Department of Homeland Security

Office of Inspector General 

Process Used by the Department of 

Homeland Security to Monitor 

Reporting by Recipients of American 

Recovery and Reinvestment Act of 

2009 Funds 

American Recovery and Reinvestment Act of 2009 
 

OIG-10-08 October 2009 
• 

/~~,~ 

Office a/II/spector Gel/eral 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homela.nd Homela.nd 

Se.cllrity Se.ciirìty 

OCT 3 a 2009 

Preface 

The Department ofHomeland Security (DRS) Office of Inspector General (OlG) was 

established by the Homeland Security Act-oj2002 (Public Law 107-296) by amendment to 

the inspector General Act oj1978. This is one of a series of audits, inspection, and special 

reports prepared as part of our oversight responsibilities for pre>grams; grants and projects 

administered by th~ department under the American Recovery and Reinvestment Act of 

2009 (Recovery Act). 

This report.discusses th(i processes used r,y the department to asseSs the completeness and 

accuracy ofreports submitted -to it by recipients ofRecovery Act funds administered by the 

department and to follow upon reporting errors. 

The recommendation herein has been developed to the best knowledge available to our 

office, and has been discussed in draft wit,h those responsible for implem~ntation. We trust 

this report will resultin more-effective, efficient, .lmdeconomical operations. We express 

our appreciation to all ofthose who contributed to the 'preparation ofthis report. 

Richard L. Skinner 

Inspector General 
Table of Contents/Abbreviations 
 

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

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

Results of Review ............................................................................................................... 4 


 DHS Headquarters ......................................................................................................... 4 
 

DHS Components .......................................................................................................... 4 
 

Recommendation ........................................................................................................... 6 


 Management Comments and OIG Analysis................................................................... 6 
 

Appendices

 Appendix A: Objective, Scope, and Methodology ........................................................ 7 
 

Appendix B: Management Comments to the Draft Report............................................ 8 
 

Appendix C: Estimated Number of Award Recipients and Number of Recipients 
 

Reporting by Component for Quarterly Reporting Period 

Ending September 30, 2009 ................................................................... 11 
 

Appendix D: Detailed Reporting Requirements.......................................................... 12 
 

Appendix E: Comparison of Attributes in the Board’s Data Quality Review Guide 


 with Component Monitoring Processes ................................................ 15 
 

Appendix F: Major Contributors to This Report ........................................................ 16 
 

Appendix G: Report Distribution................................................................................. 17 
 

Abbreviations 

CBP Customs and Border Protection 
 

DHS Department of Homeland Security 
 

FEMA Federal Emergency Management Agency 
 

GSA General Services Administration 
 

ICE Immigration and Customs Enforcement 
 

OIG Office of Inspector General 
 

OMB Office of Management and Budget 
 

USM Office of Under Secretary for Management 
 

TSA Transportation Security Administration 
 

USCG United States Coast Guard 
 
OIG 
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The American Recovery and Reinvestment Act of 2009 (Recovery 

Act) provided $787 billion to the federal government to stimulate 

the U.S. economy. Of that amount, the Department of Homeland 

Security received $2.75 billion for various projects run by the Office 

of the Under Secretary for Management, U.S. Customs and Border 

Protection, U.S. Immigration and Customs Enforcement, 

Transportation Security Administration, the U.S. Coast Guard, and 

the Federal Emergency Management Agency. 

At the request of the Recovery Accountability and Transparency 

Board, we conducted a review to determine whether the department 

has established a process to perform limited data quality reviews of 

reports submitted by recipients of Recovery Act funds administered 

by the department to identify material omissions and/or significant 

reporting errors, and to notify the recipients of the need to make 

appropriate and timely changes. 

The department process for verifying the completeness and accuracy 

of data reported by recipients is evolving. The department issued 

general guidance on reviewing contractor reports on September 15, 

2009. Also, four of five components developed approaches for 

substantiating the accuracy of recipient reporting. Later, the 

department headquarters developed a method to identify nonregistrants and began providing that information to its components. 

However, the department has not yet issued detailed procedures for 

performing limited data quality reviews of recipient reporting to 

identify material omissions and significant reporting errors. 

