770 

$74,948 

$83,948 

Mobile Homes 

(Manufactured) 

Mobile Homes (Off 

the Lot) 

Travel Trailers 

(Manufactured) 

Travel Trailers (Off 

the Lot) 

Private Sites 

Commercial Sites 

Group Sites 

Source: FEMA 

8 Management Advisory Report on the Condition, Losses, and Possible Uses of FEMA Modular Housing, OIG-07-03, 

dated October 18, 2006. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Competition in Contracts and Price Reasonableness 

In the aftermath of Hurricane Katrina, FEMA did not compete many of its 

contracts under full and open competition and did not adequately document its 

rationale for sole source selections. This created the appearance of bias or 

favoritism. As a result, FEMA had limited assurance that the prices it paid for 

goods and services were reasonable. 

After a major disaster, government agencies can award contracts under 

expedited contracting methods as authorized by FAR. In response to 

Hurricane Katrina, DHS/FEMA awarded approximately 3,400 contracts worth 

approximately $5.3 billion to provide a timely response to victims’ needs. 

More than 1,000 of the contracts were valued in excess of $500,000, but less 

than half were awarded under full and open competition. We are currently 

reviewing the terms and conditions of several contracts over $500,000 and 

other Offices of Inspector General (OIGs) are doing the same. In addition, we 

are conducting reviews of invoices, focusing on high-risk contracts. 

Shortly after Hurricane Katrina struck, FEMA awarded four major Individual 

Assistance contracts on a sole source basis for technical assistance in the gulf 

region. These contracts primarily involved the installation, operation, 

maintenance, and deactivation of housing facilities. We reviewed the source 

selection process for each of the major Individual Assistance Technical 

Assistance Contractors, but could not find complete records to determine how 

these firms were selected. While the four contractors were among the top 

50 construction contractors in the country9

 and technically qualified to 

perform the work, FEMA did not provide sufficient documentation regarding 

the process used to select these firms over other highly rated firms. Of the 

companies selected by FEMA, one ranked first, a second ranked fourth, 

another ranked fifteenth, and the fourth ranked fiftieth. 

FEMA re-competed the contracts and made awards to six large contractors 

shortly after September 30, 2006. FEMA also awarded 36 contracts, mostly 

to local and small gulf region businesses, to perform maintenance and 

deactivation work previously performed by the large contractors. Because the 

contract period for the four large contracts ended on September 30, 2006, 

FEMA also issued a Request for Proposal to the 36 maintenance and 

deactivation contractors to haul and install trailers and mobile homes in 

Louisiana and Mississippi. Nineteen of these contractors received awards for 

haul and install; 14 for Louisiana were awarded by September 26, 2006, and 5 

for Mississippi were awarded by October 17, 2006. 

9

 According to Engineering News Record magazine. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 15 
We conducted a review of the 36 Maintenance and Deactivation Contractors 

and issued a report, FEMA’s Award of 36 Trailer Maintenance and 

Deactivation Contracts, OIG-07-36 in March 2007. We reported that overall, 

FEMA treated bidders fairly during the bidding process. However, 

contracting officials did not properly assess the wide range of prices proposed 

by bidders. This exposed FEMA to the risk of paying too much for contract 

line items and not paying enough to ensure proper performance. 

FEMA said it made use of “limited competition” procedures in awarding 

contracts in response to Hurricane Katrina. FEMA defined “limited 

competition” as calculating a “reasonable” unit price range and making 

awards to those contractors who were known to FEMA and who provided 

quotes within that range. The term “limited competition” allows agencies to 

obtain competition “to the maximum extent practicable” for urgent and 

compelling reasons, although it is not a process recognized by the FAR. It 

gave FEMA a means of ensuring contracts were awarded with unit prices 

determined to be reasonable. However, the lack of objective evaluation 

criteria for determining which firms received smaller contracts and which 

firms received significantly larger contracts provided a basis for other 

non-selected contractors to assert bias or favoritism in the award process. 

To foster competition to the maximum extent possible, acquisition plans 

should consider the FAR requirement to specify company size standards in 

solicitations so that offerors can appropriately represent themselves as small 

or large businesses. To the extent possible, FEMA acquisition plans should 

anticipate all factors and significant subfactors that will affect contract award 

and their relative importance so that they can be specified clearly in the 

solicitation. In addition, the plans should use public information strategies to 

identify FEMA procurement points of contact and proposal evaluation criteria 

for major products. By having strategies that draw on state economic 

development offices, chambers of commerce, and industry associations, 

well-connected vendors would not have a significant advantage in contacting 

FEMA procurement personnel following a disaster and would not be 

perceived as receiving favored treatment in contract awards. Using this 

approach could have resulted in a more equitable distribution of contract 

awards and address the issues of fair and reasonable pricing. 

FEMA contract files contained little or no documentation regarding price 

reasonableness, although the FAR requires contracting officers to document 

the determination of fair and reasonable pricing. Many of the files contained 

no contract files checklist or record of supervisory review and approval. With 

the high volume of procurement activity within such a short period of time, 

documentation providing an explanation of the source selection process and 

the determinations of cost reasonableness was not prepared for many 

contracts. Use of streamlined documentation procedures to meet the FAR 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 16 
requirements would not have appreciably impeded FEMA’s contracting 

efforts to provide expedited assistance to the disaster victims. 

Contract Oversight and Monitoring 

Inadequate numbers of contracting staff and a shortage of experienced 

Contracting Officer’s Technical Representatives (COTRs) hampered FEMA’s 

ability to monitor Hurricane Katrina response contracts. Effective contract 

oversight and monitoring is necessary to ensure that the government gets what 

the contracts call for and that costs are controlled. 

As of March 13, 2006, FEMA awarded $5.3 billion in procurements to 

support the Gulf Coast recovery efforts. FEMA had approximately 

55 contracting personnel that were assisted by temporary deployments of 

General Services Administration contracting personnel. Based on this data 

and as depicted in Figure 3, we estimated that each of the contracting staff 

was responsible for an average of $163 million on an annualized basis, or 

more than 7 times the industry average. The workload overwhelmed the 

capacity of the contracting staff and made compliance with the requirements 

of various federal procurement regulations challenging to the staff. 

Figure 3. Comparison of Contracting Responsibilities 

$163,000,000 

$23,300,000 

FEMA 

Industry Average 

Contracting Responsibilities per Contracting Officer 

(Industry versus FEMA) 

Source: Center for Strategic Supply Research 

The shortage of trained and experienced staff to oversee and monitor contracts 

was evident: 

• FEMA officials said that in some instances, FEMA accepted delivery 

of trailers and mobile homes without inspecting them or holding 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 17 
 

contractors accountable. FEMA did not know the number of housing 

units that would be delivered on a given day and vehicle identification 

numbers were not reconciled with Bills of Lading.10 Consequently, 

there was little assurance that FEMA received what it had procured. 

• GAO reported that, in November 2005, FEMA’s contracts for 

installing temporary housing in 4 states had only 17 of the 27 required 

monitors.11 Our discussions with FEMA staff in Louisiana confirmed 

GAO’s conclusion that there were too few monitors/COTRs and 

identified other causes for insufficient contract monitoring including 

the following: 

1. COTRs rotation periods did not overlap, so the arriving COTRs 

were not sufficiently briefed by the departing COTRs, and 

2. Many of the COTRs were borrowed from other agencies and 

were not familiar with FEMA temporary housing contracts. 

In July 2006, FEMA officials said they hired Cadre of On-Call Response/ 

Recovery Employees to serve as COTRs for Gulf Coast recovery efforts; but 

the number of COTRs on staff was still insufficient to provide adequate 

contractor oversight. Because of this, some FEMA staff believed that the 

contractors were “running the show.” We are conducting a review of the four 

Individual Assistance Technical Assistance Contractors and plan to issue a 

report on their performance later this fiscal year. 

• The HAC had responsibility for coordinating temporary housing 

throughout the affected area but did not communicate its activities to 

other FEMA field organizations. This contributed to problems with 

contract oversight in that the HAC requested contractors to perform 

additional work without COTR knowledge or contracting officer 

approval. As a result, neither the contracting officer nor the COTR 

were afforded the opportunity to approve of, document, or oversee and 

monitor the contractors’ work.12 

• Another indicator of the need for additional oversight was the number 

of rejected, temporary housing sites and related costs for group sites 

developed for travel trailers and mobile homes. As of April 2006, 

FEMA has spent over $14.2 million for 338 sites that were rejected for 

10 A document listing and acknowledging receipt of travel trailers and mobile homes delivered by/for a contractor. 11 Hurricane Katrina: Planning for and Management of Federal Disaster Recovery Contracts, GAO-06-622T, dated 

April 10, 2006. 12 FAR Part I, Subpart 1.601 (a) – Career Development, Contracting Authority, and Responsibility provides “contracts 

may be entered into and signed on behalf of the Government only by contracting officers.” 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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various reasons. Since poor contract planning, monitoring, and 

oversight may have contributed to these sites being rejected, we are 

reviewing nine sites that were rejected for various reasons, after an 

estimated total of $3.7 million was spent preparing the sites. We plan 

to issue a report later this fiscal year. 

