Department of Homeland Security

Office of Inspector General 

National Flood Insurance Program 


Management Letter for DHS’ FY 2009 


Consolidated Financial Statements Audit 


(Redacted)
 

OIG-10-64 April 2011 (Revised) 
 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

APR012011

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 audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report presents the revised National Flood Insurance Program Management Letter 

for DHS FY 2009 Consolidated Financial Statements Audit. It contains observations 

related to internal control that were not required to be reported in the financial statements 

audit report. The independent public accounting firm KPMG LLP (KPMG) performed 

the integrated audit of DHS’ FY 2009 financial statements and internal control over 

financial reporting and prepared this management letter. KPMG is responsible for the 

attached management letter dated November 13, 2009 and the conclusions expressed in 

it. We do not express opinions on DHS’ financial statements or internal control or 

provide conclusions on compliance with laws and regulations. 

The observations herein have been discussed in draft with those responsible for 

implementation. We trust this report will result in more effective, efficient, and 

economical operations. We express our appreciation to all of those who contributed to 

the preparation of this report. 

Anne L. Richards 

Assistant Inspector General for Audits 
NATIONAL FLOOD INSURANCE PROGRAM 


Management Letter for the 


Year Ended September 30, 2009 

KPMG LLP 

2001 M Street, NW 

Washington, DC 20036 

Office of Inspector General, U.S. Department of Homeland Security, and 

Acting Assistant Administrator, Mitigation Directorate, Federal Emergency Management Agency, U.S. 

Department of Homeland Security, Washington, DC 

November 13, 2009 

Ladies and Gentlemen: 

We were engaged to audit the balance sheet of the U.S. Department of Homeland Security (DHS) as of 

September 30, 2009, and the related statement of custodial activity for the year then ended (referred to 

herein as “financial statements”). We were also engaged to examine internal control over financial 

reporting (internal control) of the financial statements. In connection with our fiscal year 2009 

engagement, we considered compliance with certain provisions of applicable laws, regulations, contracts, 

and grant agreements that could have a direct and material effect on the financial statements. We were not 

engaged to audit the statements of net cost, changes in net position, and budgetary resources for the year 

ended September 30, 2009 (referred to herein as “other financial statements”), or to examine internal 

control over financial reporting over the other financial statements. Because of matters discussed in our 

Independent Auditors’ Report dated November 13, 2009, the scope of our work was not sufficient to 

enable us to express, and we did not express, an opinion on the financial statements as of September 30, 

2009, and we were unable to perform procedures necessary to form an opinion, and we did not express an 

opinion, on internal control over financial reporting of the financial statements as of September 30, 2009. 

During our audit engagement, we noted certain matters involving the Federal Emergency Management 

Agency’s (FEMA) National Flood Insurance Program (NFIP) internal control and other operational 

matters that are presented for your consideration. These observations and recommendations, all of which 

have been discussed with the appropriate members of management of the named insurance companies 

(where applicable), FEMA’s Office of the Chief Financial Officer, and FEMA’s Mitigation Directorate, 

are intended to improve internal control or result in other operating efficiencies, are not considered to 

reflect significant deficiencies or material weaknesses in internal control over financial reporting, and are 

summarized in Exhibit I of this letter. The status of our prior year observations is presented in Exhibit II. 

We identified certain deficiencies in internal control that we consider to be significant deficiencies and 

material weaknesses, and communicated them in our Independent Auditors’ Report, dated November 13, 

2009, included in the fiscal year 2009 DHS Annual Financial Report. Certain control deficiencies related 

to FEMA information technology (IT) controls will be presented in a separate letter to the DHS Office of 

Inspector General and the FEMA Chief Information Officer, and certain other control deficiencies related 

to FEMA’s internal controls exclusive of our IT findings will be presented in a separate letter to the DHS 

Office of Inspector General and the DHS Acting Chief Financial Officer. 

