Department of Homeland Security
 

The State of Washington’s Management 

of Urban Areas Security Initiative Grants 

Awarded During Fiscal Years 

2007 through 2009 

OIG-12-27 January 2012
 
         

 

 

Office of Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

JAN 20 2012

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 addresses the State of Washington’s management of Urban Areas Security 

Initiative grants awarded during fiscal years 2007 through 2009. We contracted with the 

independent public accounting firm Williams, Adley & Company-DC, LLP to perform 

the audit. The contract required that Williams, Adley & Company-DC, LLP perform its 

audit according to generally accepted government auditing standards. Williams, Adley & 

Company-DC, LLP’s report identifies two reportable conditions where State management 

of the grant funds could be improved, resulting in four recommendations addressed to the 

Assistant Administrator, Grant Programs Directorate. Williams, Adley & Company-DC, 

LLP is responsible for the attached auditor’s report dated November 30, 2011, and the 

conclusions expressed in the report. 

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. 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 
 

November 30, 2011 

Anne L. Richards 

Assistant Inspector General for Audits 

Office of Inspector General 

U.S. Department of Homeland Security 

245 Murray Drive, SW, Building 410 

Washington, DC 20528 

Dear Ms. Richards: 

Williams, Adley & Company-DC, LLP performed an audit of the State of Washington’s 

management of the Department of Homeland Security’s Urban Areas Security Initiative 

grants for Fiscal Years 2007 through 2009. The audit was performed in accordance with 

our Task Order No. TPD-FIG-BPA-07-0013-0002, dated September 27, 2010. This 

report presents audit results and includes recommendations to help improve the State’s 

management of the audited Urban Areas Security Initiative grants. 

We conducted our audit in accordance with applicable Government Auditing Standards. 

The audit was a performance audit as defined by Chapter 1 of the Standards and included 

a review and report of program activities with a compliance element. Although this audit 

report comments on costs claimed by the State, we did not perform a financial audit, the 

purpose of which would be to render an opinion on the State of Washington financial 

statements or funds claimed in the Financial Status Reports submitted to the Department 

of Homeland Security. 

We appreciate the opportunity to have conducted this audit. Should you have any 

questions, or if we can be of any further assistance, please contact me at 202-371-1397. 

Sincerely, 

Williams, Adley & Company-DC, LLP 

Jocelyn Hill 

Partner 

WILLIAMS, ADLEY & COMPANY-DC, LLP 

Certified Public Accountants / Management Consultants 

1030 15th Street, NW, Suite 350 West • Washington, DC 20005 • (202) 371-1397 • Fax: (202) 371-9161 

www.williamsadley.com 
Executive Summary ........................................................................................................... 1
 

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

Results of Audit ................................................................................................................. 2
 

Urban Area Grants Management Practices Were Generally Effective, 


But Require Some Improvements .......................................................................... 2
 

Urban Area Strategy Needs Improvement ................................................................... 3
 

Recommendations ........................................................................................................ 8
 

Management Responses and Auditors’ Analysis ......................................................... 8
 

Lack of Assessment Process to Measure Improvement ............................................... 9
 

Recommendations ...................................................................................................... 10
 

Management Responses and Auditors’ Analysis ....................................................... 10
 

Appendices 

Appendix A: Purpose, Scope, and Methodology ..................................................... 12
 

Appendix B: Management Responses to the Draft Report ..................................... 15
 

Appendix C: Homeland Security Grant Program Background ............................... 20
 

Appendix D: Washington Military Department Emergency Management
 

Division Organization ........................................................................ 21
 

Appendix E: Report Distribution ............................................................................ 22
 

Table of Contents/Abbreviations 

Abbreviations 

DHS Department of Homeland Security 

FEMA Federal Emergency Management Agency 

FY fiscal year 

OIG Office of Inspector General 
 

 

 

OIG
 

Department of Homeland Security 

Office of Inspector General 

Executive Summary 

Public Law 110-53, Implementing Recommendations of the 9/11 

Commission Act of 2007, requires the Department of Homeland 

Security, Office of Inspector General, to audit individual states’ 

management of State Homeland Security Program and Urban 

Areas Security Initiative grants. This report responds to the 

reporting requirement for the State of Washington and its Urban 

Areas Security Initiative grants. 

The objectives of the audit were to determine if the State of 

Washington distributed and spent Urban Areas Security Initiative 

grant funds (1) effectively and efficiently and (2) in compliance 

with applicable federal laws and regulations. We were to also 

address the extent to which grant funds enhanced the State of 

Washington’s ability to prevent, prepare for, protect against, and 

respond to natural disasters, acts of terrorism, and other man-made 

disasters. The audit included a review of approximately 

$32 million in Urban Areas Security Initiative grants awarded to 

the State of Washington during fiscal years 2007 through 2009. 

Generally, the State did an effective and efficient job of 

administering the program requirements, distributing grant funds, 

and ensuring that all available funds were used. The State formed 

working groups to establish priorities and spent grant funds in 

accordance with such priorities and applicable federal laws and 

regulations. 

However, we identified two areas for improvement: the Urban 

Area strategy and the assessment process to measure improvement. 