FEMA is aggressively recruiting contracting officers and COTRs to augment 

its contract staff. It initially established a separate contracting office to handle 

procurement activity for the gulf region; however, that office is now rolled 

into FEMA’s procurement office under the Chief Acquisition Officer. These 

are important steps to provide additional oversight, controls, and support for 

Gulf Coast recovery operations and to better meet the procurement demands 

after future catastrophic disasters. 

Recommendations 

We recommend that the Administrator, Federal Emergency Management 

Agency: 

Recommendation #5: In coordination with the DHS Chief Procurement 

Officer, develop an acquisition strategy that (1) addresses housing needs, 

supplies, and services prior to disasters; (2) considers the effect on production 

capabilities and available on-site inventory; and (3) balances the capabilities 

of distributors, wholesalers, retailers, and manufacturers, and maximizes the 

use of them. 

Recommendation #6: Evaluate basic housing requirements occurring after 

catastrophic disasters, put in place contracts and infrastructure to respond to 

the needs of catastrophic disaster victims, and develop policies and procedures 

to re-compete contracts when expedited contracting methods are used 

immediately following a major disaster. 

Recommendation #7: Develop policies and procedures to ensure that 

procurement personnel properly maintain contract files as defined by the 

FAR, including documents that show the basis used to determine price 

reasonableness as well as documents regarding any other contracting 

decisions. 

Recommendation #8: Undertake the following actions: (1) determine the 

appropriate number of contracting professionals and experienced COTRs 

required to meet sheltering and transitional housing needs occurring after a 

catastrophic disaster, (2) continue to hire experienced contracting 

professionals to monitor and oversee housing contracts awarded in a disaster 

environment, (3) promulgate specific guidance emphasizing the authority and 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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responsibility of contracting officers and COTRs qualified to perform housing 

acquisitions, and (4) include provisions for the training of contracting officers 

and COTRs functioning in catastrophic disaster environments. 

FEMA Oversight of Leasing Sites 

Individual Assistance Technical Assistance Contractors negotiated leases for 

commercial travel trailer and mobile home park sites with little input from 

FEMA’s housing officials. As a result, FEMA had little control over the types 

of temporary sites leased or the amounts paid for the sites and, in several 

instances, contractor-leased sites were rejected for various reasons. Further, 

without explicit policies and procedures to govern the use of travel trailers in 

industrial and government sites, FEMA encountered accountability problems. 

• In Louisiana, sites were rejected because parish and city officials 

changed their minds, site owners withdrew their offers, environmental 

concerns prevented use of the sites, costs were too high, or the sites 

were not needed. Over $9 million was spent on rejected sites, and 

FEMA closed 114 commercial parks because FEMA’s contractors 

performed all negotiations for leases without any input from FEMA’s 

housing officials. Also, inexperienced COTRs contributed to the 

difficulty of monitoring contracts because they were not familiar with 

FEMA design requirements, programs, or regulations. 

• A FEMA initiative allowed the use of industrial sites to house workers 

who were victims, but also made these sites available to other victims 

as well. This was the first disaster that used sites for industrial 

purposes and the Department of Louisiana Economic Development 

was the first to implement the initiative. Since FEMA had no 

regulations and procedures to govern the initiative, accountability 

problems resulted and FEMA was uncertain that trailers were being 

used for the intended purposes. For example, one nursing home in 

Louisiana requested 15 trailers to house staff, but the trailers were 

never hooked up. FEMA finally recovered them months later as other 

victims waited for housing. 

• Another initiative known as exclusive use sites allowed installation of 

trailers to be used for critical employees of government agencies. The 

sites were established on government properties and were intended to 

house employees deemed essential to maintain health and safety, such 

as doctors, firefighters, and police. However, FEMA did not have 

policies and procedures in place to ensure the trailers were used as 

intended. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 20 
Recommendations 

We recommend that the Administrator, Federal Emergency Management 

Agency: 

Recommendation #9: Develop explicit criteria for what a temporary housing 

site should include, as well as criteria for how appropriate sites are selected 

for development. 

Recommendation #10: Institute an oversight program that ensures 

Individual Assistance Technical Assistance Contractors identify and select 

eligible temporary housing sites for disaster victims. 

Recommendation #11: Work with state and local governments to develop 

policies, plans, procedures, and processes to identify and set up group and 

individual temporary housing sites that will accommodate specific or special 

needs of victims prior to disasters. 

Manufacturers’ Warranties 

FEMA did not take advantage of manufacturer warranties on travel trailers 

and mobile homes it acquired. Instead, Individual Assistance Technical 

Assistance Contractors and Maintenance and Deactivation Contractors made 

repairs that were covered by warranties. As a result, FEMA paid for repairs 

that should have been done by the manufacturer at no cost to the government. 

In order to take advantage of and enforce warranties, FEMA needs to: 

• Establish and implement policies and procedures that require taking 

advantage of warranties on travel trailers and mobile homes, as well as 

any major item procured; 

• Identify repair and maintenance costs to provide a basis for taking 

advantage of the warranties; and 

• Recover funds from Individual Assistance Technical Assistance 

Contractors and Maintenance and Deactivation Contractors for work 

that should have been covered by warranties. 

We could not quantify the savings that could have accrued as a result of 

claims against manufacturers’ warranties because FEMA does not track 

claims or pursue them; its contractors performed most of the maintenance and 

repair work. In addition, FEMA’s contractors had little or no incentive to 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 21 
claim manufacturers’ warranties because they were paid by FEMA for all 

work they performed regardless of the existence of warranties. 

FEMA contracting officials agreed that travel trailer and mobile home defects 

identified at the time of delivery to FEMA’s staging areas were warranty 

items that should have been rectified by the manufacturers. FEMA logistics 

officials said that in many cases, defects were corrected at FEMA staging 

areas prior to FEMA acceptance of the units. However, in many other cases, 

FEMA lost control of the units when it allowed the contractors to move 

trailers to contractor-operated forward staging areas. FEMA officials said that 

the contractors should have sought reimbursement for warranty work from the 

manufacturers; however, they had no knowledge of whether this was done. 

Without this knowledge, FEMA had no basis to question bills submitted by its 

contractors. 

FEMA officials also said they had little knowledge of what trailers and mobile 

homes were received in the forward staging areas and what the Individual 

Assistance Technical Assistance Contractors were doing. We were told and 

confirmed that FEMA contractors cannibalized travel trailers. Parts were 

removed from some of the damaged trailers and used on other trailers to make 

them mission capable because replacement parts were not readily available 

after the disaster. Although FEMA’s contracts required that it be informed of 

deficient trailers upon receipt, FEMA officials said that the contractors did not 

report the damaged trailers and trailers with missing parts, nor did FEMA 

inspect the trailers at forward staging areas. As a result, non-mission capable 

trailers were listed in FEMA’s inventory as mission capable, and FEMA had 

little visibility over what work may have been eligible under the 

manufacturers’ warranties. Further, the decision to cannibalize damaged 

trailers may have voided the manufacturers’ warranties. The issue of 

cannibalization of travel trailers is more fully discussed in the OIG report, 

Cannibalization of Travel Trailers by Bechtel, GC-HQ-06-35, dated 

April 21, 2006. 

Recommendations 

We recommend that the Administrator, Federal Emergency Management 

Agency: 

Recommendation #12: Develop policies and procedures requiring that (1) all 

travel trailers and mobile homes are properly inspected/accepted upon receipt, 

(2) inspection/acceptance documentation is retained, and (3) maintenance and 

repair costs, including the costs of parts claimed by contractors, are monitored 

and warranties enforced. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 22 
Recommendation #13: For future disasters, determine whether Individual 

Assistance Technical Assistance Contractors made repairs that should have 

been reported to the manufacturers at the time of acceptance/inspection and, 

whenever applicable, covered under the implied warranty clause, and seek 

reimbursement from the contractors or manufacturers as appropriate. 

Alternatives To Status Quo 

The Stafford Act and the National Response Plan require that FEMA address 

housing needs when states are unable to meet these needs after a disaster. 

Historically, FEMA has successfully met the short- and longer-term 

temporary housing needs (shelters and transitional housing) of the victims of 

most presidentially-declared disasters. However, as a result of the Gulf Coast 

hurricanes, FEMA has not only become the focal point for meeting the 

sheltering and transitional housing needs of disaster victims, but also the focal 

point for permanent housing solutions for these victims. 