To improve the process, we are recommending that the department 

issue formal policy and procedures to guide the agency. In an 

October 28, 2009 response to the draft report (Appendix B), the 

department generally concurred with the finding and 

recommendation. Based on the response, we consider the 

recommendation resolved but not implemented. The 

recommendation will remain open until we receive a copy of the 

department-wide policy and procedures. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

1 
 
Background 

The American Recovery and Reinvestment Act of 2009 (Recovery 

Act or ARRA) made available to federal agencies approximately 

$787 billion for preserving and stimulating economic growth in the 

United States. Components within the the Department of Homeland 

Security (DHS) received $2.75 billion for the following activities: 

AMOUNT 

COMPONENT (in millions) ACTIVITY 

Transportation $1,000 Procurement and installation of 

Security baggage and passenger 

Administration explosive detection systems at 

(TSA) selected airports 

U.S. Customs and $680 Construction/renovation of 

Border Protection land ports of entry, purchase of 

(CPB) non-intrusive inspection 

systems, development and 

deployment of the Secure 

Border Initiative Program, and 

the upgrade of tactical 

communications 

Federal Emergency $610 Grants for Emergency Food 

Management and Shelter National Board 

Agency (FEMA) Program, Public 

Transportation and Railroad 

Security Assistance, Port 

Security, and Assistance to 

Firefighters for the 

construction/renovation of 

non-federal fire stations 

U.S. Coast Guard $240 Alteration of bridges, 

(USCG) improvements to shore 

facilities, and repairs to vessels 

Office of the Under $200 Continued development of the 

Secretary for DEPARTMENT consolidated 

Management headquarters 

(USM) 

U.S. Immigration $20 Upgrade of its tactical 

and Customs communications system 

Enforcement (ICE) 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

2 
 
To complete these activities, the department has and will be 

awarding contracts and grants to government, non-profit, and forprofit organizations (hereinafter referred to as recipients). See 

Appendix C for status of awards and number of award recipients 

registered in www.FederalReporting.gov for the quarter ending 

September 30, 2009. 

Section 1512 of the Recovery Act requires any recipient of 

Recovery Act funds directly from a federal agency to submit a 

report not later than 10 days after the end of each calendar quarter. 

The reports include information on the status of recovery funds; lists 

of projects undertaken; and project information, such as jobs 

created. Recipients must register and submit data through 

www.FederalReporting.gov, the online Web portal that will collect 

all Recovery Act recipient reports. The Office of Management and 

Budget (OMB) subsequently issued guidance1

 to provide federal 

agencies and recipients of funding with information necessary to 

effectively implement the Section 1512 reporting requirements. See 

Appendix D for detailed information on reporting requirements. 

Section 1521 of the Recovery Act created the Recovery 

Accountability and Transparency Board2

 (the Board) to “coordinate 

and conduct oversight of covered [Recovery Act] funds to prevent 

fraud, waste, and abuse.” As part of its oversight activities, the 

Board developed a guide3

 for use by the Inspectors General in 

reviewing “whether Federal agencies have established a process to 

perform limited data quality reviews intended to identify material 

omissions and/or significant reporting errors, and notify the 

recipients of the need to make appropriate and timely changes.” 

In a September 15, 2009 message to the Inspector General 

community, the Board advised Inspectors General to use the guide 

to conduct agency reviews and to submit final reports on the results 

of the reviews to the Board by October 30, 2009. The Board will 

compile the results of these reports and issue a consolidated report 

that will identify any systemic issues and, if appropriate, make 

recommendations for improvements across the federal government. 

1 OMB Memorandum M-09-21 dated June 22, 2009, Implementing Guidance for the Reports on Use of Funds Pursuant 
 

to the American Recovery and Reinvestment Act of 2009. OMB M-09-21 is not applicable to federal contracts. 
 2

 The Board consists of a Chairman and 12 Inspectors General from the Departments of 
 

Agriculture, Commerce, Defense, Education, Energy, Health and Human Services, Homeland Security, 
 

Interior, Justice, Transportation, Treasury, and the Treasury Inspector General for Tax Administration. 


3

 The guide is entitled Data Quality Review Guide for the Inspector General Community. 
 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

3 
 
	 

	 

	 

Results of Review 

The department process for verifying the completeness and accuracy 

of data reported by recipients is evolving. The department issued 

general guidance on reviewing contractor reports on September 15, 

2009. Also, four of five components developed approaches for 

substantiating the accuracy of recipient reporting. Later, the 

department headquarters developed a method to identify nonregistrants and began providing that information to its components. 

However, the department has not yet issued detailed procedures for 

performing limited data quality reviews of recipient reporting to 

identify material omissions and significant reporting errors. 

DHS Headquarters 

The department intended to contract for an integrated project 

management approach to ensure the accuracy of the recipientreported data. The department officials, however, said that the 

planned approach was not implemented because it was too costly. 

