HOMELAND 

SECURITY

DHS Needs Better 

Project Information 

and Coordination 

among Four 

Overlapping Grant 

Programs

Report to Congressional Requesters

February 2012

GAO-12-303

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-303, a report to 

congressional requesters

February 2012

HOMELAND SECURITY

DHS Needs Better Project Information and 

Coordination among Four Overlapping Grant 

Programs

Why GAO Did This Study

From fiscal years 2002 through 2011, 

the Department of Homeland 

Security’s (DHS) Federal Emergency 

Management Agency (FEMA) 

distributed approximately $20.3 billion 

to four grant programs: the State 

Homeland Security Program, Urban 

Areas Security Initiative, Port Security 

Grant Program, and Transit Security 

Grant Program. These programs are 

intended to enhance the capacity of 

state and local first responders to 

prevent, respond to, and recover from 

a terrorism incident. GAO was asked to 

evaluate the extent to which: (1) 

overlap and other factors among these 

programs could impact the risk of 

duplication; (2) mechanisms exist that 

enhance coordination and reduce the 

risk of duplication and how they are 

being implemented; and (3) DHS has 

implemented performance measures to 

evaluate the effectiveness of these 

programs. To address these 

objectives, GAO reviewed grant 

guidance and funding allocation 

methodologies. GAO also interviewed 

DHS officials, and grant administrators 

in five urban areas—selected because 

they receive funding from all four grant 

programs in this review—about grant 

processes and program challenges, 

among other things.

What GAO Recommends 

GAO recommends that DHS: (1) 

collect project information with the level 

of detail needed to identify any 

unnecessary duplication; (2) explore 

opportunities for enhanced internal 

coordination in grant administration; 

and (3) revise its plan to ensure the 

timely implementation of performance 

measures to assess the effectiveness 

of these grants. DHS concurred with all 

recommendations. 

What GAO Found

Multiple factors contribute to the risk of duplication among four FEMA grant 

programs that GAO studied—the State Homeland Security Program (SHSP), 

Urban Areas Security Initiative (UASI), Port Security Grant Program, and Transit 

Security Grant Program. Specifically, these programs share similar goals, fund 

similar projects, and provide funds in the same geographic regions. Further,

DHS’s ability to track grant funding, specific funding recipients, and funding 

purposes varies among the programs, giving FEMA less visibility over some 

grant programs. Finally, DHS’s award process for some programs bases 

decisions on high-level, rather than specific, project information. Although GAO’s 

analysis identified no cases of duplication among a sample of grant projects, the 

above factors collectively put FEMA at risk of funding duplicative projects. FEMA 

officials stated that there is a trade-off between enhancing management visibility 

and reducing administrative burden, but also recognized that FEMA should use 

more specific project-level information for award decisions and have taken initial 

steps towards this goal. For example, FEMA is considering how to better use 

existing grant information and has also begun to phase in a grants management 

system that includes an explicit goal of collecting project-level information. 

However, FEMA has not determined all of its specific data requirements. As 

FEMA determines these requirements, it will be important to collect the level of 

information needed to compare projects across grant programs. Given the 

limitations in currently collected information, FEMA would benefit from collecting 

information with greater detail as this could help FEMA better position itself to 

assess applications and ensure that it is using its resources effectively. 

FEMA, as well as state and local stakeholders, have taken steps to improve 

coordination in administering the four programs, but FEMA could take further 

action. For example, FEMA does not internally coordinate application reviews 

across the four programs. Specifically, the programs are managed by two 

separate FEMA divisions which review grant applications for each program 

separately and there is no process in place to ensure that application information 

is shared among the programs during this process. Thus, it is difficult for FEMA 

to identify whether grant monies are being used for the same or similar purposes. 

FEMA could benefit from further examining its internal grant coordination

process, while considering the large volume of grant applications it must process. 

FEMA introduced some performance measures for the UASI and SHSP 

programs in 2011 that add value, but these measures do not assess program 

effectiveness. FEMA has efforts under way to develop outcome measures—that 

will focus on program effectiveness—for each of the four grant programs in this 

review, but has not completed these efforts. Further, the FEMA project plan that 

guides these efforts does not provide information on what measures will be 

implemented for each grant program and when this will occur. A revised project 

plan that includes more specific schedule information and accurate 

implementation timelines could help guide these efforts. DHS also has several 

efforts under way to measure the collective effectiveness of its grant programs in 

achieving shared program goals, but these efforts are recent and ongoing. Thus, 

it is too soon to evaluate the extent to which these initiatives will provide FEMA 

with the information it needs to determine whether these grant programs are 

effectively improving the nation’s security. 

