Department of Homeland Security 

Office of Inspector General 

The State of Nevada’s Management of State 
 

Homeland Security Program and Urban 
 

Areas Security Initiative Grants Awarded 
 

During Fiscal Years 2006 through 2008 
 

OIG-11-83 May 2011 
Office ofInspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

MAY 10 2011 

Preface 

The Department ofHomeland Security (DHS) Office of Inspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. 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. 

The attached report presents the results ofthe audit ofthe State ofNevada's management 

of State Homeland Security Program and Urban Areas Security Initiative grants awarded 

during Fiscal Years 2006 through 2008. We contracted with the independent public 

accounting finn Foxx & Company to perfonn the audit. The contract required that Foxx 

& Company perfonn its audit according to generally accepted government auditing 

standards. Foxx & Company's report identifies three reportable conditions where State 

management of the grant funds could be improved, resulting in six recommendations 

addressed to the Assistant Administrator, Grant Programs Directorate. Foxx & Company 

is responsible for the attached auditor's report dated January 7,2011, 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 ofthis report. 

Anne . lchards 

Assistant Inspector General for Audits 
January 7, 2011 

Ms. Anne L. Richards 

Assistant I nspector General for Audits 

Office of Inspector General 

U.S. Departmen t of Homeland Security 

245 Murray Drive, S.W. Build ing 410 

Washington, D.C. 20528 

Dear Ms. Richards: 

Foxx & Company performed an audit of the State of Nevada’s management of the 

Department of Homeland Security’s State Homeland Security Pr ogram and Urban Areas 

Security Initiative grants for Fiscal Years 2006 through 2008. The audit was performed 

in accordance with our Task Order No. TPD-FIG-BPA-07-0007 datedSeptember 29, 

2009. This report presents the results of the audit and includes recom mendations to help 

improve the State’s management of the audited State Homeland Secur ity Program and 

Urban Areas Security Initiative grants. 

Our audit was conducted in accordance with applicable Government Auditing Standards, 

2007 revision. The audit was a performance audit as defined by Ch apter 1 of the 

Standards and included a review and report on program activities wit h a compliance 

element. Although the audit report comments on costs claimed by the State, we did not 

perform a financial audit, the purpose of which would be to rende r an opinion on the 

State of Nevada’s financial statements or the fu nds 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 call me at (513) 639-8843. 

Sincerely, 

Foxx & Company 

Martin W. O’Neill 

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


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

Results of Audit ................................................................................................................ 5 
 

Measurable Goals and Objectives ......................................................................... 6 
 

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

Management Comments and Auditors’ Analysis ................................................. 8 
 

Long-Term Sustainment of Capabilities ................................................................ 9 
 

Recommendation ................................................................................................ 11 
 

Management Comments and Auditors’ Analysis ............................................... 11 
 

Effective Grant Monitoring ................................................................................. 12 
 

Recommendations ............................................................................................... 14 
 

Management Comments and Auditors’ Analysis ............................................... 14 
 

Appendices 

Appendix A: Purpose, Scope, and Methodology .............................................. 16 
 

Appendix B: Management Comments to the Draft Report .............................. 19 
 

Appendix C: Organization Chart ...................................................................... 26 
 

Appendix D: Report Distribution ..................................................................... 27 
 

Abbreviations 

DHS Department of Homeland S ecurity 
 

FEMA Federal Emergency Managem ent Agency 
 

FY fiscal year
 

OIG Office of Inspector General 
 

Table of Contents/Abbreviations 
 
 

OIG
 


Department of Homeland Security 

Office of Inspector General 

Executive Summary 

Foxx & Company completed an audit of the State of Nevada’s 

Management of State Homeland Security Program and Urban 

Areas Security Initiative grants awarded during fiscal years 2006 

through 2008. The audit objectives were to d etermine whether the 

State distributed and spent Homeland Security Grant Program 

funds strategically, effectively, and in complianc e with laws, 

regulations, and guidance. The audit included a review of 

approximately $49.2 million in State Home land Security Program 

and Urban Areas Security Initiative grants awar ded by the Federal 

Emergency Management Agency to the State of Nevada. 

Generally, the State did an efficient and effective job of 

administering program requirements in acco rdance with grant 

guidance and regulations. The State’s plans linked funding to allhazard capabilities and to goals that were establi shed based on risk 

assessments. Also, the State established an ef fective system for 

identifying vulnerabilities and opportunities to improve the State’s 

preparedness and responsecapabilities. 

However, some improvements are needed in the State’s 

establishment of measurable goals and obje ctives, identification of 

long-term c apability sustainment options, and monitoring of 

subgrantee activities. 

Our six recommendations call for the Federal Emergency 

Management Agency to require the S tate of Nevada to initiate 

improvements which, if implemented, should help strengthen 

program management, performance, and ove rsight. 

Federal Emergency Management Agency a nd Nevada officials 

verbally concurred with our findings and recommendations. 

Nevada officials provided written comments, which are 

incorporated as appropriate, and included in their entirety in 

Appendix B. 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 1 

 

Background
 


The Homeland Security Grant Program is a federal assistance grant 

program administered by the U.S. Department of Homeland 

Security (DHS), Grant Programs Directorate within the Federal 

Emergency Management Agency (FEMA). The current Grant 

Programs Directorate, hereafter referred to as FE MA, began with 

the Office of Domestic Preparedness, which w as transferred from 

the Department of Justice to DHS in March 2003. The Office of 

Domestic Preparedness was subsequently consolidated into the 

Office of State and Local Government Coordin ation and 

Preparedness which, in part, became the Office of Grants and 

Training, and which subsequently became pa rt of FEMA. 

Although the grant program was transfer red to DHS, applicable 

Department of Justice grant regulations and legacy system s still 

were used as needed to administer the program . For example, 

through fiscal year (FY) 2008 the Office of Justice Programs’ 

Grants Management System was used to rec eive grantee 

applications and to administer the awardand reporting processes. 

Also prior to the transfer, the State Administrati ve Agency entered 

payment data into the Office of Justice Programs’ Phone Activated 

Paperless Request System, which was a drawdown payment 

system for grant funds. That payment system was replaced in 

April 2007 by FEMA’s Payment and Reporti ng System, which 

allowed grantees to make payment requests and complete and 

transmit their quarterly Financial Status R eports online. 

Homeland Security Grant Program 

The Homeland Security Grant Program provide s federal funding to 

help state and local agencies enhance their cap abilities to prevent, 

deter, respond to, and recover from terrorist atta cks, major 

disasters, and other emergencies. The Home land 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. 

Depending on the fiscal year, the program included som e or all of 

the programs: 

�	 State Homeland Security Program supports the 

implementation of State Homeland Security Strategies to 

address the identified planning, organization, equipment, 

training, and exercise needs to prevent, protect against, respond 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 2 

to, and recover from acts of terrorism and other catastrophic 

events. 

�	 

�	 

�	 

�	 

Urban Areas Security Initiative Program funds address the 

unique planning, organization, equipment, training, and 

exercise needs of high-threat, high-density Urban Areas, and 

assists them in building an enhanced and sustainable capacity 

to prevent, protect against, respond to, and r ecover from acts of 

terrorism. 

Law Enforcement Terrorism Prevention P rogram provides 

resources to law enforcement and public safety communities 

(working with their private partners) to supp ort critical 

terrorism prevention activities, including: establishing/ 

enhancing fusion centers and collabor ating with non-law 

enforcement partners, other government agencies, and the 

private sector. 

Citizen Corps Program mission is to bring community and 

government leaders together to coordinatethe involvement of 

community members in emergency prepare dness, planning, 

mitigation, response, and recovery. 

Metropolitan Medical Response System Program funds 

support designated jurisdictions to further en hance and sustain 

a regionally integrated, systematic mass cas ualty incident 

preparedness program that enables a respon se during the first 

crucial hours of an incident. The program prepares 

jurisdictions for response to all-hazards mass casualty 

incidents, including Chemical Biologic al Radiological Nuclear 

Explosive terrorism, epidemic disease outbreaks, natural 

disasters, and la rge-scale hazardous material incidents. 