As described above, the scope of our work was not sufficient to express an opinion on the balance sheet 

or statement of custodial activity of DHS or the related internal control as of September 30, 2009, and we 

were not engaged to audit the statements of net cost, changes in net position, and budgetary resources or 

the related internal control for the year ended September 30, 2009. Accordingly, other internal control 

matters and instances of non-compliance may have been identified and reported had we been able to 

perform all procedures necessary to express opinions on the fiscal year 2009 financial statements and on 

fiscal year 2009 internal control over financial reporting of the financial statements and had we been 

KPMG LLP, a U.S. limited liability partnership, is the U.S. 

member firm of KPMG International, a Swiss cooperative. 
engaged to audit the fiscal year 2009 other financial statements and fiscal year 2009 internal control over 

financial reporting of the other financial statements. We aim, however, to use our knowledge of NFIP 

gained during our work to make observations and suggestions that we hope will be useful to you. 

We would be pleased to discuss these observations and recommendations with you at any time. 

Management’s written response to our observations and recommendations in Exhibit III has not been 

subjected to the auditing procedures applied in the financial statement audit engagement and, accordingly, 

we express no opinion on it. 

This letter is intended solely for the information and use of DHS and FEMA management, DHS Office of 

Inspector General, the Office of Management and Budget, U.S. Government Accountability Office, the 

U.S. Congress, and management of the named insurance companies, and is not intended to be and should 

not be used by anyone other than these specified parties. 

Very truly yours, 
Company Policy Number Loss Date LAE Payment 

09/13/2008 $ 1,795.55 

09/13/2008 $ 1,725.39 

08/01/2008 $ 925.00 

09/01/2008 $ 1,001.31 

05/01/2008 $ 2,000.00 

Exhibit I 

I. INTERNAL CONTROL DEFICIENCIES RELATED TO CLAIMS 

A. 	Internal Control Deficiencies Identified over Claims Paid 

Observation 

We selected 12 insurance companies to perform audit procedures over claims paid for the periods October 

1, 2008 through March 31, 2009, April 1 through June 30, 2009, and July 1 through August 31, 2009. For 

the 12 companies selected, we tested a sample of claims paid totaling 688 items covering the three testing 

periods identified above. During this testing, we noted the following internal control deficiencies and 

errors: 

1)	 Based on our March 31, 2009 testwork, for one sample item, the claims file was not complete and the 

Final Report was not approved before the claim payment was processed and issued. 

Company Policy Number Loss Date Claim Payment 

09/13/2008 $ 4,250.23 

2) Based on our March 31, 2009 testwork, for six sample items, the total amount paid to the insured did 

not agree to the amount indicated on the Final Report. 

Company Policy Number Loss Date Claim Payment 

09/13/2008 $ 44,008.02 

08/21/2008 $ 9,876.40 

09/06/2008 $ 1,668.50 

09/06/2008 $ 6,929.06 

09/13/2008 $ 32,330.15 

09/13/2008 $ 31,400.00 

3) Based on our March 31, 2009 testwork, for one sample item, the claim check was not properly 

authorized. 

4) Based on our March 31, 2009, June 30, 2009, and August 31, 2009 testwork, for 14 sample items, the 

payments to the insurance company/adjusting firm for servicing the claim did not agree with the 

National Flood Insurance Program (NFIP) Fee Schedule. 

March 31, 2009 Testwork Results: 

Company Policy Number Loss Date Claim Payment 

09/12/2008 $ 10,025.96 

I.1
 
Company Policy Number Loss Date LAE Payment 

09/13/2008 $ 2,981.94 

09/14/2008 $ 3,935.62 

09/21/2008 $ 1,025.00 

Company Policy Number Loss Date LAE Payment 

08/29/2005 $ 123.72 

06/23/2008 $ 225.00 

08/29/2005 $ 3,947.70 

Company Policy Number Loss Date LAE Payment 

08/22/2007 $ 1,790.00 

04/28/2009 $ 1,099.31 

09/13/2008 $ 4,319.14 

Exhibit I 

June 30, 2009 Testwork Results: 

August 31, 2009 Testwork Results: 

5) Based on our March 31, 2009 testwork, for eight sample items, loss reserves were not established at 

the correct amount when the insurance company received notification of loss. 