After the close of the September 30, 2009 reporting period, the 

department: 

•	 Developed a means to compare the department data with data 

in Federal Reporting.gov to identify non-registrants and 

provided the information on non-registrants to the appropriate 

component for follow up. 

•	 Started to download recipient reported data, converting it to an 

excel spreadsheet, and supplying the data to components for 

use in testing and verification, and 

•	 Reached out to its components to identify best practices for 

verifying reported data. 

DHS Components 

Lacking specific guidance from the department headquarters on how 

to perform data quality reviews, FEMA, CBP, USCG, and ICE, 

developed their own approaches to monitor recipient reporting. 

TSA, however, has yet to develop a methodology. A relevant 

discussion on each department component receiving Recovery Act 

funds follows: 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 

American Recovery and Reinvestment Act of 2009 Funds 

4 
 
	 

	 

	 

	 

	 

	 

•	 FEMA completed preliminary recipient reporting and data 

quality review procedures to identify and mitigate material 

omissions and significant errors. FEMA also developed risk 

categories and criteria for the evaluation of recipient data. 

FEMA’s monitoring strategy consists of a preferred and backup 

plan to ensure recipients comply with the OMB reporting 

requirements. FEMA will conduct random samples of recipient 

records for its ARRA grant programs. 

•	 USCG developed an ongoing weekly review process beginning 

on day 11 through 29 following the end of each quarter to ensure 

recipients report data on a timely basis. The review process will 

identify material omissions and significant errors. Additionally, 

USCG incorporated periodic meetings with USCG top 

executives and contracting officials to identify critical issues and 

the status of all Recovery Act projects. Policies and procedures 

were also developed to ensure recipients comply with contract 

terms and to identify potential risk factors that may exist. 

•	 ICE developed a preliminary four-step review plan. The four 

levels of review and the weekly reporting process occurs during 

day 11 through 21 following the end of each quarter. This 

review process enables ICE to perform quality checks of the data 

and to review recipient data for accuracy and reasonableness. 

•	 CBP developed a detailed plan to review the data quality of 

recipient reporting. CBP established standard operating 

procedures to ensure recipient reporting is in compliance with 

OMB directives, an audit program to identify material omissions 

and significant reporting errors, and a risk mitigation template 

which identifies potential risks and mitigation efforts. 

•	 TSA did not develop policies or standard operating procedures 

regarding recipient reporting. 

•	 USM transferred $199 million of the $200 million appropriated 

for the continued consolidation of the department headquarters 

to the U.S. General Services Administration (GSA) through a 

reimbursable work agreement. The department officials advised 

us that GSA is responsible for reporting on the status of funds 

and for verifying recipient reports, and that a memorandum of 

agreement specifying these and other terms is being developed. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

5 
 
See Appendix E for a comparison of attributes measured in the 

Board’s Data Quality Review Guide with component monitoring 

processes. In general, FEMA, USCG, ICE, and CBP developed 

procedures consistent with the Board’s Data Quality Review Guide. 

Recommendation 

We recommend that the Senior Accountable Official for the 

department issue department-wide policy and procedures for 

performing data quality reviews of recipient reporting to identify 

material omissions and/or significant reporting errors. The policy 

and procedures should be based, in part, on an evaluation of 

component-developed processes, component characteristics, and 

best practices of other federal agencies. 

Management Comments and OIG Analysis 

In an October 28, 2009 response to the draft report (Appendix B), 

the department generally concurred with the finding and 

recommendation. Based on the response, we consider the 

recommendation resolved but not implemented. The 

recommendation will remain open until we receive a copy of the 

department-wide policy and procedures. 

The reply also presented information on actions by the department 

since completion of our field work and comments on the draft 

report. We made changes to the draft report as appropriate on the 

basis of the comments. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

6 
Appendix A 

Objective, Scope, and Methodology 

The objective of this review is to determine whether the department 

and its components established a process to perform limited data 

quality reviews intended to identify material omissions and 

significant reporting errors, and notify the recipients of the need to 

make appropriate and timely changes. 

We reviewed the department’s process for monitoring recipient 

reporting of recovery funds as of September 30, 2009. Our 

fieldwork was conducted at FEMA, TSA, USCG, ICE, CBP, and the 

department headquarters in September and October 2009. To 

accomplish our objective, we examined applicable policies, 

procedures, and internal directives used by the department to 

administer and monitor recipient reporting. We also interviewed the 

department headquarters and component officials responsible for 

managing and overseeing recipient reporting. We did not, however, 

verify the accuracy of data provided by the department or test the 

effectiveness of processes designed by the department to measure 

the quality of recipient reporting because it was not required by the 

Board. 