State Administrative Agency 

The governors of each state appoint a State Ad ministrative Agency 

to administer the Homeland Security Grant P rograms. The State 

Administrative Agency is responsible for m anaging these grant 

programs in accordance with established federal guidelines. The 

State Administrative Agency is also responsible f or allocating 

funds to local, regional, and other state government agencies. 

In 1999, Nevada’s Governor designated the Division of 

Emergency Management to be the State Administrative Agency for 

the Homeland Security Grant Programs. The Nevada Division of 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 3 
 

Emergency Management administered all of the Homeland 

Security Grant Program grants included in our audit scope. The 

Division of Emergency Management’s organizational structure is 

depicted in Appendix C. 

The State of Nevada is not divided into Respo nse Regions, as the 

State chose not to regionalize due to the topography and unique 

diversity of itsjurisdictions. The Nevada Division of Emergency 

Management and the Clark County/Las Vegas Urban Areas 

Security Initiative area are the major Planning Commissions within 

the State of Nevada that determine grant fundin g priorities within 

the State. The Division of Emergency Managem ent’s Homeland 

Security Working Group coordinates with the Ur ban Areas 

Security Initiative working group to support their needs, 

synchronize strategies, and establish consistent priorities across 

Nevada. 

Grant Funding 

The State of Nevada received approximately $58.8 million from 

the Homeland Security Grant Program during FYs 2006 through 

2008. As part of this program, the State receive d $49.2 million in 

State Homeland Security Program and Urban A reas Security 

Initiatives grants. During that timeframe, the St ate Administrative 

agency awarded subgrants to the following: 

�	 

�	 

�	 

2006: 10 first responder subawards distributed throughout 

2 counties, 1 city, 5 state agencies, 1 state association, and 

1 urban area; 

2007: 24 first responder subawards distributed throughout 

12 counties, 4 cities, 5 state agencies, 2 regional commissions, 

and 1 urban area; and 

2008: 12 first responder subawards distributed throughout 

3 counties, 1 city, 6 state agencies, 1 state association, and 

1 urban area. 

Table 1 displays a breakdown of the State Homeland Security 

Program and Urban Areas Security Initiative grant funds by year. 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 4 
 

 

 

 

 

Table 1 
 

Nevada 

Homeland Security Grant Program Awards 

Funded Activity FY 2006 FY 2007 FY 2008 Total 

State Homeland 

Security 

Program 

$ 8,110,000 $ 5,610,000 $ 9,390,000 $23,110,000 

Urban A 

ity 

Initiativ 

reas 

Secur 

es 

$ 7,750,000 $ 9,310,000 $ 9,030,000 $26,090,000 

La 

En 

Terrorism 

w 

forc 

Prevention 

am 

ement 

Progr 

$ 4,180,000 $ 4,000,000 $ 0 $ 8,180,000 

C 

Pr 

itizen 

ogram 

Corps $ 237,000 $ 179,000 $ 183,000 $ 599,000 

Metrop 

Medical 

sponse 

System 

olitan 

Re

 Program 

$ 232,000 $ 258,000 $ 322,000 $ 812,000 

Total $20,509,000 $19,357,000 $18,925,000 $58,791,000 

Foxx & Company completed an audit of the State of Nevada’s 

management of DHS’ State Homeland Secu rity Program and 

Urban Areas Security Initiative grants awarded during FYs 2006 

through FY 2008. The objectives of the audit were to determine 

whether the State distributed and spent Homela nd Security Grant 

Program funds strategically, effectively, and i n compliance with 

laws, regulations, and guidance. Nine r esearchable questions 

provided by the DHS Office of Inspector General (OIG) 

established the framework for the audit. The researchable 

questions were related to the State Administrativ e Agency’s 

planning, management, and evaluations o f grant activities. 

Appendix Aprovides additional details on the purpose, scope, and 

methodology of this audit, including the nine researchable 

questions. 

Results of Audit 

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

program requirements in accordance with grant g uidance and regulations. 

The State’s plans linked funding to all-hazard capabilities and to goals that 

were established based on risk assessments. Also, the State established an 

effective system for identifying vulnerabilities and opportunities to 

improve the State’s preparedness and response capabilities. 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 5 

 

However, some improvements are needed in the State’s establishment of 

measurable goals and objectives, identification of long-term capability 

sustainment options, and monitoring of subgrantee activities. 

Measurable Goals and Objectives 

The Nevada State Administrative Agency ca nnot demonstrate 

improvement and accom plishments tied to federal grants because strategic 

goals and objectives did not provide an adequate basis for measuring 

improvements in the State’s preparedness and response capabilities. The 

Agency had not developed measurable goals and object ives consistent 

with federal requirements and did not have an effectivesystematic method 

for the collection of performance-related data. As a result, the State did 

not have a documented evaluation of the effect that gran t funds had on the 

capability of first responders. 

Code of Federal Regulations Title 44 § 13.40 (a), Monitoring and 

reporting program performance, requires that gr antees must monitor grant 

and subgrant supported activities to assure that performa nce goals are 

being achieved. In addition, Department of Homela nd Security State and 

Urban Area Homeland Security Strategy Guidance on A ligning Strategies 

with the National Preparedness Goal, dated July 22, 2005, states that an 

objective sets a tangible and measurable target level ofperformance over 

time against which actual achievement can be compare d, including a goal 

expressed as a quantitative standard, value or rate. Therefore, an objective 

should be: 

�	 

�	 

�	 

�	 

�	 

Specific, detailed, particula r, and focused – helping to identify 

what is 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 

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

will be achieved. 

The State’s goals, objectives, and implementin g steps were broad-based 

and did not provide for tracking and objectively measuring the impact of 

funds expended for equipment, training, and exercises . The following is 

an example of th e State’s FY 2006-2008 goals, objectives, and 

implementation steps. 

�	 Goal: Equip and train Nevada’s emergency first responders and 

support agencies. 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 6 
 

�	 

�	 

Objective: Establish equipment needs and continue to equip 

emergency first responders as is permissible through available 

federal, state, local, and tribal funding. 

Implementation Steps: 

o	 Establish equipment needs to detect, accurately identify and 

report radiologicalor nuclear materials, 

o	 	Conduct thorough review of subrecipient applications for 

compliance with federal grant guidance a nd identified 

needs within each state ag ency and local jurisdiction, 

o	 	Conduct assessment in conjunction wit h evaluation of 

cumulative year-to-date equipment a llocations, 

o	 	 Authorize award for funding to subre cipient in support of 

approved application, 

o	 	 Develop statewide policies for standardization of 

equipment utilized by all emergency first responders to 

provide for ease in sharing of resourc es and mutual aid 

assistance, and 

o	 Establish working groups to perform equipment needs 

assessments and periodic reevaluatio ns. 

Starting with the 2007 State Homeland Security Stra tegy, the Nevada 

State Administrative Agency changed its Evaluation P lan section of the 

State Strategy to include a requirement that the St ate would submit 

quarterly progress reports to the Nevada Homeland Sec urity Commission 

in order to monitor progress relative to the strategy and ensure compliance 

with federal reporting requirements. As a part of the signed certified 

assurances accompanying the grant award, the State re quired the 

subgrantees to submit a quarterly progress report. Using these quarterly 

progress reports, the S tate prepared a combined statewide report for 

submission to the Commission. 

We reviewed subgrantees’ quarterly progress reports an d found the reports 

lacking in definitive measurements. While the State had m ade an attempt 

to develop a progress measurement tool with the requirem ent for quarterly 

progress reports from subgrantees, the tool was not mee ting the 

requirements of what constitutes an objective as define d in DHS guidance. 

State officials acknowledged that performance measure s must be carefully 

developed, specifically tied to the State’s strategy, goals , and objectives, 

and be consistent with resource availability and allocation. Without 

measurable goals and objectives and a mechanism to collect objective, 

results-oriented data from local jurisdictions and first responders, the State 

did not have a basis to evaluate the effect of grant expenditures on its 

preparedness and response capabilities. Also, the State was unable to 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 7 
 

determine progress toward goals and objectives when making funding and 

management decisions. 