Company Policy Number Loss Date 

 09/13/2008 

 09/01/2008 

 09/01/2008 

 09/01/2008 

 09/01/2008 

 09/01/2008 

 06/01/2008 

 09/01/2008 

Based on the results for the period ended March 31, 2009, this control was not tested during the 

periods of April 1 through June 30, 2009 and July 1 through August 31, 2009. 

6)	 Based on our March 31, 2009 testwork, for 15 sample items, the loss reserve amounts were not 

adjusted as claim payments were made to the policyholder. 

Company Policy Number Loss Date 

09/13/2008 

 09/13/2008 

 09/13/2008 

 09/01/2008 

 09/01/2008 

I.2
 
Exhibit I 

Company Policy Number Loss Date 

 08/01/2008 

 09/01/2008 

 09/01/2008 

 09/01/2008 

 09/01/2008 

 09/12/2008 

08/21/2008 

 09/21/2008 

 09/21/2008 

 09/22/2008 

Based on the results for the period ended March 31, 2009, this control was not tested during the 

periods of April 1 through June 30, 2009 and July 1 through August 31, 2009. 

7)	 Based on our March 31, 2009 testwork, for one sample item, for an open claim, the loss reserve 

amount was prematurely reduced to zero prior to the claim being closed. 

Company Policy Number Loss Date 

 09/01/2008 

Based on the results for the period ended March 31, 2009, this control was not tested during the 

periods of April 1 through June 30, 2009 and July 1 through August 31, 2009. 

Recommendations 

We recommend that the Federal Emergency Management Agency’s (FEMA) Mitigation Directorate: 

1) Follow-up with each of the insurance companies noted above to determine that appropriate corrective 

action has been implemented to address the exceptions noted in our testwork. 

2) Provide increased oversight to insurance companies participating in the NFIP to ensure claims files 

are being processed and reviewed in accordance with NFIP guidelines before approval and issuance 

of claim payments and to ensure the specific and consistent establishment and reporting of loss 

reserves and subsequent adjustments to the loss reserves. 

B. 	 Inaccuracies in Claims’ Loss Reserves 

Observation 

We selected 12 insurance companies to perform audit procedures over the accuracy and completeness of 

loss reserves established as of March 31, 2009 and June 30, 2009. For the 12 companies selected, we 

tested a sample of loss reserves reported as of March 31, 2009 and June 30, 2009, totaling 210 items and 

275 items tested, respectively. During this testing, we noted the following inaccuracies at the respective 

insurance companies: 

1)	 Based on our March 31, 2009 and June 30, 2009 testwork, for eight sample items, the loss reserve 

was not adjusted for subsequent claims adjuster documentation: 

I.3
 
Company Policy Number Loss Date Loss Reserve 

09/13/2008 $ 13,000.00 

09/13/2008 $ 10,000.00 

09/13/2008 $ 32,719.00 

09/13/2008 $ 15,000.00 

Company Policy Number Loss Date Loss Reserve 

04/28/2009 $ 140,000.00 

04/27/2009 $ 8,700.00 

05/09/2009 $ 15,000.00 

04/28/2009 $ 5,000.00 

Company Policy Number Loss Date Loss Reserve 

09/24/2005 $ 30,000.00 

09/13/2008 $ 30,000.00 

08/29/2005 $ 8,650.00 

Company Policy Number Loss Date Loss Reserve 

09/13/2008 $ 230,000.00 

06/10/2009 $ 26,303.14 

03/28/2009 $ 17,062.29 

05/09/2009 $ 41,193.22 

05/09/2009 $ 79,913.86 

04/24/2009 $ 55,000.00 

08/29/2005 $ 30,000.00 

08/29/2005 $ 30,000.00 

Exhibit I 

March 31, 2009: 

June 30, 2009: 

2)	 Based on our March 31, 2009 and June 30, 2009 testwork, for 11 sample items, the loss reserve was 

not adjusted for partial and/or advance payments made to the policyholder: 

March 31, 2009: 

June 30, 2009: 

3)	 Based on our March 31, 2009 and June 30, 2009 testwork, for 14 sample items, the loss reserve was 

not closed in a timely manner after full payment of the claim was made to the policyholder: 