FEMA’s lessons learned report on the federal response to Hurricane Katrina 

pointed out that FEMA neither identified available sites and available land to 

meet temporary and long-term housing needs before the disaster nor took 

advantage of housing resources available from other federal agencies after the 

disaster. Reports from Congress and the Executive Branch call for the federal 

government to develop a comprehensive and flexible housing strategy that 

requires the involvement of numerous federal agencies to meet the short-term, 

longer-term, and permanent housing needs of disaster victims. 

Several alternatives to the status quo should be considered before the next 

catastrophic disaster inasmuch as these alternatives may be a more cost 

effective way to meet the needs of disaster victims and provide a more 

expeditious way of returning them to a more normal way of life. Alternatives 

to FEMA being the primary provider of long-term housing include having 

(1) the states assume housing responsibility, (2) HUD assume federal 

coordination of the housing function, (3) FEMA use permanent types of 

housing in lieu of travel trailers and mobile homes, and (4) FEMA make lump 

sum payouts and rely on disaster victims to find longer term housing that 

meets their specific needs. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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States Assume Housing Responsibilities 

A White House report13 issued after Hurricane Katrina stated that state and 

local governments in areas most affected by the Gulf Coast hurricanes were 

not adequately prepared to provide housing assistance. States lacked the 

necessary information about temporary housing and had not compiled a 

comprehensive database on shelters. According to the White House report, 

temporary housing in Mississippi was provided in numbers exceeding any 

previous effort, but this success was obscured by the need to move victims 

from shelters to other types of housing within an acceptable period of time. 

The White House concluded that new housing methodologies needed to be 

examined and implemented before the next catastrophic disaster. 

Officials in Florida, Louisiana, and Mississippi said that they continually 

attempt to identify available housing, but after a major disaster event, these 

efforts are negated by federal intervention in providing housing. Arguably, 

housing needs are best determined by states and local governments. However, 

as noted in the White House report, states and local governments do not 

adequately identify and carry through on meeting these needs in times of 

catastrophic events. 

One way FEMA can assist the states in being prepared to meet the long-term 

housing needs of catastrophic disaster victims is to request from Congress 

additional Emergency Management Performance Grant funding with specific 

terms and conditions in the grants that require development of a catastrophic 

housing strategy and plan to meet the needs of disaster victims. For 2008, 

states received about $210 million for payroll and training costs related to 

preparedness. The National Emergency Management Association, which 

represents all state emergency managers, has continuously sought increases in 

Emergency Management Performance Grant funding to enhance the states’ 

preparedness infrastructure. Planning for the housing needs of disaster 

victims is a critical element of preparedness and could be a candidate for 

additional grant program funding. 

HUD Assumes Federal Coordination of the Housing Function 

The White House, Congress, and some FEMA officials believe the housing 

program should be transferred to HUD because housing is that agency’s 

specialty. However, many FEMA officials believe this is not a viable solution 

because HUD may not be sufficiently funded to accomplish this mission. 

Prior to the establishment of FEMA in 1979, HUD’s Federal Disaster 

Assistance Administration was one of several federal agencies meeting the 

housing needs of disaster victims. 

13 The Federal Response to Hurricane Katrina Lessons Learned, February 2006. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 24 
The Department of Homeland Security Appropriation Act, 2007 (Public Law 

109-295) requires that FEMA be overhauled to improve the Nation’s ability to 

respond to catastrophic events. The Public Law introduced a number of 

amendments to the Stafford Act including Section 682, National Disaster 

Recovery Strategy. This section directs the FEMA Administrator, in 

coordination with the Secretary of HUD and numerous other federal agencies 

and non-governmental organizations, to develop, coordinate, and maintain a 

National Disaster Recovery Strategy. This would include a NDHS to serve as 

a guide to recovery efforts after major disasters and emergencies. To be 

effective, the strategy must clearly define the roles, programs, and 

responsibilities of those tasked with providing housing for disaster victims and 

identify the most efficient and cost effective federal programs, to meet 

short- and long-term housing needs. 

The Public Law also requires that the National Response Plan and its annexes 

be reviewed to ensure that a unified system of strategic and operational plans 

exist to respond effectively to catastrophic events. Mass evacuation planning 

should include short- and long-term sheltering and accommodations, and 

should consider (1) relocating and transporting evacuees, (2) identifying 

populations with special needs, (3) keeping families together, 

(4) expeditiously locating missing children, and (5) establishing policies and 

procedures for pets. 

Consideration should be given to having HUD coordinate the federal response 

to disaster housing issues. The NDHS should include the roles, programs, and 

responsibilities of applicable federal agencies providing housing assistance, as 

well as those of states, local governments, and non-governmental 

organizations such as the American Red Cross. A draft of this document is 

currently in the review process. The strategy should detail how 

responsibilities will be shared, address funding issues, and address other 

matters concerning the cooperative effort to provide housing assistance 

needed as a result of a major disaster. For example, the strategy should 

consider: 

• Mechanisms to ensure that housing is provided where employment 

and other support resources are available, 

• Needs of low income victims, 

• Planning for operation of clusters of housing, and 

• Delineating what additional authorities may be needed to effectively 

fulfill the housing mission. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Permanent Housing Options 

Lessons learned from the Gulf Coast hurricanes also showed that the 

traditional travel trailer and mobile home program was neither the most 

efficient and cost effective means of providing temporary housing for 

catastrophic disaster victims nor the best method to facilitate long-term 

recovery from the disaster. In the aftermath of Hurricane Katrina, FEMA met 

short-term housing needs with travel trailers and longer-term needs with 

mobile homes, but other alternatives were needed to meet the permanent 

housing needs of disaster victims. 

Recognizing the extensive housing challenges presented by Hurricane 

Katrina, as well as limitations within the Stafford Act, Congress appropriated 

$400 million14 to DHS to support alternative housing pilot programs. 

Congress provided that: 

“Notwithstanding any other provision of law, the Secretary of 

Homeland Security shall consider eligible under the Federal 

Emergency Management Agency IA Program the costs sufficient 

for alternative housing pilot programs in the areas hardest hit 

by Hurricane Katrina and other hurricanes of the 2005 season.” 

FEMA’s Alternative Housing Pilot Program made funding available to Texas, 

Mississippi, Alabama, Louisiana, and Florida based on proposals that: 

• Represented innovative approaches to housing, 

• Represented safe housing solutions, 

• Were cost effective, and 

• Could be delivered in an expedient manner. 

We reviewed the decisions made in establishing the competitive grant 

program, as well as the process used to review each proposal. The Alternative 

Housing Pilot Program is more fully discussed in the OIG report, Evaluation 

of the Federal Emergency Management Agency’s Alternative Housing Pilot 

Program, OIG-07-39, dated April 20, 2007. 

Should FEMA continue to administer long-term housing solutions after future 

catastrophic disasters, it needs to consider modular homes, as shown below in 

Figure 4, as a more viable method of helping disaster victims in their recovery 

process rather than travel trailers and mobile homes. According to FEMA 

officials, innovations in the building industry allow builders to construct 

permanent housing following local codes, including construction in mobile 

14 Public Law 109-234, FY 2006 Emergency Supplemental Appropriation, and Conference Committee Report entitled, 

“Report 109-494-Making Emergency Supplemental Appropriations for the Fiscal Year Ending September 30, 2006, and 

For Other Purposes.” 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 26 
 Source: Robbie Caponetto/Cottage Living Magazine, 2007 

Since these units are permanent, refinancing could be sought by the victims to 

make these units their permanent residences. This would expedite their 

recovery and reduce the long periods of time some victims have had to cope 

with inadequate housing. FEMA officials believe these structures can be put 

into place in approximately the same time it takes to purchase, transport, and 

set up a trailer or mobile home, and that any additional cost would be 

minimal. FEMA has contracted with the National Institute for Building 

Sciences to provide various services related to housing issues. Institute 

officials told us they will assist FEMA in developing criteria for temporary 

housing, evaluating different alternatives to housing, and evaluating the cost 

effectiveness of these alternatives. 

Lump Sum Settlement 

Another option may be to provide the disaster victim a lump sum settlement, 

no greater than a pre-determined cap, to be used for finding permanent 

housing. This would be based on consideration of all costs associated with the 

travel trailer or mobile home set up, maintenance, and the anticipated amount 

of time that the victim would be temporarily housed. As previously identified, 

mobile homes and travel trailers can range from $17,558 to $113,770 

depending on the type and where it is installed. The primary advantage to this 

home parks. This also includes floodplain areas, in which a waiver or 

amendment of restrictions is required as housing units may be placed on stilts 

or raised above the flood level. 

 Figure 4: Modular Home, also referred to as a Katrina Cottage

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 27 
program is that it would be a one-time expenditure, paid to only those victims 

who have been screened and qualified, and would disqualify the applicant for 

any other housing assistance under a particular declaration. This program 

would require maximum oversight and a pre-qualification process with 

adequate controls to ensure that funds were authorized and issued to those 

applicants who passed all the qualification requirements. 