Our four recommendations call for the Federal Emergency 

Management Agency to initiate improvements which, when 

implemented, should help strengthen program management, 

performance, and oversight. Written responses to the draft report 

are incorporated as appropriate and included in their entirety in 

appendix B. 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 1 
Background 

The Homeland Security Grant Program provides federal funding to 

help state and local agencies enhance capabilities to prevent, 

protect against, respond to, and recover from terrorist attacks, 

major disasters, and other emergencies. 

The State of Washington (State) received $90.8 million in 

Homeland Security Grant Program funds, administered by the 

Federal Emergency Management Agency (FEMA) during fiscal 

years (FY) 2007, 2008, and 2009. This included $32 million in 

Urban Areas Security Initiative grants. Appendix A provides 

details on the purpose, scope, and methodology for this audit. 

The Governor of the State of Washington designated the 

Washington Military Department, Emergency Management 

Division as the State Administrative Agency, the entity responsible 

for administering the Homeland Security Grant Program. The 

State Administrative Agency is responsible for managing the grant 

programs in accordance with established federal guidelines and 

allocating funds to local, regional, and other county government 

agencies. The State of Washington designated Seattle, its 

surrounding counties, and the City of Bellevue as the Urban Area 

for the state. The Washington Military Department, Emergency 

Management Division organization is depicted in appendix D. 

Within the State of Washington, the State Administrative Agency 

subawarded Urban Areas Security Initiative funds to three counties 

(King, Pierce, and Snohomish), three state agencies (University of 

Washington, Washington State Patrol, and Washington 

Department of Health), one city (Bellevue), and one local agency 

(Seattle Police Department). 

Results of Audit 

Urban Area Grants Management Practices Were Generally 

Effective, But Require Some Improvements 

Overall, the State did an efficient and effective job of administering the 

program requirements, distributing grant funds, and ensuring that all 

available funds were used. The State formed working groups to establish 

priorities and spent grant funds in accordance with such priorities and 

applicable federal laws and regulations. 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 2 
However, as demonstrated by the results contained in this report, 

improvements are needed with respect to the Urban Area strategy and the 

assessment process to measure improvement. 

Urban Area Strategy Needs Improvement 

The Seattle Urban Area strategy did not contain adequately defined goals

and objectives to use in measuring performance. The strategy had not 

been updated since 2005 and was not linked to the grant application. As a 

result, the State did not have a basis for measuring improvements in its 

preparedness and response capabilities. 

Goals and objectives are not measurable and time-limited 

The goals and objectives in the strategy are not measurable and

time-limited. The strategy says that goals should be achieved

through the objectives by December 2007; however, there are no

specific target dates to identify when individual objectives are to

be achieved. Further, the strategy does not provide an adequate 

basis for measuring progress during fiscal years 2007 through 

2009. 

Department of Homeland Security (DHS) State and Urban Area 

Homeland Security Strategy Guidance on Aligning Strategies with 

the National Preparedness Goal, dated July 22, 2005, states that a 

comprehensive strategy should contain both broad-based, longterm goals and corresponding short-term objectives that address 

areas of prevention, protection, response, and recovery 

enhancements within the State or Urban Area. In addition, the 

primary determinants of an overall successful strategy are the 

quality of the goals and performance against those goals. The 

guidance also states that an objective sets a target level of

performance over time expressed as a tangible, measurable 

objective, against which actual achievement can be compared,

including a goal expressed as a quantitative standard, value or rate. 

An objective should be: 

 Specific, detailed, and focused — helping to identify what was

to be achieved and accomplished;

Measurable — quantifiable, providing a standard for 

comparison, and identifying a specific achievable result; 

Achievable — the objective is not beyond a state, region,

jurisdiction, or locality’s ability; 

 Results-oriented — identifies a specific outcome; and

The State of Washington’s Management of Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2007 through 2009 

Page 3
Time-limited — a target date exists to identify when the

objective will be achieved. 

State Administrative Agencies or Urban Area Working Groups 

should assess the quality of the strategy’s objectives to determine if 

the measures are meaningful in the context of a specific action

item or preparedness effort, the measurement methodology is 

sound, and the measures can be verified with reliable data. Only if 

the objectives meet these criteria should they be included in the 

strategy. 

The Government Performance Results Act of 1993 section 306 

states that plans shall contain general goals and objectives for the 

major functions and operations of the agency. The plans shall also

include a description of how goals and objectives are to be

achieved, including a description of the operational process, skills, 

and technology; and human capital information, and other 

resources required to meet those goals and objectives. All the 

plans and strategies used by the State as well as data collected from 

the State or other entities should be reported using the following 

terminology: 

 Goal – multiyear effort to implement or improve a program

 Objectives – annual effort to advance the implementation or 

improvement of a program 

Milestone – A significant phase in the implementation or

improvement in the program 

During our review of the Washington Urban Areas Security 

Initiative strategy we noted that Washington has a total of 5 goals 

with 72 objectives. We noted an overall concern with all the

objectives in regards to what was to be specifically achieved and 

the lack of standards for comparison. Table 1-1 provides 

representative examples where Seattle’s Urban Area strategy 

contained goals and objectives that did not specifically identify 

what was to be achieved or accomplished, and did not provide a 

standard for comparison: 

The State of Washington’s Management of Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2007 through 2009 

Page 4
 

Table 1-1: Representative Examples of Goals and Objectives 

Lacking Accomplishments or Standards for Comparison 

Goals Objectives 

1: Improve the Urban Area’s 

ability to DETER and PREVENT 

terrorism by identifying threats, 

vulnerabilities, weaknesses, and 

gaps within existing systems and 

infrastructure, and by enhancing 

planning, preparation, exercises, 

simulation, equipment needs, 

training, media, public awareness 

and involvement, and involve 

relevant public and private entities. 