March 31, 2009: 

Company Policy Number Loss Date Loss Reserve 

08/29/2005 $ 20,050.00 

I.4
 
Company Policy Number Loss Date Loss Reserve 

07/10/2005 $ 30,000.00 

08/29/2005 $ 30,000.00 

05/19/2004 $ 30,000.00 

09/06/2004 $ 30,000.00 

05/30/2004 $ 30,000.00 

09/08/2004 $ 30,000.00 

02/07/2008 $ 2,510.26 

Company Policy Number Loss Date Loss Reserve 

10/24/2005 $ 20,622.90 

09/16/2004 $ 30,000.00 

09/16/2004 $ 30,000.00 

09/05/2004 $ 30,000.00 

05/30/2004 $ 30,000.00 

09/13/2008 $ 4,250.00 

Company Policy Number Loss Date Loss Reserve 

09/04/2004 $ 41,829.85 

06/08/2001 $ 30,000.00 

Company Policy Number Loss Date Loss Reserve 

04/18/2009 $ 5,000.00 

06/10/2008 $ 10,675.00 

 

Exhibit I 

June 30, 2009: 

4) Based on our June 30, 2009 testwork, for two sample items, the entire or partial loss reserve was not 

supported by adequate documentation: 

5) Based on our June 30, 2009 testwork, for two sample items, the loss reserve was not appropriately 

established/adjusted due to a claims adjuster clerical error: 

6) Based on our June 30, 2009 testwork, for one sample item, the loss reserve resulted from a duplicate 

reserve being created for a policy that was transitioned to a different policy number: 

Company Policy Number Loss Date Loss Reserve 

04/26/2008 $ 30,000.00 

7) Based on our June 30, 2009 testwork, for one sample item, the loss reserve was adjusted for a claim 

payment prior to the claim payment being paid to the policyholder: 

Company Policy Number Loss Date Loss Reserve 

06/04/2008 $ 1,128.29 

I.5
 
Insurance Company Understatement 

$ (13,656) 

$ (69,404) 

$ (8,318) 

$ (1,175,855) 

Exhibit I 

Recommendations 

We recommend that FEMA’s Mitigation Directorate: 

1)	 Provide adequate oversight for each insurance company during a vendor merger or vendor transition 

to ensure the new vendor maintains the necessary documents in order to support the financial 

transactions and balances it is inheriting. 

2)	 Follow-up with each of the insurance companies noted above to determine that appropriate corrective 

action has been implemented to address the exceptions noted in our testwork. 

3)	 Provide increased oversight to ensure the specific and consistent documentation of the established 

loss reserve and subsequent adjustment to the loss reserve per claim in the claim file at the insurance 

companies participating in the NFIP is maintained. 

II. OTHER INTERNAL CONTROL DEFICIENCIES 

A. 	Internal Control Deficiencies Related to NFIP Restricted Bank Accounts 

Observation 

We selected 12 insurance companies to perform audit procedures over the NFIP restricted bank account 

reconciliations, and we noted the following exceptions for the period ended March 31, 2009: 

1) 	 For 5 of the 12 insurance companies selected, we noted that lockbox receipts received on the last day 

of the month (i.e., March 31, 2009) were not included in each company’s general ledger but were 

included in the company’s bank balance. Therefore, the amount of cash recorded in the insurance 

company’s general ledger was understated for these insurance companies for the period ended March 

31, 2009. 

2) For , we noted that its prior NFIP vendor wired $1,424,596 to the company in fiscal year 

2009 before the transition to new NFIP vendor. At the time of our audit procedures, 

neither nor the prior vendor could explain the purpose of the transaction or provide 

supporting documentation for the item. The current vendor determined that $319,353 of the transfer 

related to stale checks and subsequently recorded this amount in general ledger in 

February 2009. As of July 31, 2009, the purpose of the transaction had not been determined. 

3) For , we noted two unsupported reconciling items on the March 31, 2009 bank 

reconciliation. The current vendor purchased the prior vendor in fiscal year 2005 and inherited the 

two reconciling items included in the prior vendor’s bank account. Thus, these items were included 

in the bank account but not in the general ledger. 