Recommendations 

We rec ommend that the Assistant Administrator, Grant Programs 

Directorate, require the Director of the Nevada Division of 

Emerg ency Management to: 

Recommendation #1: Develop strategic goals and objectives 

applicable to first responder capabilities that are specific, 

measurable, achievable, results-oriented, and time limited; 

Recommendation #2: Incorporate the goals and objectives into a 

statewide system for measuring local jurisdiction first responder 

progress toward achieving the goals and objectives; and 

Recommendation #3: Use the progress achieved as a basis for 

making decisions regarding future first respon der grants. 

Management Comments and Auditors’ Analysis 

FEMA officials verbally concurred with the findings and 

recommendations and elected not to provide w ritten comments. 

The State provided written comments and c oncurred with the 

finding and the recommendations. The Sta te Administrative 

Agency stated that at the end of FY 2008, the Division of 

Emergency Management developed and implem ented a process 

that resulted in a statewide assessment of target c apabilities. The 

purpose of the assessment was to create a comprehensive p icture of 

current all-hazards preparedness for the State of Nevada, including 

the Las Vegas Urban Area. The process was co nducted prior to 

the FY 2009 and 2010 grant cycles and will cont inue to be used in 

subsequent years. Nevada officials said that all project managers 

are required to submit a project plan based upon the DHS approved 

investment justification for each approved proje ct. 

The officials also said that project managers, gra nt managers, and 

fiscal agents are required to submit quarterly fina ncial reports and 

programmatic summaries. Theprogrammatic summaries must 

include: percentage of project completion, tasks accomplishments, 

financial status and accountability, and any challenges that would 

potentially result in project managers being unable to complete the 

project within the grant performance period. 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 8 
 

We agree that progress has been made since the 2006, 2007, and 

2008 grant years. The State has made a concerted effort to create 

and maintain a comprehensive picture of Nevada’s all-hazards 

preparedness in terms of target capabilities. If properly 

implemented, the actions identified in the State ’s response will 

resolve the condition identified during the audit . However, the 

Assistant Administrator, Grant Programs Dir ectorate, needs to 

ensure that the State’s implementation of the process results in 

appropriate measurements of progress and tha t the progress 

achieved is reflected in the State’s requests for future first 

responder grants. 

Within 90 days, the Assistant Administra tor, Grant Programs 

Director ate, needs to outline corrective actions and a plan for 

ensuring that the State’s implementation of the assessment process 

is being implemented as intended. These re commendations remain 

open and unresolved. 

Long-Term Sustainment of Capabilities 

The State of Nevada had not prepared contingency p lans that address 

funding shortfalls if grant funds are reduced or curtai led all together in 

subsequent years. Although the Sustainability Sectionof the Investment 

Justifications from the State’s major subgrantees indi cated that Nevada 

would accept financial responsibility for post-grant funding, the 

Sustainability Section offered little substantive suppor t as to how the 

investment would address long-term costs—either from an e quipment or 

salary perspective. This creates an inherent risk to the State’s capability to 

prepare for and respond to catastrophic occurrences and to protect its 

interest in sizable assets acquired. 

The DHS Grant Program Guidance and Application Kit s as well as the 

Investment Justification Reference Guides for fisca l years 2006, 2007, and 

2008 state that grant proposals must clearly describe how projects will be 

sustained when the awarded grant funds are expended. Among other 

things, sustainability plans must address long-term costs such as 

personnel, equipment maintenance, repairs, replacement, and software 

licensing. Sustainability plans are not to place reli ance upon future grant 

awards. 

The DHS Grant Guidance Kits and Investment Justification Guides 

stipulate that grantees are to describe the long-term approach to sustaining 

the capabilities created or enhanced by the investment, or explain why the 

investment will not be sustained. DHS notes that the applicant should 

describe plans for maintaining the capabilities developed by the 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 9 
 

investment, including any additional sources of funding to be used, or 

future plans for sustaining the investment, if any. DHS further advises the 

grantees to describe how implementing the investment will continue to fill 

capability gaps beyond the grant’s performance period. For sustainment 

investments, the grantee is to describe how successf ul maintenance of the 

capabilities has been achieved and provide plans indicat ing how 

capabilities will be sustained in the long-term. 

Nevada’s investments in its intelligence collection and analys is Fusion 

Centers, as well as other terrorism combating activities, were so large and 

the processes so imbedded in the local law enforcement community that 

these activities may be considered too important to fail shou ld federal 

grant funds be reduced or eliminated. The Las Vegas Metro Police 

Department, the Washoe County Sheriff, the Elko Co unty Sheriff, the 

state bomb squads, the three intelligence gathering Fusion Centers, and the 

associated critical infrastructure protection/Silver Sh ield programs were 

either in the process of or have purchased very high-costequipment items. 

Moreover, the salaries and associated personnel costs ne cessary to keep 

these programs operating could have impact on the qu ality of the services 

delivered. 

The Investment Justifications we reviewed for Nevad a did not provide 

significant details as to how the grantee intended to f inance the project 

beyond the DHS funding period. For example, in th e FY 2007 grant 

application for the Las Vegas Fusion Center program, the Sustainability 

Justification included, among othe r things, that: 

�	 

�	 

“...a feasibility study is currently underway in the Nevada 

Legislature, with the intention of providing sustainment funding of 

the Fusion program. The costs of building a structure and the 

associated costs would be borne by the state, while the various 

agencies would contribute personnel.” In June 2010, Nevada 

Division of Emergency Management officials told us that the 

Nevada Legislature had not completed this feas ibility study. 

Improvised Explosive Device/Bomb Squads pro ject managers are 

expected to: “...identify opportunities to integrate and leverage 

funding sourcesto provide and continue...Nevada bomb squads.” 

However, neither the State nor the subgrantees could provide 

documentation supporting that these opportun ities had been 

identified during the audit. 

On November 20, 2009, DHS issued an Information Bulletin stating the 

agency will fund maintenance contracts, warranties, upgrades, and user 

fees under all active and future grant awards. While the bulletin satisfies 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 10 
 

some out-year grantee funding concerns, it does not cover the significant 

outlays that grantees will be expected to fund should DHS reduce future 

grant awards for replacement or sustainment purposes. 

Nevada has invested heavily in procuring very expensive and elaborate 

equipment together with supportive infrastructure for ongoing programs 

including the intelligence gathering anddissemination Fusion Centers, 

Bomb Squads, critical infrastructure protection/Silver Shield, and 

Improvised Explosive Devices/Weapons of Mass Des truction programs. 

In this regard, we noted that a budget shortfall of $2 billion or more was 

being publicized for the State of Nevada while a t the same time the State 

and Clark County, Nevada’s most populated county, w ere furloughing 

numerous city, county, and State employees. As a result, the sustainment 

of capabilities and the completion of multi-year projec ts may be in 

jeopardy if future federal funding is substantially reduced or not available. 

If this occurs, grantees and subgrantees would have to provide support to 

retain acquired preparedness and response capabilities. If the required 

funds exceeded the financial ability of the grantee and subgrantees, the 

acquired capabilities could be reduced or eliminated. 

Recommendation 

We recommend that the Assistant Administrato r, Grant Programs 

Directorate, require the Director of the Ne vada Division of 

Emergency Mana gement to: 

Recommendation #4: Identify ongoing and proposed projects 

that will need additional funding beyond th e grant period; estimate 

the timeframe and the amount of money neededto complete 

ongoing and proposed projects; and provide options for sustaining 

the capabilities being acquired in the absence of federal funds. 

Management Comments and Auditors’ Analysis 

FEMA officials verbally concurred with the findings and 

recommendations and elected to not provid e written comments. 

The State provided written comments and co ncurred with the 

finding and the recommendation. The State Adm inistrative 

Agency recognizes the significance of sustainm ent. Due to the 

current economic situation the State and itsmunicipalities are 

facing, the challenge to achieve sustainability independent of 

federal funding is a major concern. As the economy improves, the 

State will evaluate a shared multi-jurisdictional contribution 

method of sustainment. We agree that the current economic 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 11 
 

dilemma poses a real challenge to states and local municipalities. 