Considerations For Congress 

The results of this review and the alternatives to the status quo discussed 

above present matters that should be considered by Congress because the 

actions recommended below exceed FEMA’s authority, or require that 

Congress clarify or delineate FEMA’s authority in exercising its 

responsibilities. 

1. Authorize increased Emergency Management Performance Grant Program 

funding to allow states in high-risk areas to identify housing opportunities 

and to obtain temporary housing for victims of a catastrophic event. 

2. Determine whether HUD's mission is compatible with disaster response, 

including an assessment of capabilities, staff experience in disaster 

scenarios, and organizational capability to address catastrophic events. As 

required in Public Law 109-295, consideration needs to be given to 

mechanisms for coordination among all federal agencies that have a stake 

in housing issues and whether HUD is in a position to accomplish such an 

effort more effectively than FEMA. 

3. Evaluate a program that provides victims with a "one-time" cash 

settlement based on historical costs of acquiring, providing, maintaining, 

repairing, and administering transitional housing. This option would 

require extensive pre-screening to avoid fraud, but also would have the 

advantage of reducing FEMA's financial exposure for housing victims 

during the recovery period and hasten recovery. 

Management Comments and OIG Analysis 

FEMA provided written comments on the draft of this report (See 

Appendix C). FEMA generally concurred with 12 of the 13 recommendations 

in this report. FEMA did not concur with recommendation #13, but provided 

an acceptable alternative solution. The following summarizes FEMA’s 

responses to each recommendation, our analysis of FEMA’s responses, and 

the status of each recommendation. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 28 
Recommendation #1: Expedite the completion of the National Disaster 

Housing Strategy and develop, implement, test, and exercise a housing plan 

for meeting the needs of individuals displaced by catastrophic disasters. 

FEMA concurs with this recommendation. In response to this 

recommendation, FEMA said the NDHS will convey a broad national strategy 

that defines the roles, programs, and authorities for public, private, and nonprofit entities with responsibilities in disaster housing. The NDHS will 

highlight the forms of assistance that will be available to individuals, 

households, and communities in the event of a disaster. The NDHS will also 

include a requirement to develop a planning process that will work at the 

community, state, and federal level, and can be applied to the entire spectrum 

of potential events, and potential magnitudes, including those of catastrophic 

proportions. The disaster plan will guide the implementation, testing, and 

exercising of FEMA’s capabilities to ensure readiness to respond to and meet 

the needs of individuals displaced by disasters. 

OIG Analysis: To be responsive to recommendations, agency officials should 

provide target completion dates for implementing their planned actions. 

Although FEMA did not include a target completion date for the NDHS, 

FEMA officials have testified to Congress that the NDHS should be issued 

soon. Therefore, we consider FEMA’s planned action responsive to the 

recommendation. The recommendation is resolved and open pending 

FEMA’s issuance and our review of the NDHS and FEMA’s implementation 

and testing of its housing plan. 

Recommendation #2: Develop a command and control structure over 

housing decisions that clearly defines all roles and responsibilities and 

identifies the chain of command needed to ensure timely decision-making. 

FEMA concurs with this recommendation. FEMA said it is confident that the 

NDHS will sufficiently clarify roles and responsibilities for housing disaster 

victims for the full continuum of the disaster housing process. 

OIG Analysis: Because FEMA plans to issue the NDHS soon; we consider 

FEMA’s planned action responsive to the recommendation. Therefore, the 

recommendation is resolved and open pending FEMA’s issuance and our 

review of the NDHS. 

Recommendation #3: Develop policies, procedures, and guidelines that 

address roles and responsibilities of FEMA, and state and local governments 

articulating how housing needs of victims will be met in catastrophic events. 

FEMA concurs with this recommendation. FEMA said it has taken several 

steps to address this issue including issuing the Emergency Support Function 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 29 
(ESF) #6 annex to the National Response Framework, published in 

January 2008. Additionally, FEMA and the American Red Cross have 

worked with their ESF #6 partners at the national level to revise the ESF #6 

standard operating procedures. This process has been valuable in identifying 

and defining authorities, roles, and capabilities of all ESF #6 agencies. 

Also, the NDHS will convey national guidance and a vision for providing 

disaster housing assistance. It will define the roles, programs, authorities, and 

responsibilities of all entities, detailing shared responsibilities and 

emphasizing the cooperative efforts required to provide disaster housing 

assistance. FEMA also published its Mass Sheltering and Housing Assistance 

recovery strategy, which provides guidance and protocols for providing 

sheltering and housing assistance. Finally, FEMA developed a Transitional 

Sheltering Protocol, which can be implemented when large numbers of 

evacuees are housed in congregate shelters and are not able to return to their 

homes for extended periods of time. 

OIG Analysis: We consider FEMA’s planned action responsive to the 

recommendation. Therefore, the recommendation is resolved and open 

pending FEMA’s issuance and our review of the NDHS. 

Recommendation #4: Finalize and implement its strategy for developing a 

system that authorizes eligible applicants to obtain an IHP-subsidized 

hotel/motel room for temporary sheltering. 

FEMA concurs with the recommendation. FEMA drafted its Lodging 

Expense Reimbursement policy that will establish a national standard for 

evaluating and processing requests from individuals and households for 

disaster related lodging expenses and will apply reimbursements against the 

individual household’s IHP financial limit. 

FEMA has also drafted a Transitional Sheltering (Emergency Lodging 

Assistance) policy that is designed for use in post-disaster situations where 

states are hosting large numbers of evacuees in congregate shelters, who will 

not be able to return to their homes for an indeterminate period of time. Both 

of these draft policies are in the vetting stage and FEMA anticipates that they 

will be issued by mid-summer 2008. 

OIG Analysis: We consider FEMA’s planned action responsive to the 

recommendation. Therefore, the recommendation is resolved and open 

pending FEMA’s issuance and our review of the Lodging Expense 

Reimbursement and Transitional Sheltering (Emergency Lodging Assistance) 

policies. 

Recommendation #5: In coordination with the DHS Chief Procurement 

Officer, develop an acquisition strategy that (1) addresses housing needs, 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 30 
supplies, and services prior to disasters; (2) considers the effect on production 

capabilities and available on-site inventory; and (3) balances the capabilities 

of distributors, wholesalers, retailers, and manufacturers, and maximizes the 

use of them. 

FEMA concurs with this recommendation. FEMA said these factors are 

currently included in the acquisition strategy under the Individual Assistance 

Technical Assistance Contractors and, upon release of the NDHS, FEMA’s 

Office of Acquisition will coordinate with the IA Technical Assistance 

Contractors and the DHS Chief Procurement Officer, to develop a 

comprehensive acquisition strategy that addresses all planning elements 

outlined in the NDHS. 

OIG Analysis: We consider FEMA’s planned action responsive to the 

recommendation. Therefore, the recommendation is resolved and open 

pending FEMA’s issuance and our review of the NDHS and the new 

comprehensive acquisition strategy. 

Recommendation #6: Evaluate basic housing requirements occurring after 

catastrophic disasters, put in place contracts and infrastructure to respond to 

the needs of catastrophic disaster victims, and develop policies and procedures 

to re-compete contracts when expedited contracting methods are used 

immediately following a major disaster. 

FEMA concurs with this recommendation. In FEMA’s response, it said 

FEMA’s IA Technical Assistance Contract II contracts feature a competitive 

bidding process for each task order. The long-term acquisition strategy is 

further illustrated with the planning and procurement of the IA Technical 

Assistance Contract III contracts. These contracts will be a follow on to the 

IA Technical Assistance Contract II contracts incorporating lessons learned 

during both the IA Technical Assistance Contract I and II contracts. Upon 

release of the NDHS, FEMA’s Office of Acquisition will coordinate with the 

IA Technical Assistance Contractors and the DHS Chief Procurement Officer, 

to develop a comprehensive acquisition strategy that addresses all planning 

elements outlined in the NDHS. This revised strategy will address immediate 

and long-term contracts. 

OIG Analysis: We consider FEMA’s planned action responsive to the 

recommendation. Therefore, the recommendation is resolved and open 

pending FEMA’s issuance and our review of the NDHS and the new 

comprehensive acquisition strategy. 

Recommendation #7: Develop policies and procedures to ensure that 

procurement personnel properly maintain contract files as defined by the 

FAR, including documents that show the basis used to determine price 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 31 
reasonableness as well as documents regarding any other contracting 

decisions. 

FEMA concurs with this recommendation. FEMA said it will work to ensure 

that procurement personnel adhere to documentation requirements outlined in 

the FAR. 

OIG Analysis: Although FEMA concurs with the recommendation, its 

response does not include developing policies and procedures to properly 

maintain contract files. Therefore, we will consider the recommendation 

resolved, but it will remain open until FEMA institutes corrective action. 