1.5: Seattle: Preserve the 

response capability of the City of 

Seattle’s departments during a 

critical incident by improving the 

safety of all responders. 

2: Improve the Urban Area’s 2.19: Incorporate an intelligence 

ability to PREEMPT terrorism component into counterterrorism 

through cooperation, intelligence, (cyber and/or chemical, biological, 

surveillance, detection, early radiological, nuclear, and 

warning, and command and control. explosive) exercises as appropriate 

to each individual exercise. 

3: Improve the Urban Area’s 

ability to PROTECT against 

terrorism by defending critical 

infrastructure and providing 

seamless coordination and 

interoperability in any-place 

any-time activation. 

3.4: Conduct terrorist and 

chemical, biological, radiological, 

nuclear and explosive threats and 

vulnerabilities assessments for 

critical information technology 

systems and networks that support 

critical services each year and as 

new cyber alerts are provided. 

4: Improve and enhance the Urban 

Area’s ability to RESPOND to 

terrorism incident(s) with seamless 

coordination and interoperability 

between public agencies and 

private entities to minimize the 

impact of a TERRORIST and 

chemical, biological, radiological, 

nuclear and explosive event upon 

our community through 

collaboration and cooperation on 

planning strategies, policies, and 

funding. 

4.20: On a continual basis identify 

public works, other Urban Area 

jurisdictional employees, and 

volunteer associations who require 

additional training to support a 

terrorist and chemical, biological, 

radiological, nuclear, and 

explosive response and funded as 

resources become available. 

5: Improve the Urban Area’s 

ability to RECOVER from a 

terrorist attack through seamless 

coordination, public and private 

mobilization, mutual aid, and 

lessons learned. 

5.7: Ensure that the recovery 

phase of a terrorist incident is 

exercised as part of the Urban 

Area chemical, biological, 

radiological, nuclear and explosive 

training and exercise programs. 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 5
 
 

Grant applications not linked to the Strategy 

The State did not link grant applications for FY 2007, 2008, and 

2009 to the most recent strategy, prepared in 2005. The State does 

not have a process to link grant applications to the strategy, but 

instead bases its applications on annual rankings prepared by the 

State. 

Washington has established a Tri-County Inter-local Agreement as 

well as an Urban Area Core Group, Executive Group, and Urban 

Area Working Group. These groups oversee activities and 

investments for the urban areas. The Urban Area Core Group is 

comprised of voting members from five partner areas that include 

King County, the City of Seattle, Pierce County, Snohomish 

County, and the City of Bellevue. The Urban Area Core Group 

reviews rankings from the Working Group and makes changes as 

they deem necessary. The Executive Group is made up of one or 

two Directors, Chief Officers, and Senior Staff from each of the 

five partners. The Executive Group is appointed by the County 

Executives for Pierce, King, and Snohomish counties and by the 

Mayors for the cities of Seattle and Bellevue. The Executive 

Group approves and submits the strategy to the Governor for 

approval and signature. 

County and city first responder representatives who focus on 

specific disciplines make up the Urban Area Working Group, 

which acts as a liaison between the Executive Group and the 

subcommittees of the Urban Area Working Group. The grant 

application process begins when subcommittees are formed to 

discuss their particular needs and demonstrate how proposed 

projects support the strategy. Subcommittees prioritize projects 

based on assigned rankings and submit them to the Working Group 

for review. The Working Group prepares an overall ranking for 

the Urban Area and submits it to the Urban Area Core Group, 

which modifies project rankings to reflect the highest priorities of 

the Urban Area. Rankings are then sent through the State approval 

hierarchy with final approval made by the Governor. Once 

approved, the State Administrative Agency submits the grant 

application to the Department of Homeland Security. As a result, 

grant applications were based on annual rankings rather than being 

linked to the Urban Area’s strategy. 

FY 2007 FEMA Program Guidance Section V Part B.2 – Urban 

Area Homeland Security Strategy states that urban areas must 

utilize their Urban Area Homeland Security Strategy, the State’s 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 6 
Program and Capability Enhancement Plan, and the Goal and 

Target Capabilities List as the basis for requesting funds to support 

investments identified in the Investment Justification. There must

be a clear correlation between the goals, objectives, and priorities

identified in the Urban Area Homeland Security Strategy and

FY 2007 Urban Area Security Initiative program activities.

The State has not implemented a process to ensure that the Urban

Area strategy is reviewed and updated periodically to reflect

current goals, objectives, and priorities. Consequently, the State 

relies on a ranking and project prioritization process that is 

disconnected from the strategy. Funding of projects within the 

Urban Area is not focused on the highest priorities as described by 

the approved strategy, making the strategy irrelevant. Instead, the

annual rankings have become an ad hoc strategy that is shortsighted, focusing only on the current year. 