However, the condition reported from the audit will remain open 

until appropriate options are identified concerning project 

completions and long-term sustainment of capabilities if future 

federal funding is substantially reduced or not a vailable. 

Within 90 days, the Assistant Administra tor, Grant Programs 

Directorate, needs to provide corrective actio ns for the 

recommendations and a plan to implement the actions. This 

recommendation remains open and unresolv ed. 

Effective Grant Monitoring 

The Nevada StateAdministrative Agency could enhance the effectiveness of 

its subgrantee monitoring by following its newly established site monitoring 

procedures. When the FY 2006, 2007, and 2008 Homeland Security Grant 

Program awards were made the Agency was not conducti ng periodic site 

visits to observe the progress made by the subgrantees and did not have grant 

management and performance monitoring policies and p rocedures in 

place. Although the Agency hired a compliance off icer to perform site 

visits in January 2009, few had been completed at the tim e of our audit. In 

the absence of site visits, the Agency was not able to be fu lly aware of the 

extent that its subgrantees adhered to federal requirements and grant 

guidelines or achieved DHS and Agency programmatic go als and objectives. 

The incomplete implementation of an effective periodic, on-site, subgrantee 

monitoring program prevented the Agency from obt aining first-hand 

knowledge of specific subgrantee administrative problem s and issues. 

Code of Federal Regulations Title 44 § 13.40 (a), Monitoring and 

reporting program performance, establishes requirem ents for monitoring 

grant program performance. The regulations require grantees to 

(1) provide day-to-day management of all grant and s ubgrant supported 

activities and (2) assure that subgrantees comply with applicable federal 

requirements and achieve program performance g oals. The regulations 

also specify that the grantees’ monitoring programs co ver each program, 

function, or activity, and require subgrantees to adhere t o the same 

performance monitoring and reporting standards a s required of grantees. 

Office of Management and Budget Circular A-133, Par t 3-M also includes 

grantee monitoring requirements. Part 3-M states that grantees are 

responsible for monitoring subgrantee use of federal awards through 

reporting, site visits, regular contact, or other means. Grantee monitoring 

should provide reasonable assurance that the subgrantee administers 

federal awards in compliance with laws and regulations, as well as the 

provisions of contracts or grant agreements. Monitoring should assure 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 12 
 

that performance goals are achieved. In addition, all state and local 

governments that expend $500,000 or more of federal awards must obtain 

a Single Audit. Single audits include the physical inspection of inventory 

items and the follow-up of actions taken as a result of findings from 

previous audits. 

The Nevada Division of Emergency Management hired a Compliance 

Officer to conduct grant monitoring after the State legislature approved 

funding for this position in January 2009. The primary monitoring 

activities performed by the State prior to January 200 9 were desk audits 

conducted during quarterly financial status report rev iews, periodic 

program reports, interactions with subgrantee represe ntatives during 

periodic working group meetings, and occasional visit s or undocumented 

telephone calls with the subgrantees. 

Since coming on-board, th e Compliance Officer: 

�	 

�	 

�	 

Developed formal policies and procedures for m onitoring grant 

recipients based upon Code of Federal Regulations 

Title 44 § 13.40, 

Created a 7-page compliance protocol documen t to be used when 

making subgrantee r eviews, and 

Proposed a schedule for on-site visits during the period July 1, 

2009 through June 30, 2010. 

A total of 35 subgrantees were identified for monitoring visits by the 

Compliance Officer. The proposed schedule assumed each on-site review 

would take one week. The schedule included 20 subgrantee visits during 

the period July 1, 2009 through June 30, 2010. Nine visits were scheduled 

during the first 6 months, but only eight had reports co mpleted. 

We review ed the reports from the eight monitoring visits and found that 

six were for Emergency Management Performance Grants. The remaining 

two visits were for: 

�	 

�	 

A FY 2006 $120,000 State Homeland Securit y Program grant 

awarded to a Nevada State Agency that had been closed with 

$56,774 de-obligated. The “visit” turned ou t to be a desk audit and 

the report did not identify any observations or nonconformance 

situations. 

Two small State Homeland Security Program grants to a local 

emergency planning commission totaling $15,150. 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 13 
 

The creation of the Compliance Officer position and the policies and 

procedures were important accomplishments in the State’s efforts to 

comply with federal monitoring requirements, and overcome the State’s 

earlier inadequate monitoring of subgrantee activities. However, based 

upon our review of the monitoring that was comple ted during the first 

6 months, the State’s monitoring commitment coul d be greatly improved. 

High-value grants should have been a priority and visits to subgrantees 

completed. Also, we question whether one individual can adequately meet 

the State’s monitoring requirements. In this regard, the State could 

consider other means to monitor the subgrantees such as reviewing Single 

Audits, requiring additional procedures to be added to annual audit scopes, 

or requesting periodic program progress. 

Recommendations 

We rec ommend that the Assistant Administrator, Grant Programs 

Directorate, require the Director of the Nevada Division of 

Emergency Management to: 

Recommendation #5: Fully implement the policies and 

procedures for on-site monitoring of subgrante es, with the largest 

grant recipients designated the highest priority w hen scheduling 

visits. 

Recommendation #6: Ensure adequate resources are provided to 

the monitoring efforts to complete scheduled site visits or obtain 

subgrantee monitoring information through othe r sources of visual 

verification such as date stamped video, photographs, or internet 

based videoconferencing. 

Management Comments and Auditors’ Analysis 

FEMA officials verbally concurred with the findings and 

recommendations and elected to not provide written comments. 

The State provided written comments and conc urred with the 

finding and the recommendation. The State ac knowledged the 

benefits of on-site review and verification as apreferable method 

of monitoring. The State Administrative Agenc y has worked 

within the constraints of limited resources and S tate officials felt 

they had sufficient subgrantee status information from multiple 

sources and processes to provide them with adequate monitoring 

knowledge. However, the State officials said that when resources 

are available the State will continue to strive for effective 

The State of Nevada’s Management of State Homeland Security Program and
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 14 
 

implementation of an on-site monitoring program or a modified 

method to achieve similar results. 

The State also said that it monitored subgrantees and had 

performance monitoring policies and procedu res in place when the 

FY 2006 through FY2008 grant awards were made. In this regard, 

we noted that a FEMA monitoring review in June 2008 reported a 

lack of subgrantee monitoring for the FY 2006 g rant by the 

Nevada Division of Emergency Management. In addition, a 

FEMA monitoring review in 2009 of the Clark C ounty Urban 

Areas Security Initiative grant identified th at no subgrantee 

monitoring policies and procedures existed for the grants awarded 

for fiscal years 2004 through 2008. 

We believe that if the S tate effectively implements its proposed 

ongoing monitoring including performing on-site visits, the 

proposed actions identified in the State’s resp onse will resolve the 

condition identified during the audit. 

Within 90 days, the Assistant Administrator, Grant Programs 

Directorate, needs to provide corrective acti ons for the 

recommendations and a plan to implement th e actions. These 

recommendations remain open and unresolv ed. 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 15 
 

�

�

�

�

�

�

�

�

�

Appendix A 

Purpose, Scope, and Methodology 

The purpose of the audit was to determine whether the State of 

Nevada distributed and spent State Homeland Security Program 

and Urban Areas Security Initiative grant funds strategically, 

effectively, and in compliance with laws, regulations, and 

guidance. The goal of the audit was to identi fy problems and 

solutions that can help the State of Nevada be tter prepare for and 

respond to threats, acts of terrorism, and oth er hazards. The audit 

further enabled us to answer the following n ine researchable 

questions: 

Were measurable goals developed f rom plans? 

Do funded plans link all-hazards capabilities to goals? 

Were funds and resources distr ibuted based on goals? 

Does the State accurately measure ri sk? 

Does the State measure response cap abilities? 

Can the State demonstrate improved perform ance? 

Were grants administered complia ntly? 

Did the State monitor gra nt programs? 

What innovative practices can be used by other states? 

The scope of the audit included the State H omeland Security 

Program and Urban Areas Security Initiative grant awards for 

Fiscal Years 2006, 2007, and 2008 as described in the Background 

section of this report. 