Recommendation #8: Undertake the following actions: (1) determine the 

appropriate number of contracting professionals and experienced COTRs 

required to meet sheltering and transitional housing needs occurring after a 

catastrophic disaster, (2) continue to hire experienced contracting 

professionals to monitor and oversee housing contracts awarded in a disaster 

environment, (3) promulgate specific guidance emphasizing the authority and 

responsibility of contracting officers and COTRs qualified to perform housing 

acquisitions, and (4) include provisions for the training of contracting officers 

and COTRs functioning in catastrophic disaster environments. 

FEMA concurs with this recommendation. FEMA said it continues to focus 

on right-sizing contract oversight operations in the field and has increased its 

professional acquisition staff from approximately 35 to 118. FEMA agreed to 

develop additional specific guidance regarding the authority and responsibility 

of contracting officers and COTRs and agreed to provide additional 

procurement training to address catastrophic disasters. 

OIG Analysis: Although FEMA generally concurred with the 

recommendation, its response did not provide target completion dates for 

planned actions. Therefore, the recommendation is resolved and open 

pending completion and our review of additional specific guidance, and 

development and implementation of procurement training to address 

catastrophic disasters. 

Recommendation #9: Develop explicit criteria for what a temporary housing 

site should include, as well as criteria for how appropriate sites are selected 

for development. 

FEMA concurs with this recommendation. FEMA agrees with the need to 

develop explicit criteria that will govern the group site selection and 

construction process. FEMA is developing a policy document that will 

outline site identification considerations, such as cost and the proximity to 

services and the affected area. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina 

Page 32 
OIG Analysis: Although FEMA concurred with the recommendation, its 

response did not provide a target completion date for its planned action. 

Therefore, the recommendation is resolved and open pending completion of 

development of explicit criteria, and development and our review of the policy 

document. 

Recommendation #10: Institute an oversight program that ensures 

Individual Assistance Technical Assistance Contractors identify and select 

eligible temporary housing sites for disaster victims. 

FEMA concurs with this recommendation. FEMA responded that oversight 

currently exists through the Individual Assistance Branch of the Joint Field 

Office, which is responsible for identifying and selecting eligible temporary 

sites. The IA Technical Assistance Contractor supports the identification of 

eligible sites, but only with direct management by the JFO Individual 

Assistance Branch. 

OIG Analysis: We consider FEMA’s planned action responsive to the 

recommendation. Therefore, the recommendation is resolved and closed. 

Recommendation #11: Work with state and local governments to develop 

policies, plans, procedures, and processes to identify and set up group and 

individual temporary housing sites that will accommodate specific or special 

needs of victims prior to disasters. 

FEMA concurs with this recommendation. FEMA responded it is working 

closely with states, tribal governments, counties and independent 

municipalities on a Gap Analysis planning initiative that includes the predisaster identification of housing resources, including rental units and 

potential group site locations. This analysis will include special needs 

considerations as part of the planning process. 

OIG Analysis: Although FEMA concurred with the recommendation, its 

response did not provide a target completion date for its Gap Analysis 

planning document. Therefore, the recommendation is resolved and open 

pending completion of the planning document. 

Recommendation #12: Develop policies and procedures requiring that (1) all 

travel trailers and mobile homes are properly inspected/accepted upon receipt, 

(2) inspection/acceptance documentation is retained, and (3) maintenance and 

repair costs, including the costs of parts claimed by contractors, are monitored 

and warranties enforced. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 33 
FEMA concurs with this recommendation. FEMA responded it has 

implemented a stringent Quality Assurance/Quality Control program for the 

procurement of new temporary housing units. 

OIG Analysis: We consider FEMA’s action responsive to the 

recommendation. Therefore, the recommendation is resolved and open 

pending our receipt and review of documentation supporting the Quality 

Assurance/Quality Control program. 

Recommendation #13: Determine whether Individual Assistance Technical 

Assistance Contractors made repairs that should have been reported to the 

manufacturers at the time of acceptance/inspection and, whenever applicable, 

covered under the implied warranty clause; and seek reimbursement from the 

contractors or manufacturers as appropriate. 

FEMA does not concur with this recommendation. While FEMA agrees that 

repair requirements should have been reported to the manufacturers and 

covered by warranty, FEMA does not concur with the recommendation to 

seek, at this late date, reimbursement from Hurricane Katrina contractors or 

manufacturers for minor repairs performed by IA Technical Assistance 

Contractor personnel, believing that such an effort would be cost-prohibitive. 

However, to correct this problem in the future, FEMA has instituted a 

stringent Quality Assurance/Quality Control process that will identify and 

correct discrepancies prior to acceptance at the manufacturing facilities. At 

this time FEMA is completing 100% inspection of all newly procured units 

and requiring all discrepancies be corrected prior to acceptance. 

OIG Analysis: FEMA did not concur with the recommendation to seek 

reimbursement from contractors at this late date for repairs that should have 

been reported to the manufacturers and covered by warranty. We revised the 

recommendation to indicate that this should be implemented for future 

disasters. We accept FEMA’s alternative corrective action that the 

development of the Quality Assurance/Quality Control process should prevent 

this problem in the future. Therefore, the recommendation is resolved and 

open pending our receipt and review of documentation supporting the Quality 

Assurance/Quality Control program. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

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Appendix A 

Purpose, Scope, and Methodology 

Our objectives were to determine whether and to what extent FEMA 

(1) conducted pre-disaster planning for emergency sheltering and temporary 

housing; (2) complied with existing federal regulations and policies governing 

emergency housing assistance provided under the Robert T. Stafford Disaster 

Relief and Emergency Assistance Act, as amended; (3) managed and executed 

its pre- and post-landfall emergency sheltering and transitional housing 

mission; (4) effectively and efficiently met disaster evacuees housing needs; 

and, (5) developed and implemented disaster specific guidance and lessons 

learned to prepare for future major catastrophic disasters. 

We focused on FEMA’s housing assistance activities in Louisiana, 

Mississippi, Texas, Florida, and Alabama. We also considered potential 

alternatives to fulfilling FEMA’s housing mission. 

We analyzed disaster sheltering and temporary housing related plans, policies, 

procedures, and guidance established and maintained by FEMA/DHS, HUD, 

and state and local governments; and interviewed federal, state, non-profit, 

and private sector officials. 

Our interviews included officials from: 

• FEMA, DHS, Department of Health and Human Services, HUD, and 

the Homeland Security Institute; 

• State Emergency Managers and Planners in Alabama, Louisiana, 

Texas, Florida, and Mississippi; 

• FEMA Individual Assistance Technical Assistance Contractors in 

Alabama, Louisiana, and Mississippi; 

• Volunteer Agency Liaisons and Faith-Based Organizations; and 

• FEMA authorized case managers in Alabama, Missouri, Louisiana, 

Mississippi, and Texas. 

Fieldwork began in March 2006 and continued through January 2008. This 

review was conducted under the authority of the Inspector General Act of 

1978, as amended, and according to Quality Standards for Inspections issued 

by the President’s Council on Integrity and Efficiency. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 35 
 

 

 

 

 

Appendix B 

Event Decision Timeline 

Date Event Detail 

August 25, 2005 Landfall Katrina makes landfall in Florida as a Category 1 hurricane. 

August 28, 2005 Declaration President Bush declares a State of Emergency for Florida. 

(FEMA Disaster Number-1602) 

Landfall Katrina makes landfall in Louisiana, Mississippi, and Alabama as a 

Category 3 hurricane. 

August 29, 2005 Declaration 

President Bush signs major disaster declaration for Louisiana, Mississippi 

and Alabama to provide Individual and Public Assistance to selected 

parishes and counties. (FEMA Disaster Numbers-1603, 1604, and 

1605) 

Amendment Amendment 1 to the Presidential Declaration allows Louisiana to receive 

Public Assistance categories A and B, including direct federal assistance. 

September 6, 2005 Policy Expedited Assistance authorized in the amount of $2,000 for eligible 

applicants under Individuals and Households Program (IHP). 

September 9, 2005 Decision FEMA released Disaster Specific Guidance #2. Eligible Costs for 

Emergency Sheltering Declarations-Hurricane Katrina. 

September 19, 2005 Decision FEMA releases a policy on Temporary Housing Assistance for 

Households displaced by Hurricane Katrina. 

Landfall Rita makes landfall in Texas and Louisiana as a Category 3 hurricane. 

September 24, 2005 Declaration President Bush issues a major disaster declaration for Texas and 

Louisiana. (FEMA Disaster Numbers-1606 and 1607) 

September 28, 2005 Policy 

Transitional Housing Assistance authorized for eligible applicants in the 

most affected areas of Louisiana and Mississippi in the amount of $2,358 

for rent without home inspection under IHP. 

October 13, 2005 Decision FEMA addresses requests for 30-day submissions for Requests for Public 

Assistance. Extension granted with new due date of November 30, 2005. 

Landfall Hurricane Wilma makes landfall in Florida as Category 3 hurricane. 