We conducted this review according to the Quality Standards for 

Inspections issued by the President’s Council on Integrity and 

Efficiency. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

7 
Appendix B 

Management Comments to the Draft Report 

U;8. Dcpiirtment.ofBomclaDd Sc,Dr!ty 

WlIhligton, DC 205ZS 

OCT 21,2009
 Homeland Security 

MEMORANDUM FOR:	 Richard L.Skil'er 

ll'spectorGeneral 

De..p.artm. entof.Home.~land. s.&C. u rity . .
 

FROM:	 Brian de Vallance . 

DHS Senior Account b . Offlal 

AmerIcan Reco\leryandRè-lniiestment Act
 

Department of Homeland Security 

SUBCT: DRAFT REPORT: Process Used by the Departentof Homeland Security to 

Monitor Reportng by Recipients of American Recovery and Reinvestment Act of 2009 Funds 

The Executive Summary of .tle subject report st!1testh!1t, 'We found tha.t the department has an evolving proess for examining recipient reportng. To Improve the process, we recommended that DHS Issue formal 

policy and proci;dures to guide the agency." The Department generally COnc;\lrs with that statement, and 

notes that not only istheOepartentalove.rsight of the Recipient Repo.rtng proess of an evolYng nature, the 

Guldanceanddlrectlon frQm OMS, OFFill!. OFPP and .the .ReCQvery Implementation Offce Is also evolving. 

Guidance is distrbutec;. through a variety for a, inch,iding the OMS Max website, Town HaU Meetlng$ and twice 

weekly Conference calls ("ter alia. D,"S, like cither agel'cles, strives tQ keep pace with this ever..hanglng

landscape. 

In the sectonentltled, "Results of RevieW' the followil'g statementls m!1de, "Howevi¡r, DHS has nt;tyet 

i$sued proceduri¡$ for perfClrmlng limited data qualityrevlliWll of recipient rlipOrtng to Identify material 

cimli;sions !1niiorsignlfiQant repClrting errørs, !1nd..to notify the recipients; øf the l'-llid to miake approprtateand 

timely changes. · 

The Oep!1rtment feølsthlit this statement is overly broac;. For example, the Offce of the Chief Procurement 

Oficer (OCPO) ha$ ii;sued Oep!1rtlint-wlde prø.cedures fClr dlita quality reviews of recipient reports 

submitted by DHS contr!1.ctClt$ In Acquisition Ahart 09-14, Recovery Act ccntract Actions - Implementation and Review of Contrctor Reports, .The origil'al Alert wai ii;si.ed Ol' September15, 2009.. The Alert was 

subllequ~mtiy updatlid(Amendment 01) on October 7,2009t91ncol'rateaddillon!11 guidance resulting from 

the Office cif Federal Procurement Policy (OFPP) memorandUm diatedSeptemb-lr 30. 2009, Interim Guidance 

on Reviewlrg ContrctorRepOrfs on the Use Of Recovery ActFimds In ACCQrQsnce with FAR Clause 52.204­

11. OCPO provIded a copy of the d.rafLAlert tathe OIG at the September 11. 20.09, meetini;, Atlhemeetlng with the IG on October 13, 2009, the OIG representatives indicated they h!1d seen both the fin!1l version of the 

origin!1l Alert and Amendment 01. The Oep!1rtmentbelleves that the DHS OCPO procedure$ for data quality 

reviews of contt!ctor recipient report meet. thli follClwlng !1ttb\ltes listed In AppendiX E of the draft report: 

1, Acquisiton Alert 09-14 est!1blishes policies and procedures for reviewing quarterly reciplentreport
 

submitted by connctors consistent with OMB Memot!nda M-09-10, M.09.15, !1nd M.09-30; Federal 

Acquisition RegulatiCln (FAR) 4.1501 !1nd 52.204-11; Federal RegIster notices Issued by the Civilian 

Agency Acquisition Councli on August 25, 2009 (74 FR 42877) al'd September 25, 2009 (74 FR 

48971); ànd the OF?? memClt!ndumof September 30, 2009. As noted In foo.lnote 1 on pagli 3 of the 

dt!ft report,OMB M-09-21 does not !1pply to contmcts. The procures include: 

. Arequirement to specitcally notifylremlnd eachèontmctor ofitsreporLlng responsibilties and to provide certin d!1ta elements necessary to Identify the connct consistent with data 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 

American Recovery and Reinvestment Act of 2009 Funds 

8 
Appendix B 

Management Comments to the Draft Report 

entered in the Federal Procurement Data System (FPDS). The Alert includes a detailed 

sample. leter for ColitrctingOffcers to use. 