The audit methodology included work at FEM A Headquarters, 

State of Nevada Division of Emergency M anagement office, the 

Clark County/Las Vegas urban area, and various subgrantee 

locations. To achieve our audit objective we ana lyzed data, 

reviewed documentation, and interviewed the ke y state and local 

officials directly involved in the management and adm inistration of 

the State of Nevada’s Homeland Security GrantPrograms. We 

conducted 21 site visits and held discussions with appropriate 

officials from 5 of the 17 counties representing all emergency 

management regions within the State, and 5 o f the 7 State agencies 

awarded State Homeland Security Program and Urban Areas 

Security Initiative grants in order to determineif program grant 

funds were expended according to grant requirements and Stateestablished priorities. One State agency was merged into another 

agency and one received a FY 2008 grant award where no funds 

were spent at the time of our audit. 

The State of Nevada’s Management of State Homeland Security Program and 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 


Page 16 

 

Appendix A 

Purpose, Scope, and Methodology 

We conducted site visits to the following 21 subgrantee 

organizations: 

State Agencies 

�	 

�	 

�	 

�	 

�	 

Nevada Department of Agriculture 

Nevada Department of Information Technology 

Nevada Department of Public Safety – Investigations Division 

Nevada Department o f Public Safety – Office of Homeland 

Security/Division of EmergencyManagement 

Nevada Department of Transportation 

Counties 

�	 

�	 

�	 

�	 

�	 

Douglas County Local Emergency Planning Commission 

Elko County Local Emergency Planning Commission 

Lyon County Local Emergency Plannin g Commission 

Washoe County Local Emergency Pla nning Commission 

Washoe County Sheriff 

Urban Area 

�	 

�	 

�	 

�	 

�	 

�	 

�	 

City of Las Vegas 

City of North Las Vegas 

Las Vegas Metropolitan Police Department 

Clark County Emergency Management Local Emergency 

Planning Commission 

Clark County Coroner 

Clark County Information Technology 

Clark County Southern Nevada Area Communications Council 

First Responders 

�	 

�	 

Carson City Local Emergency Planning Commission 

Nevada Hospital Association 

Regional Activities 

�	 

�	 

Regional Transportation Commission – No rthern Nevada 

Regional Transportation Commission – South ern Nevada 

At each location, we interviewed responsib le officials, reviewed 

documentation supporting St ate and subgrantee management of the 

awarded grant funds (including expenditures for equipment, 

training and exercises), and physically inspected some of the 

equipment procured with the grant funds. 

The State of Nevada’s Management of State Homeland Security Program and 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 


Page 17 

 

Appendix A 

Purpose, Scope, and Methodology 

We conducted the audit between December 2009 and May 2010, in 

accordance with Government Auditing Standards as prescribed by 

the Comptroller General of the United States (Yellow Book-2007 

Revision). Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusion s based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusio ns based on our 

audit objectives. 

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

performa financial audit of those costs. This was a performance 

audit as defined by Chapter 1 of the Standards, a nd included a 

review and report of program activities with a c ompliance element. 

Foxx & Company was not engaged to and did not perform a 

financial statement audit, the objective of which w ould be to 

express an opinion on specified elements, a ccounts, or items. 

Accordingly, we were neither required to rev iew, nor express an 

opinion on, the costs claimed for the grant pro grams included in 

the scope of the audit. Had we been required to perform additional 

procedures, or conducted an audit of the financia l statements in 

accordance with generally accepted auditing standards, other 

matters might have come to our attention thatwould have been 

reported. This report relates only to the progr ams specified and 

does not extend to any financial statements of the State of Nevada. 

While the audit was being performed and the rep ort prepared under 

contract, the audit results are being reportedby the DHS Office of 

Inspector General to appropriate FEMA and State of Nevada 

officials. 

The State of Nevada’s Management of State Homeland Security Program and 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 


Page 18 

 

r-.oo.. ofE.., ..._ """_'.'

o_c""

",,,r_~Il_

K ..."""" '..... ('7" ",.,,,,.• ,~,,,,: .,,_,'" •'""11_ r·w '"'"I

S~27,2010

M,. Dol,? Fiwn<)'

Pr~ Ano.l:l'~ Wcrtcrn !>ivioioo

DH&HMA

800 IC Str<>oi, ~W

Wuhi"~too. OC 204n·3<i2l

On "",,,If ofthc _od. l:l<porlmont ofl'uhli, Safety. DiYi,ioo ofEmuaeocJ M"",_("JEM),

to"' 'ott<>- i, inlcndo;d to """" .. ""1'01=" ttl< "'COO1lll<IlIl"""""",,,,, by the D<p&rtm=L of

ll:~mcl",d Soc.mly (DHS), Office of lr_r Gonorol " ....,.• '" <1><;, oudit of [[w, S""< of

NovaJa', ~<lltQfth< St>t, Hom,1onoJ

JLutiati~< (VAS!) P'_ til" -.«re ""'>nkdS,=ity l'rojl<am (SHSI') and Urn", 1=.. Secuoitydu~"; F,d",.1 ,·....1V"", l((() (FfY06) tJ.ooi/l

F«!eral Fiscal Yo", 200lI (FFYO!).

T1l< DEM fin! ~'" to "'poc.. c.",;"""", 'l'P"<"i,nOfi fu< the .fR>rt, of>I1_"'l,"'iv" of

Dcpo_ ofRomd.nd S""urlIy, it. OfTLoc of Jnopc_ Cc"",," mol fOll & COOl!=y to.-

thei< <!«lie""" in ..,i<lU\i r,'cv>d. ",ith ito .Ill", to iIIlprov, prot,.... olfk! p,,,,,,,,,,- "" Lk<

.ff-;vo _,of oh< ,fu<=tioood (<<let>: ilf"" proF""" 1\ lw Wly been • J>Ie*<"'~

~",n"i: witt ,n pattie, "",,1,-..:1

It<<omlllOllclallo.' I; Devolop ""'''~I< ~oolJ 0lU! obj<.ti." .ppli..bk to ..t ,..poa.4..

,.,.b_1II..." .pe<1ll<, "",..._Ie, ",~i...bl" "",lto-.,-;..t<d, IIJI~ liDMliril.d;

It.._ ..,

The "'~ of ""',k '" tloo 010 ,","I i""hxIod FFY06 1h.'''uIh FF'{OO. 10.. DEM: ooncm; with. thi,

U""""" ..wi """"",fully ""'"'~ tho 'ollowing ""l'WiaOOo .. well .., iot<!"odd .oJia< oI<"<><ly

i",~l""'ent,~ =0""'0 oclio..

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 19
 

 

no DEM""ukl srbm~ tha lho FFYC>6 _ wu ""t """,,0<1 ""til the end affl'Y!17 "'" likwioc

w;OIl oub"",""",,,..,.. Thi,,;' OOrttb;""t.... ,,;u, \he fOGl ~t bc~ w;:h fFYIJ6, tho

l""I"""'" .hifted "' • ,,,••,,;.Je ,....l<d i•• bel of ""r.a,~i>rilY .,OJ ."". eha11<I\1el

(i .•.• "''''''''''''''-'<>-l:''''''"'''''''' telIti""", projod """_, by • oin31< j"l:!diotiQ', <Ie.)