The State’s failure to link the grant application with the strategy 

hinders the Washington Military Department, Emergency 

Management Division and FEMA’s efforts in determining whether 

goals and objectives are being met and progress is being made.

Also, the strategy does not reflect two of the eight National 

Priorities as required by the September 2007 DHS State and Urban 

Homeland Security Strategy Guidance on Aligning Strategies with

the National Preparedness Goal. Because the strategy has not been

updated to reflect current priorities, it does not address: 

Implement the National Infrastructure Protection Plan

Strengthen Planning and Citizen Preparedness Capabilities 

The State has not implemented processes to ensure that the Urban 

Area strategy contains measurable and time-limited objectives, or

is periodically updated. The Urban Area strategy has not been

updated since 2005 and does not contain the required level of 

detail to develop an adequate basis for measuring progress. As 

such, FEMA’s ability to assess overall program effectiveness and

impact, and to properly report results to Congress, the Office of 

Management and Budget, and the President is hindered. 

The State of Washington’s Management of Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2007 through 2009 

Page 7
Recommendations 

We recommend that the Assistant Administrator, Grant Programs 

Directorate, direct the State Administrative Agency to: 

Recommendation #1: Develop procedures to periodically update 

the Urban Area strategy to include goals and objectives that are 

measurable and time-limited. 

Recommendation #2: Link the current grant application to the 

revised Urban Area strategy. 

Management Responses and Auditors’ Analysis 

FEMA officials concurred with the intent of recommendation 1 

and concurred with recommendation 2. The officials said that the 

National Preparedness Directorate, the FEMA entity responsible 

for developing guidance regarding the Homeland Security Strategy 

process and preparedness performance measurement systems, is 

revising the guidance and expects to release it by the end of the 

year 2011 for the FY 2012 application cycle. FEMA will require 

the State to formalize a policy and document procedures for 

updating the State strategy in compliance with the revised 

guidelines. 

In regard to recommendation 2, FEMA officials said that the State 

of Washington is currently revising its FY 2005 Seattle Urban 

Areas Strategy, and it should be ready for review the first quarter 

of FY 2012. Once it is adopted and ratified by the State and 

approved by FEMA, all future Urban Areas Security Initiative 

applications must link with the strategy. FEMA requested that 

recommendations 1 and 2 be resolved and open. However, 

because there are no firm target dates for implementing the 

corrective actions, recommendations 1 and 2 will remain 

unresolved and open. 

State of Washington officials agreed with recommendations 1 and 

2. The officials said although not required by current guidance, 

they are working on an updated strategy that will include goals and 

objectives that are measureable and time-limited. The State 

estimated that the strategy update will be completed in April 2012. 

State officials said that they link the strategic objectives in the 

State strategy to their grant application in the federal Grants 

Reporting Tool. However, the State does not base its application 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 8 
on the strategy, but rather on annual rankings prepared by the 

State. 

The Assistant Administrator, Grant Programs Directorate, needs to 

outline specific corrective actions with supporting documentation 

for implementation of the recommendations, and a timeline to 

ensure that the State’s implementation of its proposed corrective 

actions proceeds as intended. The recommendations will remain 

open until such time that corrective actions have been 

implemented. 

Lack of Assessment Process to Measure Improvement 

The State has not implemented an assessment process to measure 

improvements in preparedness. Each year the State reassesses its 

priorities without consideration of performance improvement and 

attainment of objectives that were established in prior years. The State has 

not fully incorporated the use of the Target Capabilities List established by 

FEMA to assist them in measuring improvements and identifying gaps 

according to FEMA guidance. 

The Homeland Security Grant Program Guidance and Application Kits for 

FYs 2007 through 2009 state that as part of the FY 2007, 2008, and 2009 

Homeland Security Grant Program Investment Justifications, applicants 

will be asked to establish specific capability-based outcomes associated 

with proposed investments. Progress will be measured in accordance with 

the Target Capabilities List, State and Urban Area Homeland Security 

Strategies, and applicable national plans and strategies to provide 

concrete, measurable outcomes and milestones, while preserving the 

necessary flexibility to meet unique State and Urban Area operational 

requirements. Adopting this approach sets the conditions for compliance 

with Homeland Security Presidential Directive 8 National Preparedness, 

and congressionally-directed requirements for annual state preparedness 

reports included in the FY 2007 Department of Homeland Security 

Appropriations Act. 

The State has not fully implemented or documented procedures to ensure 

that they perform an analysis of capabilities and performance with respect 

to achieving goals and objectives. For the Urban Areas Security Initiative 

program, the State recently implemented preliminary procedures for 

measuring improvement, but the procedures were not performed during 

the audited FY 2007 to 2009 time period. 

The lack of procedures for assessing performance prevents the proper 

evaluation of the Urban Area’s accomplishments to ensure that the goals 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 9 
 

and objectives are being achieved, or requested funding is still in line with 

the real threats and vulnerabilities of the Urban Area. Without good 

performance measurements, DHS may be hindered in properly 

determining the program effectiveness and impact, and may report 

imprecise results. 

Recommendations 

We recommend that the Assistant Administrator, Grant Programs 

Directorate, direct the State Administrative Agency to: 

Recommendation #3: Fully implement procedures to measure 

performance improvements and progress towards goals using the 

Target Capabilities List. 