· Direction to registerat FedetaIRepomng.gov,
 

. A requirement to complete designatèd OMBWebinar trining modules.
 

. Procedures for conflrmingthat award information is accurate and for identifying signifcant 

errors ånd material omissions. 

. Authority to delegate review responsibilities to the Contring Offcets Technical 

Representative (COTR), subjec to th.e same trining requirements. The Alert includes a 

detl'iled sample delegation memorandum. 

. Guidance on assigning review responsibilties under Interagency Agreements.
 

. Specifc tlmeframes for tie notification to contrctors and completion of trining, In addition to
 

the government-wide tlmeframes established fotthe foral review procesS.
 

2. Thetransmission oUhe Alert to Components on September 15,2009, included a list of the DHS 

Recvery Act actions reported to the Federal Procurement Data System as of September 15, 2009. 

3. Consistent with FAR and OFPP requirements, the 	 Alert designates the Contracting Offcer as the 

responsible reviewing offcial, withauthorily delegate to thèCOTR. As noted above, thE! Alert 

provides detailed procedures and timefremes to promote contractor compliance and effective data 

quality revieWs. 

4. Section4.C(5) Of the Alert provides policy and procedures for detecting material omissions and 

significant reportng errrs. These are also incorporated Into tlsample delegation to the COrR. 

5. Consistent with FAR 4.1501(C) and (d) and OFPP's September 30,200S memorendl.m, 	 sectons 

4.0(6) and (7) an(l4.D(4) of the Alert reinforc the Contrcting Offcets responsibility to apply 

appropriate contractual remedies for noncompliance with reporting requirements. As note.din 

OFPP's memorandum. the specific remedies will be determlned case-by..se based onthesevetlty 

of the noncompliance. 

6. The review proedures and compliance with FAR 4.1501 wll assess compliance with award 

agreement terms and conditions, both for cømpllance with submission requirements and for achieving 

contractgoais (checking the contractor's report on project progress forreasOn!!bleresS and
 

consistency with other sources .of project progress iofrmaticm).
 

7. The Alert dol'S not specifically address risk assessment. However, the quarterly r!!port WOl.ld b!! 

One sourceofinformatlontogether with other contrctor progress report and InfOrmaton obtained 

during performance monitoring for program management to identif cost schedule, or performance 

risks; 

8. With a few exceptions, DHS Recovery Act contracts are and will be fixed pric!!. For thes!!, payment Is 

based on actual work performed and accepted - services Performed andlor supplies received. For 

the few costlype contracts that DHS wil award. the quartrly recipient report should notb.ethe only 

source of informal ion of project progress. The contractor wll be submittng invoices once a month or 

more frequently as provided und!!r the contract The COTR should be receiVing more frequent 

report of progresEithrough formal report andlor periOdic monitoring (phone calls, emalls, etc.). 

Relying on the quarterly reports WOUld not provide timely information f()r Invoice review and apProval, 

The contractots quarterly reports wil be checked for accuracy against other more timely Information 

that DHShas on contrctor performance. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of
 

American Recovery and Reinvestment Act of 2009 Funds
 

9 
Appendix B 

Management Comments to the Draft Report 

Later in that section, iatthe beginning of the discussion on DHS Components ltisstates thøt, "TSA, however; 

has yet to develop a methodology! The Department believes that policies devE)lopedsubsequentto the initial 

røview atTSAoffrs adlfførentpicturø. TSAwasthefirst component interviewed by thø DHS QIG, two days 

following the /'ceîpt of DHS AcqUisition Alert 09-1400 September 15,2009, It is correct that attlat point in 

time. TSA bad not yet drafted a policy to Implement the reuirements.. However, prior to the deadllneforthe 

submission ()fcontractor report on Ocober 10, '2009, TSA proided to the aCQuisition pers()nnelinvolved 

with Recvery Act implementation, a draf policy to provide guidance to ensure that all Reçovery Açtreporting 

requirements are properlY satisfied. Qn October 14, 2009, TSA finalized this policy following Issuance of. DHS 

Acquisition Alert 09-14 Amendment 1, which was. issued Qctober 7,2009. This TSA pOlicy wasprovidØd to 

the DHS. QIG on Qctober19, 2009. Additionally, TSAcontracting and proram personnel røeived training 

from the DHS Offce of the Chief Procurement Qffcer(OCPO) po Qctober 9,2009. Thøreforø, the 

Departent believes that the existønce and substantie content of this policy sl'OUld bø reflected .in the OIG's 

finaireport Additionally, the information c()ntalned in AppendixE of the report should be updated to reflect 

the policy's comparison with the atlriliutes contained in that Appendix. 