The table below provides a listing of the insurance companies discussed above, the understatement of 

cash dollar value per company at March 31, 2009, and the total understatement of cash dollar value at 

March 31, 2009. 

I.6
 
 

 

Exhibit I 

Insurance Company Understatement 

Total 

$ 

$ 

$ 

 (6,420) 

(47,971) 

(1,321,624) 

Recommendations 

We recommend that FEMA’s Mitigation Directorate: 

1)	 Follow-up with each of the insurance companies noted above to determine that appropriate corrective 

action has been implemented to address the exceptions noted in our testwork. 

2)	 Provide increased oversight to insurance companies participating in the NFIP to ensure that NFIP 

cash management procedures are being followed by insurance companies in accordance with NFIP 

guidelines. 

3)	 Provide adequate oversight for each insurance company during a vendor merger or vendor transition 

to ensure the new vendor maintains the necessary documents in order to support the financial 

transactions and balances it is inheriting. 

B. 	 Internal Control Deficiencies in the Claims Reinspection and Submit for Rate Programs 

Observation 

In fiscal year 2008, during our interim control testwork, we identified instances where FEMA did not 

consistently maintain documentation of the Submit for Rate review and/or follow-up on underwriting 

errors nor follow-up appropriately on claim reinspections with the insurance companies. 

As of the start of our fiscal year 2009 audit procedures, the current NFIP service provider had been 

instructed by FEMA’s Mitigation Directorate to begin using the NextGen ‘FREE’ and ‘ezClaims’ 

applications for all Submit for Rate Program and Claims Reinspection Program functions, respectively, 

even though NextGen did not have the authority to operate on a Department of Homeland Security (DHS) 

network and was not the system of record. 

Based on that information, the Submit for Rate Program and the Claims Reinspection Program were not 

operating using policy and claim data from the NFIP system of record (i.e., Transaction Record Reporting 

and Processing [TRRP] system) throughout fiscal year 2009. 

Recommendation 

We recommend that FEMA’s Mitigation Directorate use the official NFIP system of record as the basis 

for the Submit for Rate and Claims Reinspection Programs and not transition these program activities to a 

new system before it is authorized to operate as the system of record. 

C. 	Insufficient FEMA Oversight of the NFIP Service Provider’s Methodology Used to Calculate 

Estimates Reported in the FEMA Financial Statements 

Observation 

In fiscal year 2008, we noted that the NFIP service provider’s methodology was insufficiently 

documented to allow a reasonable person to re-perform the year-end estimates and yield the same results. 

For fiscal year 2009, the NFIP service provider updated the methodology to address the prior year 

documentation deficiency. 

I.7
 
 

Exhibit I 

The financial statement estimates for the NFIP are based on the service provider’s judgments, historical 

knowledge, and assumptions to determine the final value of a variety of material account balances. Since 

the Mitigation Directorate is the responsible division within FEMA for the management and oversight of 

the NFIP and the Office of the Chief Financial Officer (OCFO) inherits the risks associated with the third 

party service provider’s processing and reporting of the NFIP financial data to FEMA, the Mitigation 

Directorate should have obtained and provided this information to the OCFO’s Financial Management 

Division, which in turn should have reviewed and approved the methodology used by the service provider 

to report significant line items. 

For fiscal year 2009, we obtained and reviewed the updated deferred revenue, deferred acquisition cost, 

and accounts payable methodology from the service provider and followed-up with the FEMA OCFO 

concerning the sufficiency of the methodology. Based on the follow-up performed, we observed that the 

Mitigation Directorate did not provide the deferred revenue, deferred acquisition cost, and accounts 

payable methodology to the FEMA OCFO, and consequently, we concluded that as of July 1, 2009, the 

OCFO had not reviewed and approved the service provider’s estimation methodology for the NFIP 

financial statements and ultimately the FEMA financial statements. 

The OCFO reviewed and approved the methodology on July 10, 2009 after we informed them of this 

deficiency. 