Recommendation #4: Include performance measurements 

developed during this process in any update to the Urban Area 

Strategy. 

Management Responses and Auditors’ Analysis 

FEMA officials concurred with the intent of recommendations 3 

and 4. As stated previously, the National Preparedness 

Directorate, the FEMA entity responsible for developing guidance 

for Homeland Security Strategy processes and preparedness 

performance measurement systems, is revising the guidance and 

expects to release it by the end of the year 2011 for the FY 2012 

application cycle. FEMA will require the State to use the guidance 

to implement procedures to measure performance improvements 

and progress towards goals using the Target Capabilities List, as 

applicable. FEMA will also require the State to include 

performance measurements during the process of updating the 

Urban Area Strategy in compliance with FEMA’s revised 

guidance. FEMA requested that recommendations 3 and 4 be 

resolved and open. However, because there are no firm target 

dates for completion, recommendations 3 and 4 will remain 

unresolved and open. 

State of Washington officials agreed with recommendations 3 and 

4. The officials stated although not required by current guidance, 

they are working on an assessment of capabilities and the results 

and analysis will feed directly into the strategy update that will be 

completed in April 2012. 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 10 
The Assistant Administrator, Grant Programs Directorate, needs to 

outline specific corrective actions with supporting documentation 

for implementation of the recommendations, and a timeline to 

ensure that the State’s implementation of its proposed corrective 

actions proceeds as intended. The recommendations will remain 

open until such time that corrective actions have been 

implemented. 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 11 
Appendix A 

Purpose, Scope, and Methodology 

The objective of this audit was to determine whether the State of

Washington distributed and spent Urban Areas Security Initiative 

grant funds strategically, effectively, and in compliance with laws, 

regulations, and guidance. The goal of this audit is to identify

problems and solutions in order to assist FEMA and the State to 

improve the nation’s ability to prevent and respond to all hazards 

on a local as well as a statewide level. 

The scope of this audit included the plans developed by the Urban 

Area to improve preparedness and all hazards response, the goals 

set within those plans, the measurement of progress towards the 

goals, and the assessments of performance improvement that result 

from this activity. Further, the scope included the assessment of 

these activities within the context of risk to determine if the State’s 

plans produced strategic performance improvements related to the 

highest areas of risk rather than merely producing improvements in 

a broader sense. 

Together, the entire Homeland Security Grant Program and its five

interrelated grant programs fund a range of preparedness activities, 

including planning, organization, equipment purchase, training, 

exercises, and management and administration costs. Because of 

the interrelationship of these grant programs, all were considered 

when evaluating the planning cycle and the effectiveness of the 

overall grant program. However, only Urban Areas Security 

Initiative funding, and equipment and programs supported by the 

grant funding, were reviewed for compliance. State Homeland 

Security Program grants were addressed in the DHS OIG report

“The State of Washington’s Management of State Homeland 

Security Grants Awarded During Fiscal Years 2004 through 

2006,” OIG-08-98, September 2008. 

In accordance with the audit guide, auditors chose to visit all eight 

subgrantees receiving Urban Areas Security Initiative grant funds. 

We visited nine total sites, including the State Administrative

Agency, and eight subgrantees: 

Washington Military Department, Emergency Management

Division (State Administrative Agency) 

City of Bellevue

King County 

Pierce County 

Seattle Police Department 

Snohomish County 

University of Washington 

The State of Washington’s Management of Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2007 through 2009 

Page 12
Appendix A 

Purpose, Scope, and Methodology

Washington State Department of Health

Washington State Patrol 

The scope of the audit included the Urban Areas Security Initiative 

grant awards for FYs 2007, 2008, and 2009 as shown in the 

following table: 

Homeland Security Grant Program 

FYs 2007 through 2009 

Funded Activity FY 2007 FY 2008 FY 2009 Total 

Urban Areas

Security Initiative $10,660,000 $10,340,000 $11,030,900 $32,030,900

State Homeland 

Security Program $10,030,000 $19,780,000 $18,190,000 $48,000,000

Law Enforcement 

Terrorism 

Prevention

Program 

$7,170,000 Not

Applicable 

Not

Applicable $7,170,000 

Citizen Corps 

Program $291,665 $295,668 $294,119 $881,452

Metropolitan 

Medical Response $774,435 $963,663 $963,663 $2,701,761

System Program 

Grand Total $28,926,100 $31,379,331 $30,478,682 $90,784,113

Source: Federal Emergency Management Agency 

The team reviewed a statistical sample of the Urban Area’s

expenditures representing 16% of the dollar value expended for

each grant year to determine the sufficiency of internal controls. 

We conducted this performance audit between October 2010 and 

May 2011 pursuant to the Inspector General Act of 1978, as

amended, and according to generally accepted government

auditing standards. Those standards require that we plan and 

perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based 

upon our audit objectives. We believe that the evidence obtained 

provides a reasonable basis for our findings and conclusions based 

upon our audit objectives. 

Although this audit included a review of costs claimed, we did not 

perform a financial audit of those costs. This was a performance 

audit as defined by Chapter 1 of the Government Auditing 

The State of Washington’s Management of Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2007 through 2009 

Page 13
 

Appendix A 

Purpose, Scope, and Methodology 

Standards, and included a review and report of program activities 

with a compliance element. 