October 24, 2005 Declaration President Bush issues a major disaster declaration for Florida. 

(FEMA Disaster-1609) 

October 31, 2005 Status 45,526 households were sheltered in hotel and motel rooms. 

November 6, 2005 Status 48,292 households were sheltered in hotel and motel rooms. 

November 10, 2005 Lawsuit 

McWaters v. FEMA Class Action lawsuit was filed against FEMA in 

United States District Court in New Orleans on behalf of hurricane 

survivors who did not receive adequate FEMA assistance. 

November 14, 2005 Decision 

FEMA issues Disaster Specific Guidance for Hurricanes Katrina, Rita and 

Wilma Temporary Housing Strategy. The letter informs each household 

that hotel assistance under Section 403 (Public Assistance) is scheduled to 

end on December 1, 2005. The guidance includes options for transitioning 

to a more permanent housing solution. 

November 18, 2005 Decision 

FEMA issues a letter addressing a request for an extension to the 30-day 

submission for Public Assistance for FEMA Disasters 1603 and 1607-

Louisiana. In this letter, FEMA extends the Transitional Housing 

Assistance program until January 1, 2006. 

December 1, 2005 

Policy 

FEMA guidance ends Hotel Assistance, new or extended apartment leases, 

paid by either local or State governments, reimbursements under Stafford 

Act Section 403 (Public Assistance) funds. 

Policy 

Hotel funding paid under the contract between FEMA and the Corporate 

Lodging Consultants ends. Extension may be authorized but no more than 

14-day increments. No extension will be authorized after January 7, 2006. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 36 
 

 

 

 

 

 

 

 

 

Appendix B 

Event Decision Timeline 

Date Event Detail 

December 3, 2005 Status 38,373 households were sheltered in hotel and motel rooms. 

December 5, 2005 Decision FEMA hotel-motel housing programs for Hurricane Katrina evacuees in 

Louisiana, Texas and Mississippi extended to January 7, 2006. 

December 12, 2005 Lawsuit 

Judge Duval, United States District Court of New Orleans, issued an order 

requiring FEMA to (1) extend the hotel/motel program until February 

2006; (2) give every evacuee in short-term lodging at least two weeks 

notice prior to terminating their assistance in the program; and (3) stop 

FEMA from requiring completion of a Small Business Administration 

loan application before Temporary Housing Assistance is given. 

January 1, 2006 Status 33,703 households were sheltered in hotel and motel rooms. 

January 7, 2006 Policy FEMA states that no hotel funding extensions beyond this date. 

January 12, 2006 Lawsuit 

Judge Duval issued a modified order authorizing FEMA to (1) extend the 

deadline so that the earliest any evacuees can be terminated from the hotel 

program is February 13; (2) March 1, for evacuees in the City of New 

Orleans and Jefferson Parish; and (3) ordering evacuees to register with 

FEMA by January 30. 

February 1, 2006 Status 26,262 households were sheltered in hotel and motel rooms. 

February 22, 2006 Decision 

FEMA issues guidance regarding the transitioning of all eligible evacuees 

to long-term housing solutions by March 1, 2006. (Transitioning from 

Stafford Act Section 403 funding to Section 408 funding.) 

Policy All Stafford Act Section 403 (Public Assistance) apartment leases end. 

March 1, 2006 Policy All Stafford Act Section 403 to 408 program transitions should be 

completed, with the exclusion of state and local employee camps. 

Status 6,533 households were sheltered in hotel and motel rooms. 

March 4, 2006 Decision 

FEMA issues guidance extending the transition of all eligible evacuees to 

long-term housing solutions to April 1, 2006. This policy is only for the 

State of Texas. 

March 26, 2006 Decision 

FEMA issues Disaster Specific Guidance - Conversion of Assistance from 

403 to 408. This guidance provides possible eligibility for Individuals & 

Households Program recipients who have reached program limits and 

have a continuing housing need, to transition from Financial Assistance to 

Direct Assistance. Assistance will last 18 months after the disaster 

declaration. (See Notes 3 and 4). 

March 27, 2006 Decision 

FEMA issues a letter providing State Public Assistance Grantees 

additional guidance on the transition of evacuees from Stafford Act 

Section 403 to 408 funding. This letter reflects the information listed in 

the March 26, 2006, FEMA Disaster Specific Guidance. 

April 3, 2006 Status 1,481 households were sheltered in hotel and motel rooms. 

April 15, 2006 Policy FEMA makes an effort to notify all Public Assistance applicants of the 

number of evacuees who are eligible to receive continued assistance. 

April 30, 2006 Policy 

FEMA issues guidance specifying that Public Assistance Applicants (state 

governments) must notify or assure notification of evacuees of lease 

termination. 

May 1, 2006 Status 547 households were sheltered in hotel and motel rooms 

May 19, 2006 Lawsuit 

Watson v. FEMA was filed in United States District Court in Houston on 

behalf of hurricane Katrina and Rita survivors who did not receive proper 

assistance in the FEMA Apartment Program. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 37 
 

 

 

 

Appendix B 

Event Decision Timeline 

Date Event Detail 

May 31, 2006 

Policy 

FEMA will not reimburse states for emergency sheltering costs for 

ineligible evacuees beyond May 31, 2006. Ineligible evacuees who were 

notified after April 15, 2006, will be granted an additional 30 days to 

receive Stafford Act Section 403 emergency sheltering funding. The 

exceptions are when (1) Public Assistance Applicants to Landlord and 

evacuee were accomplished by April 30, 2006 and (2) contractual lease 

termination provisions require more than 30 days notice. 

Lawsuit A United States District Court judge in Houston orders FEMA to expedite 

all apartment extension requests. 

June 2, 2006 Status 250 households were sheltered in hotel and motel rooms. 

July 13, 2006 Lawsuit 

The United States District Court judge in Houston issues an injunction 

ordering FEMA to pay both rent and utilities, up to the HUD Fair Market 

Rents for all Section 408 Temporary Housing Program participants. 

August 2006 Status 

121,922 

households 

reside in 

FEMA 

provided travel 

trailers and 

Louisiana 

3,514 - Mobile 

Home units used 

67,620 - Travel 

Trailer units 

used. 

Mississippi 

6,300 -Mobile 

Home units 

used. 

41,974 -Travel 

Trailer units 

used. 

Alabama 

2,514 -Travel 

Trailer units used. 

mobile homes. 32 households 

are living in 

hotel/motels. 

August 29, 2006 Lawsuit 

The Association of Community Organizations for Reform Now (ACORN) 

vs. FEMA filed a complaint on behalf of evacuees of Katrina and Rita 

stating that FEMA terminated housing assistance without notification. 

September 6, 2006 Lawsuit 

United States 5th Circuit Court of Appeals overturned Houston District 

Court judge’s injunction, alleviating FEMA’s requirement to pay both 

Section 408 participants’ rents and utilities. 

September 17, 2006 Status 31 households were sheltered in hotel and motel rooms. 

November 29, 2006 Lawsuit 

The United States District Court for the District of Columbia ordered 

FEMA to reinstate 403 sheltering for all hurricane Katrina/Rita evacuees 

determined ineligible for assistance under the Section 408 temporary 

housing program as of August 31, 2006. 

December 5, 2006 Lawsuit FEMA filed a notice of appeal and motion to stay the order with the 

United States District Court for the District of Columbia. 

December 8, 2006 Lawsuit 

The United States District Court for the District of Columbia denied 

FEMA' s motion for a stay and issued an order seeking additional 

information. 

December 11, 2006 Lawsuit FEMA filed an Emergency Motion for Stay Pending Appeal with the D.C. 

Circuit Court of Appeals. 

December 12, 2006 Lawsuit 

The United States District Court of District of Columbia amended its 

Nov. 29, 2006 order, ordering that FEMA restore 403 sheltering assistance 

to evacuees in Texas who, on August 31, 2006, were being sheltered under 

Section 403 and had been found ineligible for Section 408 temporary 

housing. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 38 
Appendix B 

Event Decision Timeline 

Notes 

1. FEMA uses households as its primary measure. 

2. Hotel and motel information is measured by room night billed. Variations can occur such as one person in a 

hotel room or 4 or more persons per room. 

3. Direct Assistance is defined in Section 408 of the Stafford Act as temporary housing units acquired or leased 

directly to individuals and households because of a lack of available housing resources. 

4. Financial Assistance is defined in Section 408 of the Stafford Act as financial assistance provided to individuals 

and households to rent alternative housing accommodations, existing rental units, manufactured housing, 

recreation vehicles, or other fabricated dwellings, based on the fair market rent for accommodations. 