",I.ov' '0 fI"gr>.mipro;"" i"'l'1on>enb.bon. Tho.-ef",,,, f"oj<d. w=, i~ 'orne ""', "'-I.j'«l "",;1

..,k ,kali,,,S" e<>U!<I be oddo<...,o. Du, '" thoo<; Oe~l"', the DID{ did not MV< the .bihljl '" bc~n

IIll accu<al< .n<! p«Xbem-, """,-""""t 0< _"'>IIl<fOt of ..-oj_ url:iI m odoqual< l<Yd.'

l'fOi!WI' w.. ocl~,v«l O. ::>.ell projOCl, Tcoi, " ... "",,,poundo:! by the 1>cl that 00 ';'lill, pru;..e1 WI!

fully _0<1 in. 'ir'iI' grv>< ,jrl<. nti, p..-.coc. wos imp_.meto 1Il< .....,.,.~tll"'O:i"" of....oriJljl

that l'lIndilIa opi>liO<! !or m;I .>=led w,," Iloo. ",;,it 'ho _wleOil< tbat the '1'''-''''«1 .00

USf""iv< mil..,o"", would only be .pproved with ",.sidor"""', oftile !illldi'lll we!, ~bed

perfo",,,••,. flMj<>:f ond tboo ,oJity to "'mpl"," lh< .""bll5hod rni""'-' w;o,;. L","- ,Uno pori<>;1

.~l !l>< e.l<I orFFYOi (wbi<k w.. ""L.ally lh< b<ii"""~ ,ftho l'FnS lI'0nL "d" r~, ~ith

"'0 ""or. of proj"'t r...di"ll ., t>«>I:1"'s., Lbe OEM,;, port..,.,.),T with rh' 1;',,.-, A"" (CI,'\'

'.ounl,~ <lo..-d~ <md ""PI""""1o>i 0 p"""""""-..,It,';" 0 ...tcwi<le ...,.",,,,,t of "'¥'" o,~.bil~io<. TIM """'_, MW irnp!""""lod. vo. """duo". p,;",-Io '-"00 FFY'19 >JJd FFYl~ grxLt

o,d" Mlti will o""tin", '" 00 00ll'",1od lX'ior '" <och sclose""",t t.tur, O)do, _, thi'

wos <lell< in owjunclioo ",i~, rc<jui!ini. .u ",oj"", ro ;oo,llify how l!l<y are ,_'0 aa;l ac~.

the iQlli m:I oojootiv.. _i>bod 1Vi1hin. tho SIa:e Hotrl<l>nd Socoriljl 8t""I)', >no! the Utbtn

!\r" Slm:egy (M .ppli<.~lel1'hio .".,.,"""" reaLl" in , o...",t "'OJ"hot depictin3 l!l< =,."-f....orO, lnt «"

""pabililk. r""omdn".. bol. """'" Nov.<i.. i""iJdilll! Iho L" VegM Urb Am, Proporod"""

i,vcl, 'TO "",",,,,,,d ., L""" of tno 37 Tori<! C>pobiliti.. List (TCL) d roJaod act;viti", ..

" ..hli",.. .. ooch of"'" r",ll'" ,->-paMhi". 'P.li;l "''' oo;l,,1ion ocoon tl"",~ a om.. of

....,>ro""t int"",i...., -.vitk '''bj«t =nor ..pert, (8MB» !L'nill.. '"ilh tllo pi<lie<1ar "",>lJililjl >od

r.illed dio,iplin«') .....>Od, How..", it 'rollol be Mud tkat tbote .... ntany vwblea,

"'Nell are ,}'I1tp",,,,,,ti, o[ tho _ 1<r «>'OIvinr; p"'".,....... ",1;;-iti... t'''' dXo<Lly ~l Lbo

me.o""""<.tlt of oap/lb;lhj' 11 .JlY j.i,<.tl limo. 11><00 ;-.,.;.,;,;" ;""l<rlt, Ito:. "'" ,"" limit," to

!'Jnjll:>l"" now """~ ,,"J't<', P"""""""',t"""","00', '''1l.n;..ti'''''1 ofIrnp, .to

Tho P"'P"'" of th, ,•.,,,,,,,,,1 ..... In ", ~';v. p;"t.-o of ",,,mt all·"".ro. p~od,,"", Ii:>: tho St,." of

*""".. Tho ,,,,,,,,,nt ..... nood in flY09 J<ld ..-iii coolin:.;, jQ to

uood by the Stt<o in tl>;; m~ oflOOs' ",osr='. nti, =srn<J>t i, cro;loctoo lDlct the

joint.ut!lO<iljl oft.'>o Sm. !Wmlnistt:ll.ive Apo,y (the DEM\ itI<l ,he Ulb.n Are. Poiot o[Coot"t,

"'ith r<Yi"" m:I .pprov:>l 0[<1>0 Nevada COlMh""'" 00 1bwd>..'>1 80curity \1'iClIS). l\:<tner. tbi.

pKlC<lS h.>< be... l"";-X\ed J<>r;nNov"".', S"'" P""..abe.. Rtpo" (SPR), .. ;. ""I">:ed _.lly

hytheDH8,

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 20
 

 

,bolly, 'leva:!>. a40 ""I"i'C< oll f"".M< _ to .ubt:ait. pro;'" pl>n b_ upoo Ihe DIIS

approved i""'>1lr,'"j",ti:'t«ti""""'"""'J)' (l') fot otell. "WfOV<>J proj«:<, lloi. ilWnll.tioo ""P''''''' the

mil..",,,,,.. alb .00 tirnclinc. to C""'l'I<", eee~ projocc n. ",iI,,,,,,,.. '"'" ..... ore

lll=.rabl< >nd fCNl' oci"ntod ...ith limo dri,'<ll ~~",,<h no d_ly non,"",," 'y tho DEM

m;l "0 p-.o"~LO til< :'>CHS "". ~«ly_"

St.,o" folly 1...lo....Wi

R!£Om!!lAA~11jg! f 1, I.""rpor_ lb. CO.I...d obJ._.. loto ••tal.wld. 'y",m fo,

......oriol 10<01 jori'driQll llrtI ....poIldu JX'<lzm. ""'xi ••bl<vltll '110 ~W< ".d

obj«1l,...; .nd

In odd;';"", lhe DEM '''1'';'''' tIoc proj,ct man'ge", .'1""''' .,.,,,~.... .oc ft"",1 >.geJl" '" ",bmit

<J-!"dy tin",,,;'1 -'1""" _ ~"""orI1 programttloti" '"~, ~1lich incllld. a clear

do'Ill'>I,.tl.ci<m of prole'" P"'llfC". Tloo proi'.mlll.bo .lIltU1'ltli.. """" ."""eo p=....t~, of

proj"" compktioo. toob """ompii>hmcnu, iiJanci<1 51"" a<>d ><oounl>!lilil" _ .." clmllen~

rho> woold _tially r=lt in ".-oj"", lllW>.i"" m,'I:....oIo", ''''''plci. tho I""ioct "iLh'" !he

~lI1t I'orfo<"""",, l'Orioo.

~t.tu: t'.My lw.l.woWl

Rtro"'O!AA<bl';oo t 3, Do< tho ''''~".. o<.i... ... b••h for III>kfJlZ ...."lolon. nprd!nz;

!otor< 0 .., r",nod,r ~r..",

A. i, would ">I.,,. '" th, S_ ...obIi.hi"~ • "",", ii..- ,,,,",lDg 4",,>00", rc:g..,li"" r"core ti",

""!J<lnci« W"-''', [~.. Dl'M ..iii,,, "'"'" tooh and j'>'t><e<= .. "'planoti"" tho UEM_«

_ely witk oM pro.;&, do'ioioo-tt"-"bn~""'~ to tho N..oda C""""'.."'" "" S",urity

priu- ., tho holJinning of...,j, g<ont o)'Oi" Ttl... toolo ill<h>d.. btl< or. oot limited

11<_10, tho St."

Homcltnd S"""";!}' SIr""N, U,bon Nca SIr"'"IY, "'t",'lel. Torp< C""obility _""...."""'" !<1M3

C"""";-.<O 1'",i (NIMSCASI.l. SrR, Oi5torbJ lin>ncioJ ><eli,iL)' ll)' ,_iii, I"~j ..[, hisrod.all<<1""

oomrleti<mlpro_, "]>0"", proj«:t .";".,, p"""'t.iom'oxpan""",,., y ",,=_,

£od.....1.d...,.:Onancid "'"' rcqui~'1'llond'"'~ole.