Williams, Adley & Company-DC, LLP was not engaged to and did 

not perform a financial statement audit, the objective of which 

would be to express an opinion on specified elements, accounts, or 

items. Accordingly, Williams, Adley & Company-DC, LLP was 

neither required to review, nor express an opinion on, the costs 

claimed for the grant programs included in the scope of the audit. 

Had Williams, Adley & Company-DC, LLP been required to 

perform additional procedures, or conducted an audit of the 

financial statements in accordance with generally accepted 

auditing standards, other matters might have come to its attention 

that would have been reported. This report relates only to the 

programs specified and does not extend to any financial statements 

of the State of Washington. 

While the audit was performed and the report prepared under 

contract, the audit results are being reported by the DHS Office of 

Inspector General to appropriate Federal Emergency Management 

Agency and State of Washington officials. 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 14 
Appendix B 

Management Responses to the Draft Report 

U.S. l)('parUncllI of Ilurneland Scrorl,,· 

50el C St n..'CI. SW 

Wa,hiu!;tuu. 1ll'10472 

OCT 0 5 2011 

MEMORANDUM FOR: Anne L. Richards 

Assistont In spector General for Audits 

Oll1ce o f Inspector General 

FROM: ~~ ~r Director 

Office o f Policy and Program Analysis 

SUBJECT: Response to DraB OIG Report, 'I111! Stale (J/Washillg/(J/I's 

Mallagemcm oIVrbarl Areas Secl/rity Illitiatives (VAS!) Grall!s 

Awarded durillg Fiscal rears 200711lroltgh 2009 

Th.mk you for the oPPOitunity to comment 0 11 the drati report. l1le iimlings ill the rl!porl will bl! 

used 10 strcngthen the effcdivcllcss und cfticieney ol' how we execute and measure our 

programs. We recognize the nced to continue to improve th e process, including addressing the 

recommendations raised in this report. Our responses to the recommendations are as follows: 

OIG Recommendatio n #1: We recommend that the Assistant Administrator, Grant Programs 

Directorate, direct the Sta te Administrati ve Agency to develop procedures to periodicall y updatc 

the Urban Area strategy to include goals :1nd objecti ves th:11 are measurable and time-limited, 

FE:\1A Rcsponse: r EMA concurs with the intent of this recommendation. Speci fi cal1y, the 

National Preparedness Direc torate (NPD) is the FEMA cntit y rcsponsible fo r developing 

guidmlCe regarding the J-lomebnd Sceurity Strategy (I-lSS) process and preparedn ess 

perfo nna nce measurement systems. NPD is revising the guidance for HSS contcnt. It is 

anticipated that. in preparation lix tht:: FY 201 2 HOlll chllld Security GratH Program (HSGP) 

application cycle. this new guid<l ll ce wil l be released by the end o f lhe year 201 1 for the FY 2012 

HSG P application cycle. FEMA will require the State to fonnalize !l poli cy and document 

procedures for updati ng the State strategy in complinnce wit h revised guidelines developed by 

NPD. 

W\\ " ,rl' n1:1.:':0'· 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 15
 
Appendix B 

Management Responses to the Draft Report 

FEMA will continue to strengthen the language of the guidance, and requests that this 

recommendation be resolved and open pending implementation of the stated corrective action. 

OIG Recommendation #2: We recommend that the Assistant Administrator, Grant Programs 

Directorate. direct the State Administrative Agency to link the current grant application to the 

revised Urban Area strategy. 

FEMA Response: FEMA concurs with this recommendation. The State of Washington's EMD 

is in the process of revising their current FY 2005 Seattle Urban Areas Strategy. and it should be 

ready for review the first quarter ofFY 2012. Once the new Urban Area strategy is adopted and 

ratified by the State and approved by FEMA, aU future UASI applications must link with the 

strategy. FEMA will continue to work towards strengthening the language of the guidance, and 

requests that this recommendation be resolved and open pending implementation of the stated 

corrective 'action. 

OIG Recommendation #3: We recommend that the Assistant Administrator, Grant Programs 

Directorate, direct the State Administrative Agency to fully implement procedures to measure 

perfonnance improvements and progress towards goals using the Target Capabilities List. 

FEMA Response: FEMA concurs with the intent of this recommendation. All 56 states and 

territories have developed a base HSS. This document is the primary mechanism for State, 

Urban Areas and Territorial governments to identify the Homeland Security goals for their 

respective communities. NPD is the FEMA entity responsible for developing guidance on 

Homeland Security strategies and preparedness perfonnance measurement systems. As stated in 

our response to Recommendation 1, it is anticipated that NPD will release new guidance in the 

by the end of the year 2011 for the FY 2012 HSGP application cycle. FEMA will require the 

SAA to use the guidance developed by NPD to implement procedures to measure performance 

improvements and progress towards goals using the Target Capabilities List. as applicable, 

FEMA requests this recommendation be resolved and open pending implementation ofthe stated 

corrective actions .. 

DIG Recommendation #4: We recommend that the Assistant Administrator, Grant Programs 

Directorate, direct the State Administrative Agency to include performance measurements 

developed during this process in any update to the Urban Area Strategy. 