Recommendation 

We recommend that FEMA’s OCFO and Mitigation Directorate develop and implement procedures for 

the OCFO’s Financial Management Division to timely complete such a review and approval whenever 

changes are made to the NFIP service provider’s estimation methodology, to include procedures for the 

Mitigation Directorate to obtain and provide the changes to the OCFO timely. 

D. Monitoring and Communication of Significant Financial-Related Matters in the NFIP 

Observation 

During fiscal year 2008, based on control testwork and observations and communications with FEMA 

personnel, we noted the following areas where financial management improvements were needed in 

monitoring the NFIP operations: 

� Retrospective Reserve Analysis 

� Change in Service Provider 

� Change in NFIP Systems 

� Changes to the Actuarial Liability and the Related Actuary Report 

Based on our fiscal year 2009 control testwork, observations and communications with FEMA personnel, 

we noted the aforementioned conditions had been remediated during the current fiscal year. However, 

during our testwork in current year over the NFIP deferred revenue estimate, we noted that the service 

provider unilaterally changed the estimation methodology on October 7, 2009. The methodology 

changed from deferred revenue being based on a two-year historical growth percentage, which was 

applied to August deferred revenue to calculate September deferred revenue, to deferred revenue being 

based on a function of written premium. A three-year historical percentage of deferred revenue derived 

from written premium was applied to the September 2009 written premium balance to estimate deferred 

revenue at September 30, 2009. Based on our corroborative inquiry with the OCFO and Mitigation 

Directorate, we noted that both divisions were unaware of the change to the year-end deferred revenue 

methodology. The related estimate was recorded in FEMA’s general ledger. 

I.8
 
Exhibit I 

Recommendations 

We recommend that the: 

1)	 Mitigation Directorate develop and implement communication protocols with the service provider to 

ensure that significant financial-related events are timely communicated to the Mitigation Directorate. 

2)	 Mitigation Directorate designate a point of contact responsible for the timely communication of 

significant financial-related events with the service provider and the OCFO. 

3)	 OCFO develop and implement communication protocols with the Mitigation Directorate for 

significant financial-related events and designate a point of contact responsible for these 

communications and related accounting and reporting action. 

I.9
 
Status of Prior Year Observations Exhibit II 

The status of each observation reported in our letter dated November 14, 2008 to the Office of Inspector 

General, U.S. Department of Homeland Security, and Acting Administrator, Mitigation Division, Federal 

Emergency Management Agency, U.S. Department of Homeland Security, is summarized in the table 

below. For each repeated observation, we provided the current year Observation Number and Notice of 

Findings and Recommendations (NFR) Number. 

Disposition 

2008 Repeat (2009 

Observation Description Closed Observation No./ 

No. NFR No.) 

I.A 

Internal Control Deficiencies Identified over Claims 

Paid – Interim Testing I.A/ FEMA 09-36 

I.B 

Internal Control Deficiencies Identified over Claims 

Paid – Final Testing I.A/ FEMA 09-36 

I.C Inaccuracies in Interim Claims’ Loss Reserves I.B/ FEMA 09-37 

I.D 

Internal Control Deficiencies in the Claims 

Reinspection Program II.B/ FEMA 09-41 

II.A 

Internal Control Deficiencies Identified over 

Premiums Written X 

II.B 

Internal Control Deficiencies in the Submit for Rate 

Program II.B/ FEMA 09-41 

III.A 

Insufficient Documentation of Methodology Used 

to Calculate NFIP Estimates Reported in the FEMA 

Financial Statements 

II.C/ FEMA 09-39 

II.1
 
Management’s Response Exhibit III 


III.1
 
Management’s Response Exhibit III 


III.2
 
 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

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 

Chief Financial Officer 

Chief Information Officer 

Federal Emergency Management Agency 

FEMA Administrator 

Chief Financial Officer 

FEMA Audit Liaison 

Director of Mitigation Division 

Chief of Risk Insurance 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 
ADDITIONAL INFORMATION AND COPIES 

To obtain additional copies of this report, please call the Office of Inspector General (OIG) at (202) 254-4100, 

fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

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