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 21
 

 

Whil, """" oftlx>oo t""lo "lOy not >;ppoarto \>e 4iffi:tly 'dated '" "1xc1"" "'''111,"'' be .-l.. ,

0..;, "" U1&Dog dcci.ion< re3"'<!iIli bnur< full r<<po<ldor 1''''''~ tho DEM. throu,:h "'pononc<,

h.. ob.,m,d thot "':>rki"~ <no"'loo4o of <Ill compooOIl'" ... ctitiool rot tho d<c~mak", >;hen

mlmti..: proj«:t j><rionn."", _ 1'«'1'.... and i,ll!rt~", "'~lor "'rounlal>li'y p_po'" ..

i'''''''''ld nll'''''to II"j<e< proj<et oo"'l'loti<Nl 0JId f_1 inlosri'r.

a".....'.dotin. # 4, Td""H,. "'"I""'I .ud prop",'" pr<JO<t••lut "m ..001 .ddltloul

.,,,,,pl'" r".d;n~ boyoo" 'no I"'.' perial; "'i-<, lb. timolram...... 'h. ''''''''DO .rlOOll'1 ...nlod '0ulolnl ..... , •.,""... P'.j","; ud pro.ld••ptl.,,, l:..- ."."""-;n~ tI,,, ''''l"'bllili<,

b,iq; ..qu~.iR.., .boon".f fo<l"oIll1l"l1.

A. prev'=r ""to<1 "'.col !""lOO" ;"pro""''' """.do. havo boon don< ov" ;h< """"'" "r m,,1ip1. ~"'t

"l"'I<oI to the ...lily of to >ohiO". multi,;,,,,, tim<ly "opoodi.~ of fund> ltd

"""",eOOn of mi.,...,e>. M",y of t'o: ~. an: """"I. Th'''' ,....,""-«1 projocl....

I!ld ,,,,,i<l<rod "'orr ;~" i. lcl>.ti"" to "clt it"'< ')cle, Thi> co,i<... ;, runWcted hy;'"

Ku",daJXl S",urity W~ UrDu!> (HSWG) I!ld the F......,. emn",;tt" of the No.....

Commm;oo o.H~Soo\lrily.oo the 1\>11 N"oda Commi...,. on I~S"'<rit~

Th< DEM ~'Dulu "'"l'","'ullr 'obutit. row""", thot d",'" the =-'10.10 <>fth. """"""~, """'~

I""j.,.".oo ,,,.hIiohod ,,...bilili,, r<m.>tn "il""t upon the '''''''''' {}[ lOdetal f""", ., pru>i<!e ...

tl\e ""in!"""" ofoOOl< _ "f d_ cop>bjEli<o< ..::1"",«,1 .. i, 1"""""" '" in lJqn<t,.- "f

Ho"",lai>l ~oourity'. !llfc<ma~oo B',]etiu ~J!6 (I.."," N'u;'''''''''''' l.II, 2009).•·"rlh.... w1'i., ..1

..-"1<1". ""'" oo,",i.r<!ltlr bee. r<oe<""bffi, ...:i «plOOnS opti<mo 'ot "'","'.nel". tho< >rc

inci<l>i.. of multi_I...1 juti«fution poruei!"'ti"". th, ,orren< """"""l' io not condocj.. to

""""""<.tit all(] impl"""""'tion .. 0.;,; t;m,

n" St." of Now.<l.", "'JI<lltly <:xpai<trin~. $3 .il""" ddiul ~'i" ;!a politi.,.. ..Wlviai<u

,<p<ria>;;inr; <",,,10<,,,. <ilniar f"""cial challonil'~ Notoblr. Nev.n.. i. ".,,,," .. h..ing tho M~>i

rate .00 ~" "","""",,,,...., "to in Lt.< eoun:ry. "i, wHh rnucl1 "''''''". tkot . ok..1y ow, j" tbe _, of f,J",.j fundin8 ., " ..il .. tOe cutretlt "onomEC cl\ma .

mo.oy of OUl' 1""5e<t> """ "'ob~>!t<d ..~al>iilti"" would .. >i~UltiJ O«l<d bock '" <'""I'!etoly

d:",""",d. I1u"""-,,, in til< """" of .nm<h imjxo>od e",,,,omy. th< lit"'-< "'ill "",,1"'10 a

£hot<d ""It;_j uri>dictionol cootrib.oo. "'OthOO for '"-'rum-.

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 22
 

 

Fm.Jly. lJ>,

•

DEM ",,,,"t> with th;" findi.g ,..;,t, uoo...t,nd"s of the ch>Jl_ nolOd '""'YO "'"

";11 octivoly ,"';vo '" """""" .uolaXnb;IOty ;"d~ offcrt""ll\m<JiI\l"IIOO!l" i,[,,,,r,I<.

R<'«om d-.. • 5: >:"lIy imp!......i lbe polld.....d pl'OeMuns to< <Il>-<IU ..."i.......1 .r

lub~r ","itb tho 1>"11,,1W,., rffiplflln d«I!:".ted tIlo ~If:h"" 1""""';'" "In. "b.~uli.1

.I,llJ,.ud

RD.....,

Tho llRM, '" oxpl.i,.,l dun~ t!oo ,.,,"'"of'''' .ooit, ~","d • COJlllltiooc. orneer in i",lWY, 200",

Si""" "'.. tWne, the C<mpli""", ()!ftc<, ~<v.1op<d l!l< OEM', p<lli<i.. al>l proct<!I1'" JOt

ocmplimco 1Uouito~ md bop • pilot prell''"'' f", 'Olpl=<tll.tJoo_ no;, ""IP" ","" _nor

.Wi'1Jll'. odolini"'''d by 111< DEM, 10 1<51 Ill. polici« oll>:I ~,.,,, prior to fill! impl<mrololio"

'hot wo\ill ",,,,,1,,,, ~tr, .>",,, ''''''I'l'' ..blP"" S"."" ibo tim, of ibo l'l'di~ "'" L>li.~l',

C<I",plia""o om,,, ",,,>no<! '" ...,!h<r _"".,.1"'"[H",iLi.on '. ",..",,!Iy 0"1",, """,",""""_

Tho "".. rlh j),i. mding md ""knowl,d)", to. b...fi" of Oil-'''. "":",,' o<>:l

.<rille"ioo prefcrahIc ",,£'>0<1 of\n""ite<ins- Howcvct. 'lith ooostrJinto ofIimitd I'tsoorctl,

tb<: DEM '0'",,10 =lJQCtfuJly "bmit tho iblloorjn~:

n, ~n<ling, r""ltin& in thi, =ommen<!"'iou, ""ool:w. "i" N"aJ. SAA clio not od"fW-tdy

<OOrUlor:h< acti~iti .. otsubgranl"" TIt. 1lIM0' I!id "",,_, f"'riodk oil, .i~~ .. oil...... tho

~rogr.." 3'סOIl. by ~l:'tn_ pi"".fIrt<!",,-~id "" -., \1''"'' m""'lioment ud porl(wm.""" """,;","n8

]!Qlioi.. ID;\ proctd""",", tho l'F\'06. FFYQ1 "'d Fl'Y(tl) ll00101.r<l >e<onl)' GrJ<lt

PrOiC"" .w.m. ...", =de. A""","nWl. ().., 'J;01J<Y ~' .. OO! In¥UC of tho 0""" that i"

'cb_'.... >dl""J '" fMec.1 ""lui""""'" ..4 IP'" ~,\<I<li""" or oclo;""rl Dr,.'; ..-.1 'll""Y

P"'\l"'ID"''';-' ~.~ ....1~'''"'',._ L'ho I""k of. p<,;ooie, M-..... ""'ll'lItltt. tnOOit~""'1''"''

p_",Lod <he .g<ncy froIn ontllining fir>t-hond koowlodl'- of lpOCifi, lWll'1'tI.. odInini,troti"

prol>l<rn' and i,,,,.~" Sub"'l'l<tlUy 1'<f<l'<ll«d .. re~.""y.... 0<1_;"""". ,..,..i1'<"",," "".. 44 CfR lJ,4lX') ID:! OMB A_133, Pllt 3·),1,

Fi"'. ,Ilt OEM """tu "'limit th'" i' <1i.l "Ild«J-<Ir """,i"',' -I> ""I!'an\t" md d;d """ "17"'"

"""'"Iert't"'" "'"I""!<,rn,.,,,,o "",,""'ring pol~ .00 .. in p1aco ..bon tho nY06, I'1'Y<l7