FEl\1A Response: FEMA concurs with the intent of this recommendation. As stated in our 

response to Recommendation 1, it is anticipated that NPD wi11 release new guidance by the end 

of the year 2011 for the FY 2012 HSGP application cycle, FEMA will require the SAA to 

include performance measurements during the process of updating the Urban Area Strategy in 

compliance with revised guidelines developed by NPD. FEMA believes this satisfies the intent 

of the recommendation and requests that this recommendation remain resolved and open, 

pending revision of Urban Area Strategy. 

We thank you for the opportunity to review and update our comments to your recommendations 

contained in your final report. Should you have further questions regarding OUf response, please 

do not hesitate to call FEMA's Chief Audit Liaison, Brad Shetka, at 202-646-1308 

2 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 16
 
Appendix B 

Management Responses to the Draft Report 

STATE OF WASH INGTON 

MILITARY DEPARTMENT 

EMERGENCY MANAGEMENT DIVISION 

MS: TA·10 Building 10 

Camp Murray, W.5hins'on 9B410·5'11 

Phon~: (253) 512·7000 · FAX: (1531 512·7100 

October 14, 2011 

Jocelyn A. Hill 

Williams, Adley and Company. LLP 

1030 151h Street rNV. Suite 350 

Washington. DC 20005 

Dear Ms. Hill: 

Thank you for the opportunity to respond to the Williams, Adley and Company Draft Report: The 

State of Washington's Management of Urban Areas Security Initiative Grants Awarded During 

Fiscal Years 2007 through 2009 - For Official Use Only. Our response comments are included 

in this letter, along with report text that the comments address. Our understanding is that our 

response comments will be incorporated into the final draft report forwarded to the Office of 

Inspector General, for eventual reporting to Congress and publication on the OIG web site. 

Response Comments 

Report text is shown In italics. Our comments are shown In bolded text. 

The objectives of this audit were to determine if the State of Washington distributed and spent 

Urban Areas Security Initiative grant funds (1) effectively and efficiently and (2) in compliance 

with applicable federal laws and regulations. We were also to address the extent to which grant 

funds enhanced the State of Washington's ability to prevent, prepare for, protect against, and 

respond to natural disasters, acts of terrorism, and other man-made disasters. (p1J) The 

objective of this audit was to determine whether the State of Washington distributed and spent 

Urban Areas Security Initiative grant funds strategically. effectively, and in compliance with laws. 

regulations, and guidance. (p 10J Overall, the State Administrative Agency did an effective and 

efficient job of administering the program requirements, distributing grant funds, and ensuring 

that all available funds were used. The State formed working groups to establish priorities and 

spent grant funds in accordance with such priorities and applicable federa/laws and regulations. 

{p2] 

The State of Washington State Administrative Agency (SM) appreciates this 

determination of compliance, effectiveness, and efficiency in its management of Federal 

Fiscal Year 2007, 2008, and 2009 Urban Area Security Initiative (UASI) program awards 

for the Seattle Urban Area . 

.. . we identified two areas for improvement: the Urban Area strategy and the assessment 

process to measure improvement. {p1] We recommend that the Assistant Administrator, Grant 

Programs Directorate, direct the State Administrative Agency to: Recommendation #1: Develop 

procedures to periodically update the Urban Area strategy to include goals and objectives that 

- 1 -

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 17
 
Appendix B 

Management Responses to the Draft Report 

Jocelyn A. Hill 

October 14, 2011 

Page 2 

are measurable and time-limited. Recommendation #2: Unk the cUffent grant application to the 

revised Urban Area strategy. [pBl Recommendation #3: Fully implement procedures to 

measure performance improvements and progress toward goals using the Target Capabilities 

U st. Recommendation #4~ Include performance measurements developed during this process in 

any update to the Urban Area Strategy. {p9} 

The State of Washington State Administrative Agency (8AA) recognizes that these 

recommendations are being made to the FEMA Grants Program Directorate, and if 

implemented, will apply to all recipients of UASI grant funds. In 2007, the Seattle Urban 

Area Working Group independently established the need to perfonn a capabilities 

assessment process, and began this project with FFY2008 UASI funds. This project will 

be completed by the end of this year. In 2008. the Urban Area Working Group 

Independently established a need to update Its strategy and began this project using 

FFY2009 funds. The Capabilrties Assessment Project results and analysis feed directly 

into the Strategy Update Process. The Strategy Update Project will complete In April 

2012, and the updated strategic goals and objectives will be loaded into the federal 

Grants Reporting Tool for linking all potentially UASI funded future Investments. Goals 

and objectives will be measurable and time-limited. In short, though not required by 

guidance, the Seattle Urban Area Working Group has demonstrated that it is in full 

agreement with the recommendations to FEMA outlined in the Williams Adley report, and 

Is already Implementing those recommendations. 

The State Administrative Agency did not link grant applications for FY 2007, 2008, and 2009 to 

the most recent strategy, prepared in 2005. The State does not have a process to link 

applications to the strategy, but instead bases its applications on annual rankings prepared by 

the State. {p6} 

This statement is incorrect. Homeland Security Grant Program guidance requires the 

UASI strategy to be loaded Into the federal Grants Reporting Tool (GRn. where each 

year, both the Investment Justifications and UASI-funded local and state projects must 

be tied to UASI strategic objectives. The SAA loaded the 2005 UASI Strategy Into the 

GRT. The SAA and the Seattle UASI ensured the 2007, 2008, and 2009 grant applications 

were linked to the 2005 strategy. Examination of Washington State's UASI grant 

applications in GRT will demonstrate the linkage of Investment to strategy. OHS will not 

approve a grant application without it. In addrtion to this guidance-required linking each 

year, the State has also used every tool and process at its disposal to maintain relevant 

homeland security strategies and to ensure those strategies guide UASI-funded projects. 