Oter comments:
 

In the summary of USCG and ICE Pl'dures refer to wøekly progress reviews ofl'cipientreportdata. It Is 

notcleat whether this iapplles to a weekly rèvieWdUringthe formalsl.bmissionaod reviewpl'ocess each 

quaier(Day1 throgll49 each Jam.lsry, April, July and October). Since report are .submitted only ona 

quartrly basis snp cannot be revised until the nextleportlng cycle, thel' would seem to be no need fOra 

review every week, DUring the review cycte, OCPOhas questioned whether weekly reviews are suff.cient In 

practice there have been daiiy conferènces between the Components and the Departmental Coordination 

offçe to track Progl'SS and solve problems. tn the sUmmary of actions taken by FEMA, the report stiates that, 

"FEMA wil conduct random samples of recipient recrds for its ARRA grant pr09l's:Sloce tle IG'.s visit 

with FEMA, that Component has developed an integratedtQol that they have used to accomPlIshEl100% 

electonic revlewthathlglillghtunyreportngparameters needing indlvduallnterpretatioo or Intervention. 

l.n.Appendix 0: The footnote 1 on page 3 properly notes that OMB-09-21 doesnotapplyto contract~ 

However,l!t bot "Days 1-10" and Days 11-21,øAppendlx D refers to reviews by "contracting officials." 

Appendix D should more clearly explain the applicable guidance and should add references to reviews by 

grants offcials and those responsiblefør I'viewlng report under Other Transactions. Altrnatively, the 

Appendix could delete refel'nces to "contracting offcials" and use only a generic reference to "the DHS 

Componentø 

Undel' .Pay 30," the report states that "(tlhEl DHSComponeliti$leauired to POsntie detailed prime recipient 

I'ports on ww.Recovery.gov.d This Is not accuratø, FederaiReportinG.gov wil automatically transfer the 

I'port, forall recIpients andal.l agencies, to Recovery.gov. Thøl'ls no action reqi.!Ired by any Federal 

agency. 

In Appendix E: The first attribute references M~09-21. It should also reference policy that applies to contracts, 

Under the last attribute, the FEMA process notes that FEMA wil."use contrct terms to address noncompliance." OCPO believes the correct reference should be to. "grant terms" as FEMA has nb contrct 

actions issued Under the Recovery Ac only Grants. 

The Departent appreciatø$ the opportunity to provide these views and looks forward to continue working 

with the .IG Recovery Aet.eam to address rlsks,idElntlfy l!reas of concern and address them cooperatively 

and collaboratlvely. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 

American Recovery and Reinvestment Act of 2009 Funds 

10 
 

Appendix C 

DHS Reported Status of Awards and Number of Award Recipients Registered in 

www.FederalReporting.gov 

Recipient Data FEMA TSA USCG ICE CBP HQ Total 

Number of Awards as of 

September 30, 2009 335 52 12 10 1 1 411 

Number of Recipients 

Registered as October 318 51 10 10 1 1 391 

2009 

Number of Recipients 

not Registered 17 1 2 0 0 0 20 

Percentage of 

Recipients Registered 94.9 98.1 83.3 100 100 100 95.1 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

11 
 

 

	 

	 

	 

	 

	 

	 

	 

 

Appendix D 

Detailed Reporting Requirements 

Under the Recovery Act and OMB M-09-21 entities that receive 

recovery funds are defined as “recipients”. Section 1512 of the 

Recovery Act states that a recipient “means any entity that receives 

recovery funds directly from the Federal Government (including 

recovery funds received through grant, loan, or contract) other than 

an individual; and includes a State that receives recovery funds.” 

OMB M-09-21 says that there are two primary reporting groups: 

prime recipients and sub-recipients. “The prime recipients are nonFederal entities that receive Recovery Act funding as Federal awards 

in the form of grants, loans, or cooperative agreements directly from 

the Federal government” and “a sub-recipient is a non-Federal entity 

that expends Federal awards received from another entity to carry 

out a Federal program but does not include an individual who is a 

beneficiary of such a program.” Federal agencies are not considered 

prime- or sub-recipients. 