""" FFY~ ll<>IDoJan4 Sccuri'y Gr",t Progrom 1lWlIl<!. "'... Ina<!.: lilt DE),!, during th:o dr••

pm"'" otilir.oo:! IItld ,om",u.. 10 "tiliz. lO<lay tit< follov.."'~ "..-, ...hile "ri"ng 1O",.,d

~lerr=tllli<m of",,,il< IOOni>:Jnnll ,i,i":

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 23
 

 

1. Quarterly Pinmci>l Rtpo~, Reviowod, audit,d "xl v<rifiod rrpmi"'" """v!""'" p;io<

2, "'Q'ua«ody

Prooes""'i Pro~,&:~Ropoo' ···Rev"""1"-"""''' _ """fiod Yo< imp!"""",,,,,,,,, ,00 .:'Iu, ofpro~"

J. R","",,' of annual joo'io:l'oU",1Oi ...:li< "'fI"N':' _ R"'"tt;n~ ;n rolt"",-\>\, ...t Jralilorj~ of

• E",b1i_' '''''''''''''. ""tiooof fedeciol, .tIc (program) oncI fi"""iaj """""""" _ Ro""j<ed to be 'i~

by <000 ~, .. ,"o,-,;htior\ foc=cipt ofth_ a...ord

j, 'Nevada Comrno,.joo 00 lioo1.l>OO S""",ity Qu"'""Y Ropct'l• ..>dl", 1'<,..".,.;".... _

Proviilini h publio tnJ"'~=ocy m;f "'oont....hty

6, r"got C"I'ooility A"....-t< _ Utth:zod rot tho P"'J'O'" of -....ri_8 "'0;""=",' of

1;Oals, obj tctiv"' JJ>l tim<!iJw, .. y".h ..P'"_ ""-"'t: "pallili';'"

7, C"",in",d <J>:l ,,~.....",,,,ct'oo with ,"b~""', throogh ",rh.1 ond ,!cotto..,

c""""..mc"","" ",laLive Lo .&Jib"...1..-mon.S"""" ond j><rl'o"",n"" r<""",~u",,,,, (i.••,

EJIP, ITSEEP, Tni,i"l(-"'laW "l'i","'al requim"""", C""""""ioo. "I'P"'vll! rcquirccnenll.

Oltt-of-C""n~T "P!""vol ''''l',;,'''''''t~ ""..) " ",ell .. toelri",l ,,>1>t"". in LIt.

m""'gem"" ol..b.!!'..,,, ,,,",do,

AI",. b<iinr"n~ wit" ,tl< ""YO') gmt ,ycle, Iho DEM, ~'iTh "p,,,,,,'aJ oftb< N"od. Commi,,",,,,

on Iioclcland "'"""1''''''''' &x:uriry- ullj)I<Jl>O:<'" • po>li;:y idorLtiIT": .. o;"cl<'" L1 1h< ~. or

improvinJ 0(""jac, ,~ "",""t< _ ....&/;,],;n: ~Ool;",. "' 0<1<1,.", "''I'"''''

,!lot itJJ><rently '''\lit HI • ,t.rn:e of ",tOll! frC<tl tOe oriJlinolly .wen,'ed prr;ect

FU1<III~, <II< DEl.! wolok «hail tJ.< wle boTh pro,;,;o", r.<[1P<c """"Iotir.io ;bey do oot

'I'<ci~coli, morul... "",,,,iLe v;~',· ... (he roquiro<1 """'" of """orrpl~M,,,,,a" rtlOOitcrina,

S"",i~i.ll" p",- 3_M .Lot" tho, jronlo<' u, reopornilk fur moni>rirl.i ,uI>JrUl"'" \1.1. off.~oral

.Won. thmtl£o ..eporti"~, ,ito ,,,it!, ",~l>' ,oot"",. '1l c<h<t morn<. 1lI. omp/losi> i. ph«<! 00. the

"c<" in ,to:, 1."SUoe<' oIlowins fur tloxibiliOy in the 'l'l"'O"'h utilc.ool b~ " ff \""",ld rolille

10 ;he roooitoou.g of <ubgrnn".~ .p 10 ani! iock>:linj; "". of "oth<t mc"'~· The DEM "£UI"I~

..j\i.;:" r~ rcrul.. OO"'><ll!!!!! oth<t """'" '" tn<lnn.- ",h",.._ w~h i"",_,tior\ of

"" ,"':.. in P'OI;!OS' "k.,,',," ,.,..;bl._ Hu"",y,,-, t)-" DEM "",.ld Ii" <~" ,t<

acknol'llod__t cl the b<rteotl d<rivorl IiTIm on-"Io """,tooin3 ...t>on ~.,h i••#.,,,"'10 tb1'OOth

"",1:0010 ,,"oill,,,,, md will ,ooLin", eo ,m"" tot oIfootiv, implllllotUtiOO of on 00_';'" mooltorinj;

P"'~"" ot.mod:fioJ onetM., 'C!1lovo sim~or ",cit<.

Stat." r.lly Implo.....t<d .itbtJl ....bJI...od m.od.t"

Ro,•.,m,Rd.tkln _ 6, b ••" ""''1u," "",.r'"" or. ]>I'<'Yt<lOll '" lb. ra._r;"1 ,trnrl, to

'."plore oolloilukd .... "~'" OJ< .I>Wn ,u~-U...tt. ""'Ilto""-l ;n'onllarl"" tb""'llb ot/M.

' ••IT'" ohu,uol yorili<.ti"" 'UM" d.,. ,..",pod >1doo, pkot.JlI"IpJo" SI<ype, ot,,-

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 24
 

 

Th DBM ''''''''''' "ith t:Hs ~"iI """ ;. commi""" to en,urillll ilioI """"'roM, 10;:1>0, ,0<

ootIiltoiJ:Lt' of .,,"'Iobl< ""0lltCt0, "'" l'C"".,.,d CO tbe off"", '" ,,*,i'W monil<Jrinll. Furth<.-, tho

DEM "m """'''''' V>rioo. Ol'''''"'' to ;~o=en( "'"' ~...",whiob. lIlO.y ;llCluded",_i<.

dl.te-.""'P"i pOOw...."o....-.do'", v>leo. S')pC, vi"'" lel"""o!"on<O, 0ClItII0d ooruop<>nden",,- 010-

S'orn: tortioJ/~i lmpl<mn.tod - FIlll..,le,,,"'''loo "J>«'" ",ilhio <; m••tll>

In clooini:. th< DEM ",ould likc 10 ""p"'" .If"". "" iWitud< f"" ,he ,<>11«". ,fln"" ol.~

in ",.;,.;"~ tllc S"", of _,,,,,. '" it> [0 im"",v• .00 eJohonoe i'>nI "'."'__ .m

IOOnioorinJ pr!IC<>oa hI holp to ."".,••!!ocr;v' .,\d dki",,' I""g<"" impl<mcnb'k., ""I.

""1>ining >pp1'Oj)ri>to tro,Up:trMCy ""ti." o.l 'ubli'.""o """""""""lily. It', \»on • ,.,.j plcasrlr<

woro>a wit). lb< ,"" off">", '" (''''''1'0-"'1 ..0 I ..,..ld l\mbcr like to ac~a<1110

oo,,>l>toIr, 1,,·<\ 0 f prof"' 1;"" .lU. ''''' <lem<mW"od """ m>inI>iD:<l throuiOO<! this ~ro:."elI

Appendix B 

Management Comments to the Draft Report 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 25
 

The State of Nevada’s Management of State Homeland Security Program and
 
 

Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 26
 


Appendix C 

Organization Chart 
 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretary 

Director, GAO/OIG Liaison Office 

Assistant S ecretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Off ice of Legislative Affairs 

Federal Emergency Management Agency 

Administrator 

Assistant Administrator, Grant Programs Directorate 

Federal Emergency Management Ag ency Audit Liaison 

Grant Programs Directorate Audit Liais on 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

The State of Nevada’s Management of State Homeland Security Program and
 


Urban Areas Security Initiative Grants Awarded During Fiscal Years 2006 through 2008 
 

Page 27 
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.