The State Administrative Agency has not implemented a process to ensure that the Urban Area 

strategy is reviewed and updated periodicalfy to reflect current goals, objectives, and priorities. 

[P7) 

Federal UASI grant guidance stipulates who the local members are in each Urban Area, 

and requires those members to form a Working Group and Charter to jointly determine 

how UASI program funds should be prioritized. Washington State closely follows grant 

guidance and the SAA is an active partner in the Seattle UASI governance. In many If not 

most other Urban Areas, states do not enter into the UASI governance process but 

simply pass through the funds. The State of Washington, however, enjoys a somewhat 

unique collaborative arrangement whereby the State is a facilitating partner with the 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 18
 
Appendix B 

Management Responses to the Draft Report 

Jocelyn A. Hill 

October 14. 2011 

Page 3 

other UASI members, and the State and locals work together to agree on projects in a 

fully transparent process. The State and locals together comprise the Urban Area 

Working Group, which has fully matured In Its processes over the ten years of UASI 

funding, which have been demonstrated in its detennination to measure its capabilities 

improvements and to update its strategies. This is evidenced by the UASl's review of the 

2005 strategy, goals, objectives and priorities and the determination in 2008 that the 

strategy needed to be updated. Beginning with the fiscal year 2011 grant program, states 

are now required to update their strategies every two years. The Seattle UASI will 

continue to comply with this grant guidance. 

The Urban Area Working Group's mission is to meet the compliance, effectiveness and 

efficiency objectives noted at the beginning of this letter. The SM is pleased to receive 

the determination that tho Urban Area Working Group has met those objectives. 

Again, Ms. Hill, we thank you for this opportunity to comment on the Williams Adley report. We 

also wish to note the outstanding friendliness and professionalism of the Williams Adley staff 

that perfonned this audit. 

Sincerely. 

~~~ Director 

cc: Robert Ezelle, Unit Manager 

Jennifer Schaal. Homeland Security Section Manager 

Russell Sonmore, Subrecipient Monitoring Manager 

Program Files 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 19
 
Appendix C 

Homeland Security Grant Program Background 

The Homeland Security Grant Program provides federal funding to 

help state and local agencies enhance their capabilities to prevent, 

protect against, respond to, and recover from terrorist attacks,

major disasters, and other emergencies. The Homeland Security 

Grant Program encompasses several interrelated federal grant

programs that together fund a range of preparedness activities, 

including planning, organization, equipment purchase, training, 

and exercises, as well as management and administration costs.

Programs include: 

State Homeland Security Program provides financial 

assistance directly to each of the states and territories to

prevent, respond to, and recover from acts of terrorism and 

other catastrophic events. The program supports the 

implementation of the State Homeland Security Strategy to

address the identified planning, equipment, training, and 

exercise needs. 

Urban Areas Security Initiative provides financial assistance

to address the unique planning, equipment, training, and 

exercise needs of high risk urban areas, and to assist in building 

an enhanced and sustainable capacity to prevent, respond to, 

and recover from threats or acts of terrorism and other

disasters. Allowable costs for the urban areas are consistent

with the State Homeland Security Program. Funding is 

expended based on the Urban Area Homeland Security 

Strategies. 

In addition, the Homeland Security Grant Program includes other 

interrelated grant programs with similar purposes. Depending on 

the fiscal year these include: 

Metropolitan Medical Response System 

Citizen Corps Program 

Law Enforcement Terrorism Prevention Program

(through FY 2007) 

The State of Washington’s Management of Urban Areas Security 

Initiative Grants Awarded During Fiscal Years 2007 through 2009 

Page 20
Appendix D 

Washington Military Department Emergency Management Division Organization 

Organization as of September 2010 

Source: Washington Military Department, Emergency Management Division 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 21
 
Appendix E 

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 

Federal Emergency Management Agency 

Administrator 

Assistant Administrator, Grant Programs Directorate 

Federal Emergency Management Agency Audit Liaison 

Grant Programs Directorate Audit Liaison 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

The State of Washington’s Management of Urban Areas Security
 

Initiative Grants Awarded During Fiscal Years 2007 through 2009
 

Page 22
 
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 e-mail your request to 

our OIG Office of Public Affairs at DHS-OIG.OfficePublicAffairs@dhs.gov. For 

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

@dhsoig. 

OIG HOTLINE 

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

or noncriminal misconduct relative to Department of Homeland Security programs and 

operations: 

• Call our Hotline at 1-800-323-8603 

 

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

• E-mail us at DHSOIGHOTLINE@dhs.gov; or 

• Write to us at: 

DHS Office of Inspector General/MAIL STOP 2600, 

Attention: Office of Investigation - Hotline, 

245 Murray Drive SW, Building 410 

Washington, DC 20528 

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