The data required for reporting consists of the following: 

	 The total amount of recovery funds received, expended or 

obligated to projects or activities; 

	 A detailed list of all projects or activities for which recovery 

funds were expended or obligated, including: 

	 the name of the project or activity; 

	 a description of the project or activity; 

	 an evaluation of the completion status of the project or 

activity; 

 an estimate of the number of jobs created and retained by 

project or activity; 

 the purpose, total cost, and rationale of the agency for 

funding infrastructure investments with recovery funds; and 

	 a contact person. 

	 Detailed information on any subcontracts or sub-grants awarded 

by the recipient to include the data elements required to comply 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 

American Recovery and Reinvestment Act of 2009 Funds 

12 
Appendix D 

Detailed Reporting Requirements 

with the Federal Funding Accountability and Transparency Act 

20064

, allowing aggregate reporting on awards below $25,000 or 

to individuals, as prescribed by OMB. 

Prime recipients will submit data via www.FederalReporting.gov on 

a quarterly basis (no later than the 10th day following the end of the 

quarter). The first reporting period will be October 10, 2009. 

Reporting cannot be combined with existing federal reporting 

requirements. Waivers will not be granted for any recipients 

required to report. Non-compliance will be considered a violation, 

and violators will be subject to the stipulations outlined in the award 

terms and conditions. 

In addition, the OMB guidance requires that the information 

reported by recipients be made public via www.Recovery.gov no 

later than the 30th day following the quarter end. The relationship 

between FederalReporting.gov and Recovery.gov is depicted in 

Figure 1. 

Figure 1 

4 The Federal Funding Accountability and Transparency Act of 2006 (P.L. 109-202) requires OMB to ensure 

the existence and operation of a single searchable website, accessible by the public at no cost to access, that 

includes for each Federal award - (A) the name of the entity receiving the award; (B) the amount of the 

award; (C) information on the award including transaction type, funding agency, the North American 

Industry Classification System code or Catalog of Federal Domestic Assistance number (where applicable), 

program source, and an award title descriptive of the purpose of each funding action; (D) the location of the 

entity receiving the award and the primary location of performance under the award, including the city, State, 

congressional district, and country; (E) a unique identifier of the entity receiving the award and of the parent 

entity of the recipient, should the entity be owned by another entity; and (F) any other relevant information 

specified by the OMB. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

13 
	 

	 

	 

Appendix D 

Detailed Reporting Requirements 

The key reporting activities performed are outlined below. 

All reporting recipients and reviewing federal agencies must be 

registered as authorized parties prior to submitting or reviewing 

recipient reports on www.FederalReporting.gov. 

Days 1 – 10: The reporting entities are storing the data to be 

submitted and making the necessary changes prior to submission to 

www.FederalReporting.gov. All reporting entities must submit data 

by the 10th day and those who do not will be considered as noncompliant. 

Days 11 – 21: The prime recipients will review the data submitted 

by the sub-recipients and notify them of any significant reporting 

errors or material omissions. Also during this time, the department 

components will review the reports submitted to identify any 

significant errors or material omissions. 

Days 22 – 29: The department component will perform a formal 

data quality review of the reports submitted by the prime recipients. 

The contracting officials may perform automated checks and 

sampling methods to review data reported to identify any significant 

reporting errors or material omissions. The department component 

will classify submitted data as: 

•	 Not Reviewed by agency 

•	 Reviewed by agency, no material omissions or significant 

reporting errors 

•	 Reviewed by agency, material omissions or significant reporting 

errors identified5 

Day 30: The department component shall make the detailed prime 

recipient reports available on www.Recovery.gov so that the public 

is made aware of how the recovery dollars are being allocated and 

spent. Issues identified after the data has been posted will be 

corrected in the following quarterly report. 

5

 This classification will require the DHS to submit these findings to recoveryupdates@gsa.gov so the Board 

can publicize this information on www.Recovery.gov. 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

14 
DHS COMPONENT PROCESSES 

Attribute FEMA CBP USCG ICE TSA 

Do policies and procedures 

exist for reviewing 

Quarterly Recipient 

Reporting pursuant to OMB 

M-09-21? 

Yes Yes Yes Yes Process not yet 

developed. 

Does Plan for review 

include a process for 

identifying the recipient 

reporting universe? 

Yes Yes Yes Yes Process not yet 

developed. 

Does plan for review 

describe how the component 

will ensure that it conducts 

required reviews of reported 

data.? 