Legend 

Color Action 

Hurricane Landfall 

 Presidential Declaration 

FEMA Policy Decision 

 FEMA Policy 

 Housing Status

 Lawsuit 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 39 
Appendix C 

Management Responses to Draft Report 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 40 
Appendix C 

Management Responses to Draft Report 

Federal Emergency Management Agency (FEMA) Responses to 

Recommendations 

DRAFT OIG REPORT – Sheltering and Transitional Housing Activities 

after Hurricane Katrina

Recommendation 1: Expedite the completion of the National Disaster 

Housing Strategy and develop, implement, test, and exercise a housing plan 

for meeting the needs of individuals displaced by catastrophic disasters. 

FEMA concurs with this recommendation. The National Disaster Housing 

Strategy is currently under accelerated development, and is an Agency 

priority. The NDHS will convey a broad, national strategy that defines the 

roles, programs, and authorities for public (federal, state, local, tribal), 

private, and non-profit entities with responsibilities in disaster housing, 

highlighting the forms of assistance that will be available to individuals, 

households, and communities in the event of a disaster. The NDHS 

proposes that we develop a planning process that will work at the 

community, state, and the federal level, and can be applied to the entire 

spectrum of potential events, and potential magnitudes, including those of 

catastrophic proportions. This planning process will guide the 

implementation, testing, and exercising of our capabilities, to ensure our 

readiness to respond, and meet the needs of individuals displaced by 

disaster. 

Recommendation 2: Develop a command and control structure over housing 

decisions that clearly define all roles and responsibilities and identifies the 

chain of command needed to ensure timely decision-making. 

FEMA concurs with this recommendation and is confident that the NDHS 

will sufficiently clarify roles and responsibilities for housing disaster 

victims for the full continuum of the disaster housing process. The NDHS 

will clearly identify the structure for coordinating those roles, and identify 

those entities with the primary responsibility for the safety and welfare of 

those affected by the disaster during the sheltering, interim, and long-term, 

self-sustainable housing phases. This structure recognizes the importance 

of timely, event-specific, field-driven actions, determined and 

implemented at the appropriate, lowest jurisdictional level possible. Roles 

and responsibilities outlined in the NDHS will be consistent with those 

identified in the National Response Framework (NRF). 

Recommendation 3: Develop policies, procedures, and guidelines that 

address roles and responsibilities of FEMA and State and local governments 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 41 
Appendix C 

Management Responses to Draft Report 

articulating how housing needs of victims will be met in catastrophic 

disasters. 

FEMA’s first step in addressing this issue has been the comprehensive 

revision of the Emergency Support Function (ESF) #6 annex to the NRF, 

published in January, 2008. The ESF #6 annex (Mass Care, Housing, 

Emergency Assistance, and Human Services) supports and augments state, 

regional, local, tribal, and nongovernmental organization (NGO) mass 

care, emergency assistance, housing, and human services missions. 

Through the Post Katrina Emergency Management Reform Act, Congress 

has mandated that federal agencies take on additional responsibilities 

during emergencies resulting in an expansion of the responsibilities under 

ESF #6. The NRF established a new operational framework for ESF #6, 

which significantly expands the responsibilities and activities of that 

emergency support function. FEMA and ARC have worked diligently 

with their ESF #6 partners at the national level to revise the ESF #6 

standard operating procedures, and the process has been valuable in 

identifying and defining authorities, roles, and capabilities of all ESF #6 

agencies. 

The Post-Katrina Emergency Management Reform Act of 2006 requires 

FEMA to develop a NDHS. The NDHS will convey national guidance 

and a vision for providing disaster housing assistance. It will define the 

roles, programs, authorities, and responsibilities of all entities, detailing 

shared responsibilities and emphasizing the cooperative efforts required to 

provide disaster housing assistance. The NDHS will establish the 

importance of an effective collaboration by Federal, State, Tribal, and 

Local governments and includes nonprofit organizations and the private 

sector in the provision of disaster housing assistance. The NDHS will 

outline the most efficient and cost-effective options for meeting disaster 

housing needs, and serve as the basis for pre-event planning by all 

organizations with roles or responsibilities in disaster housing. The 

NDHS describes and will address how disaster victims typically move 

through the continuum of disaster housing as they work to achieve a 

permanent housing solution. The NDHS development process included 

extensive vetting and coordination with other entities involved in the 

provision of disaster housing, including multiple federal, state, tribal, 

local, and private organizations. 

Additionally, in July 2006, FEMA published a Mass Sheltering and 

Housing Assistance Recovery Strategy, which provided guidance and 

protocols for providing sheltering and housing assistance. While this 

strategy focuses on assistance associated with large hurricane evacuations, 

the procedures and underlying processes may also apply to no-notice 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 42 
Appendix C 

Management Responses to Draft Report 

events of a catastrophic nature. Key elements of the strategy are advance 

identification of Congregate and Transitional Shelters to provide shortterm lodging and Temporary Housing facilities for an extended period of 

time. Contained within the strategy is a Shelter Registration Protocol, 

which will allow FEMA field personnel to proactively register evacuees at 

designated congregate shelter locations and organized evacuee reception 

sites, including those out-of-state. FEMA also has a Transitional 

Sheltering Protocol, which may be implemented when large numbers of 

evacuees are being housed in congregate shelters and will not be able to 

return to their homes for extended periods of time. 

Recommendation 4: Finalize and implement its strategy for developing a 

system that authorizes eligible applicants to obtain an IHP-subsidized 

hotel/motel room for temporary sheltering. 

By regulation (CFR 206.117b), FEMA may provide reimbursement for 

reasonable short-term lodging expenses that individuals and households 

incur in the immediate aftermath of a disaster. To further effectuate this 

authority, we have drafted a Lodging Expense Reimbursement policy that 

will establish a national standard for evaluating and processing requests 

from individuals and households for disaster related lodging expenses. 

Reimbursements will be calculated against the individual household’s IHP 

financial limit. 

Additionally, we initiated an IHP-subsidized hotel/motel program for 

Hurricane Katrina and Rita applicants who were housed in FEMA TT/MH 

units and who requested relocation to a hotel/motel because of health 

concerns related to formaldehyde. A specific 24-hour 800 number was 

created to connect concerned applicants to a specialized group of 

caseworkers who address their individual concerns. The caseworkers can 

identify hotel resources and alternative housing if needed. If a hotel or 

motel is needed for short term lodging, an authorization is granted which 

allows the applicant to check into a participating hotel. Hotels are 

available throughout the gulf coast region and coordination and 

authorization is done through a contract with Corporate Lodging 

Consultants. 

Lastly, in accordance with the Transitional Sheltering Protocol as 

described in the “Mass Sheltering and Housing Assistance – RS-001” 

strategy, FEMA will authorize and fund the use of hotels, motels, cruise 

ships or berthing vessels as transitional shelters. To effectuate this 

authority, we have drafted a Transitional Sheltering (Emergency Lodging 

Assistance) policy that is designed for use in post-disaster situations where 

States are hosting large numbers of evacuees in congregate shelters, who 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 43 
Appendix C 

Management Responses to Draft Report 

will not be able to return to their homes for an indeterminate period of 

time. Transitional sheltering will be funded under Section 403 of the 

Stafford Act and will not be calculated against the individual household’s 

IHP financial limit. 

Both of these draft policies are in the vetting stage and it is anticipated that 

they will be issued by mid-summer 2008. 

Recommendation 5: In coordination with the DHS Chief Procurement 

Officer, develop an acquisition strategy that (1) addresses housing needs, 

supplies, and services prior to disasters; (2) considers the effect on production 

capabilities and available on-site inventory; and (3) balances the capabilities 

of distribution, wholesalers, retailers, and manufacturers, and maximizes the 

use for them. 

These factors are currently included in the acquisition strategy under the 

IA TAC. 

Upon release of the National Disaster Housing Strategy, FEMA’s Office 

of Acquisition will coordinate with the IA TAC and the DHS Chief 

Procurement Officer, to develop a comprehensive acquisition strategy that 

addresses all planning elements outlined in the new strategy. 

Recommendation 6: Evaluate basic housing requirements occurring after 

catastrophic disasters, put in place contracts and infrastructure to respond to 

the needs of catastrophic disaster victims, and develop policies and procedures 

to re-compete contracts when expedited contracting methods are used 

immediately following a major disaster. 

FEMA’s Individual Assistance (IA) Division, in conjunction with FEMA 

Acquisition Management, has developed the IA TAC II contracts. The 

contracts are Indefinite Deliverable Indefinite Quantity deliverables that 

feature a competitive bidding process for each task order. These contracts 

were competed in a non-disaster environment allowing both FEMA and 

the contractors to clarify and modify the scope and terms when applicable 

or required. The contracts encompass all IA missions and are exercised 

continually on smaller disasters. 

The long term acquisition strategy is further illustrated with the planning 

and procurement of the IA TAC III contracts. These contracts will be a 

follow on to the IA TAC II contracts incorporating lessons learned during 

both the IA TAC I and IA TAC II contracts. 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 44 
Appendix C 

Management Responses to Draft Report 

Upon release of the National Disaster Housing Strategy, FEMA’s Office 

of Acquisition will coordinate with the IA TAC and the DHS Chief 

Procurement Officer, to develop a comprehensive acquisition strategy that 

addresses all planning elements outlined in the new strategy. This revised 

strategy will address immediate and long-term contracts. 