Yes - Provides for 

reviews of key 

reporting data and 

random sampling of 

universe. 

Yes - Provides for 

contracting officials 

to perform 

necessary reviews 

Yes - Includes a 

checklist providing 

for weekly 

examinations and 

random sampling of 

reporting universe 

Yes - Provides for 

a four-level review 

process. 

Process not yet 

developed. 

Do policies and procedures Yes- Provides for Yes - Includes audit Yes- Includes Yes - Reviews will Process not yet 

exist to detect material automated or program to identify regular reviews be conducted, developed. 

omissions and significant manual matching of material omissions including errors/omissions 

reporting errors? data, as applicable, 

and weekly 

meetings to discuss 

material omissions, 

significant errors 

and validation of 

data submitted. 

and significant 

reporting errors. 

reconciling invoices 

to reports and 

weekly discussions 

with contracting 

officials to discuss 

omissions/errors. 

will be acted on by 

contracting 

officials, and 

actions will be 

monitored by the 

Office of the Chief 

Information 

Officer and Chief 

of Staff 

Does process exist to Yes- Provides for Yes - Provides for Yes - Provides for Yes – Incorporates Process not yet 

remediate systemic or contacting recipients use of an audit contacting regular contracting developed. 

chronic reporting problems? for corrections and 

enforcing contract 

terms to address 

non-compliance. 

program to 

remediate reporting 

problems. 

recipients for 

corrections and 

enforcing contract 

terms to address 

non-compliance. 

oversight to 

address contractor 

performance and 

reporting 

problems. 

Recipient-reported 

information can be used to 

assess compliance award 

agreement terms and 

conditions? 

Yes - Will assess 

compliance by 

using data reported 

by recipients for an 

information 

framework and by 

importing award 

data into an 

Enterprise Data 

Warehouse. 

Yes - Will reconcile 

projected to 

reported data; and 

will cross-check 

prime and subrecipient data to 

prevent duplicates. 

Yes - Will provide 

an information 

framework to assess 

compliance using 

reported data. 

Yes - Will 

compare data 

submitted by 

contractors with 

expected project 

baselines and 

milestones, and 

follow- up as 

necessary. 

Process not yet 

developed 

Recipient-reported 

information can be used to 

assess risk? 

Yes- Will categorize 

and review 

submitted data to 

identify awards/ and 

reporting 

compliance risks. 

Yes- Developed a 

risk and mitigation 

template to identify 

potential risks and 

mitigation efforts, 

and to assess 

results. 

Yes- Will 

categorize 

recipients using a 

risk approach and 

identify higher-risk 

recipients. 

Yes- Will use 

substantiated data 

reported to further 

assess current 

risks and identify 

new risks. 

Process not yet 

developed 

Recipient-reported Yes- Will work Not Applicable ­ Not Applicable ­ Yes- Will measure Process not yet 

information can be used to directly with This does not apply This does not apply useful information developed 

determine when remaining recipients for to fixed-priced to fixed-priced against project 

funds are released? corrections and use 

grant terms to 

address noncompliance. 

contracts used by 

this component 

contracts used by 

this component 

deliverables and 

expenditure plans 

to assess remedial 

actions. 

Appendix E 

Comparison of Attributes in the Board’s Data Quality Review Guide with 

Component Monitoring Processes 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

15 
 
Appendix F 

Major Contributors to This Report 

 Roger LaRouche, Director 

 William Gillies, Audit Manager 

 Stephen Doran, Auditor 

 Kendra Morgan, Auditor 

 Pamela Weatherly, Program Analyst 

 James Bess, Referencer 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 
 

16 
 
Appendix G 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff for Operations 

Chief of Staff for Policy 

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 

Under Secretary for Management 

DHS Acting Chief Procurement Officer 

Director, Office of Procurement Operations 

DHS Component Liaison, FEMA 

DHS Component Liaison, CBP 

DHS Component Liaison, TSA 

DHS Component Liaison, USCG 

DHS Component Liaison, ICE 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

Process Used by the Department of Homeland Security to Monitor Reporting by Recipients of 
 

American Recovery and Reinvestment Act of 2009 Funds 

17 
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. 

OIG HOTLINE 

To report alleged fraud, waste, abuse or mismanagement, or any other kind of criminal or noncriminal 

misconduct relative to department programs or operations: 

• Call our Hotline at 1-800-323-8603; 

• Fax the complaint directly to us at (202) 254-4292; 

• Email us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigations - Hotline, 

245 Murray Drive, SW, Building 410, 

Washington, DC 20528. 

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