Recommendation 7: Develop policies and procedures to ensure that 

procurement personnel properly maintain contract files as defined by the 

FAR, including documents that show the basis used to determine price 

reasonableness as well as documents regarding any other contracting 

decisions. 

FEMA concurs with this recommendation and will work to ensure that 

procurement personnel adhere to documentation requirements outlined in 

the FAR. 

Recommendation 8: Undertake the following actions: (1) determine the 

appropriate number of contracting professionals and experienced COTRs 

required to meet sheltering and transitional housing needs occurring after a 

catastrophic disaster; (2) continue to hire experienced contracting 

professionals to monitor and oversee housing contracts awarded in a disaster 

environment; (3) promulgate specific guidance emphasizing the authority and 

responsibility of contracting officers and COTRs qualified to perform housing 

acquisitions, and (4) include provisions for the training of contracting officers 

and COTRs functioning in catastrophic disaster environments. 

FEMA concurs with recommendations: (1). FEMA continues to learn 

valuable lessons from our ongoing disaster response operations and 

continues to focus on right-sizing our contract oversight operations in the 

field. FEMA concurs with recommendation (2). Since Katrina struck the 

gulf coast, FEMA has increased its professional acquisition staff from 

approximately 35 to 118. In addition, FEMA’s Disaster Assistance 

Directorate created the IA-TAC Program Management Office, which 

oversees contractor support for FEMA’s housing and sheltering 

operations. This Office is staffed with several DHS certified Program 

Managers and approximately 40 DHS certified COTRs. FEMA also 

concurs in part to recommendation (3) to the extent that additional specific 

guidance emphasizing the authority and responsibility of contracting 

officers and COTRs is needed. 

FEMA concurs, in part, with recommendation (4), after a determination of 

how existing training needs can be modified to address catastrophic 

disasters. 

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Appendix C 

Management Responses to Draft Report 

Recommendation 9: Develop explicit criteria for what a temporary housing 

site should include, as well as criteria for how appropriate sites are selected 

for development. 

FEMA concurs with the need to develop explicit criteria that will govern 

the group site selection and construction process. At the same time, the 

selection of group site locations is heavily influenced by state, local, and 

environmental factors that are beyond FEMA’s control. State and Local 

governments lead the initial identification of potential sites, and must 

concur with the use and development of a group site location. The site 

identification process requires that these influences are coordinated and 

balanced to the greatest extent possible. In order to facilitate this process, 

FEMA is pursing the development of a policy document that will outline 

site identification considerations, such as cost and the proximity to 

services and the affected area. 

In addition, FEMA has requested that the National Advisory Council 

(NAC) issue recommendations that will be used to establish a standard list 

of facilities and services to be included in FEMA group sites. This includes 

the delivery of infrastructure and additional social services to affected 

residents living on temporary housing sites that go beyond a physical need 

for housing. Specifically, the NAC has been asked to identify appropriate, 

required, wrap-around services, identify the responsible agency or entity 

(federal, state, local, or voluntary) for required services that FEMA does 

not have the authority to provide, how the services should be funded, and 

the effect of the services in relation to motivating more permanent 

solutions. 

Lastly, any housing units donated to a third party for the purposes of 

housing disaster victims will be governed by FEMA’s Interim Policy 

9455.1, Temporary Housing Unit Donations. 

Recommendation 10: Institute an oversight program that ensures Individual 

Assistance Technical Assistance Contractors identify and select eligible 

temporary housing sites for disaster victims. 

Oversight currently exists through the Individual Assistance Branch of the 

Joint Field Office, which is responsible for identifying and selecting 

eligible temporary sites. The IA-TAC supports the identification of 

eligible sites but only with direct management of JFO Individual 

Assistance Branch. 

Recommendation 11: Work with state and local governments to develop 

policies, plans, procedures, and processes to identify and set up group and 

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Appendix C 

Management Responses to Draft Report 

individual temporary housing sites that accommodate specific or special needs 

of victims prior to disasters. 

FEMA concurs, and is working closely with States, tribal governments, 

counties and independent municipalities on a Gap Analysis planning 

initiative that includes the pre-disaster identification of housing resources, 

including rental units and potential group site locations. Several FEMA 

Regions are currently working with state and local partners to pre-identify 

group site locations under this initiative and have included special needs 

considerations as part of their planning process. 

FEMA has also developed related policy guidance: FEMA’s Interim 

Policy # 9452.1, Temporary Housing Units for Eligible Disaster Victims 

with a Disability. The purpose of this policy is to ensure that FEMA 

provides temporary housing units on sites that can accommodate the 

specific and special needs of disaster victims and outlines the agency’s 

adoption of the Uniform Federal Accessibility Standards (UFAS) 

established under the Architectural Barriers Act. In addition, this policy 

establishes target inventory levels of units designed to incorporate UFAS 

specifications, as well as set asides for accessible units and pads within 

FEMA constructed group sites. 

Recommendation 12: Develop policies and procedures requiring that (1) all 

travel trailers and mobile homes are properly inspected/accepted upon receipt, 

(2) inspection/acceptance documentation is retained, and (3) maintenance and 

repair costs, including the costs of parts claimed by contractors, are monitored 

and warranties enforced. 

FEMA concurs and has implemented a stringent Quality 

Assurance/Quality Control program for the procurement of new temporary 

housing units. The manufacturer is required to conduct a “station by 

station” check of each unit and make any necessary repairs before going to 

the next station. Once constructed, the manufacturer conducts a whole unit 

test and fixes any repairs required by the inspection. Also, FEMA will 

have a qualified technical monitor (TM) on-site for the duration of the 

contract and until the last unit is constructed. The TM will monitor each 

unit from start to finish ensuring no errors are found. If any error is found, 

the manufacturer is responsible to bring the unit into compliance or the 

government is not responsible or obligated to purchase the unit. Once the 

TM signs off on the unit, stating it meets the required specifications and 

the unit is functional, the unit is transported to a long term staging site. At 

this stage, a staff member from the Logistics Management Directorate 

(LMD) inspects the unit for road damage. If damage is found, the 

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Appendix C 

Management Responses to Draft Report 

manufacturers are responsible for repairing the unit on location or replace 

the unit with an additional unit at no expense to the government. 

All inspection documentation is maintained within FEMA’s Logistics 

Management Directorate. 

Manufacturer’s warranties are reviewed throughout this inspection and 

acceptance process to ensure comprehensive understanding of terms and 

conditions and prevent duplication of benefit or unnecessary spending on 

the part of FEMA. In a catastrophic disaster environment, a cost benefit 

analysis of enforcing manufacturer warranties must be evaluated against 

the urgent and compelling need to provide immediate housing solutions. 

Recommendation 13: Determine whether Individual Assistance Technical 

Assistance Contractors made repairs that should have been reported to the 

manufacturers at the time of acceptance/inspection and, whenever applicable, 

covered under the implied warranty clause, and seek reimbursement from the 

contractors or manufacturers as appropriate. 

While FEMA agrees that repair requirements should have been reported to 

the manufacturers and covered by warranty, FEMA does not concur with 

the recommendation to seek, at this late date, reimbursement from Katrina 

contractors or manufacturers for minor repairs performed by IA-TAC 

contract personnel, believing that such an effort would be cost-prohibitive. 

However, as a remedy for future procurements of temporary housing units, 

FEMA has instituted a stringent Quality Assurance/Quality Control 

process that will identify and correct discrepancies of units prior to 

acceptance at the manufacturing facilities. At this time FEMA is 

completing 100% inspection of all newly procured units and requiring all 

discrepancies be corrected prior to acceptance. 

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Appendix D 

Major Contributors to This Report 

Gina Smith, Director (Lead) 

Robert Lastrico, Director 

Moises Dugan, Supervisory Program Analyst 

Cliff Melby, Senior Program Analyst 

Gary Cox, Senior Auditor 

Nigel Gardner, Senior Program Analyst 

Lori Smith, Auditor 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina 

Page 49 
Appendix E 

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 

DHS Chief Procurement Officer 

FEMA Audit Liaison (Project code GC-HQ-06-STH) 

Assistant Administrator, Disaster Assistance Directorate 

Director, Office of Management, FEMA 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committee, as appropriate 

 

FEMA’s Sheltering and Transitional Housing Activities After Hurricane Katrina

Page 50 
 Additional Information and Copies 

To obtain additional copies of this report, call the Office of Inspector General (OIG) at 

(202) 254-4199, fax your request to (202) 254-4305, or visit the OIG web site at 

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To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal 

or noncriminal misconduct relative to department programs or operations: 

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