View GAO-12-303. For more information, 

contact David C. Maurer at (202) 512-9627 or 

MaurerD@gao.gov.
Page i GAO-12-303 Preparedness Grant Programs

Letter 1 

Background 6

Overlap and Other Factors Increase the Risk of Duplication among 

Grant Programs 12

Enhanced Federal Coordination Could Help Reduce the Risk of 

Duplication 26

Some Performance Measures Exist for Individual Grant Programs, 

but Work Remains to Assess Grant Effectiveness 30

Conclusions 36

Recommendations for Executive Action 37

Agency Comments and Our Evaluation 37

Appendix I FEMA Grants Portfolio 41

Appendix II Comments from the Department of Homeland Security 42

Appendix III GAO Contact and Staff Acknowledgments 46

Tables

Table 1: SHSP, UASI, PSGP, and TSGP Funding for Fiscal Years 

2002-2011 7

Table 2: Purpose, Project Type, and Eligible Applicants of SHSP, 

UASI, PSGP, and TSGP 14

Table 3: Description of Project Information to Which FEMA Has 

Access for Four Projects in One Jurisdiction 23

Table 4: Description of Project Information to Which FEMA Has 

Access—Example #2 24

Table 5: Selected DHS Grant Program Initiatives to Develop 

Outcome-Based Performance Measures 32

Table 6: FEMA Initiatives to Evaluate Overall Effectiveness across 

Grant Programs 35

Figures 

Figure 1: General Grant Life Cycle 9

Contents
Page ii GAO-12-303 Preparedness Grant Programs

Figure 2: Involved Federal Agencies and Grant Funding Paths and 

Processes of SHSP, UASI, PSGP, and TSGP 16

Abbreviations

BSIR Biannual Strategy Implementation Report

CBRNE Chemical, biological, radiological, and nuclear detection 

 equipment

DHS Department of Homeland Security

FA Fiduciary Agent

FEMA Federal Emergency Management Agency

GPD Grant Programs Directorate

HSPD-8 Homeland Security Presidential Directive-8 

IJ Investment Justification

NAPA National Academy of Public Administration

ND Grants Non disaster grant management system

NPAD National Preparedness Assessment Division

NPD National Preparedness Directorate 

OIG DHS Office of Inspector General

PPD-8 Presidential Policy Directive-8 

PSGP Port Security Grant Program

SAA State Administrative Agency

SHSP State Homeland Security Program

THIRA Threat and Hazard Identification Risk Assessment

TSA Transportation Security Administration

TSGP Transit Security Grant Program

UASI Urban Areas Security Initiative

UAWG Urban Area Working Group

USCG U.S. Coast Guard

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Page 1 GAO-12-303 Preparedness Grant Programs

United States Government Accountability Office

Washington, DC 20548

February 28, 2012

Congressional Requesters

More than 10 years after the September 11, 2001, terrorist attacks, the 

United States remains vulnerable to attack, as evidenced by the 

attempted Christmas Day bombing of Flight 253 in 2009, the attempted 

car bombing of Times Square in New York City in 2010, and the disrupted 

plot to attack the subway system in Washington, D.C., in 2010, among 

other examples. As noted by the Department of Homeland Security 

(DHS), terrorist threats continue to evolve and can vary widely in their 

origin and scope, ranging from a lone U.S. citizen detonating a pipe-bomb 

to a sophisticated biological attack by an international group. In addition 

to the vast expansion of federal homeland security measures over the last 

decade, state, local, tribal, and private sector entities, as well as citizens 

themselves, have assumed a greater role in protecting the nation from 

terrorism. To assist states and localities in strengthening the security and 

resilience of their communities against risks associated with potential 

terrorist attacks, the federal government has undertaken a variety of 

initiatives. For example, the government has expanded financial 

assistance to a wide array of public and private stakeholders for terrorism 

preparedness activities through various grant programs administered by 

DHS through its component agency, the Federal Emergency 

Management Agency (FEMA). For certain grant programs that require a 

particular subject-matter expertise, FEMA also coordinates with other 

DHS entities, such as the U.S. Coast Guard (USCG) or the 

Transportation Security Administration (TSA), to administer the grant 

program. Through these grant programs, DHS has sought to enhance the 

capacity of states, localities, and other entities, such as ports or transit 

agencies, to prevent, respond to, and recover from a terrorism incident.

From fiscal years 2002 through 2011, the federal government 

appropriated over $37 billion to a variety of DHS homeland security 

preparedness grant programs.1

 

1

This total is based on Congressional Research Service data and GAO analysis, and 

includes firefighter assistance grants and emergency management performance grants. 

See Congressional Research Service, Department of Homeland Security Assistance to 

States and Localities: A Summary of Issues for the 111th Congress, R40246 (Washington, 

D.C.: Apr. 30, 2010).

DHS distributed approximately $20.3 

 
 

Page 2 GAO-12-303 Preparedness Grant Programs

billion of this funding to grant recipients through four programs: the State 

Homeland Security Program (SHSP), the Urban Areas Security Initiative 

(UASI), the Port Security Grant Program (PSGP), and the Transit Security 

Grant Program (TSGP). Although these four programs are administered 

separately, they fund broadly similar activities, such as planning, training, 

equipment, and exercises. We previously reported on FEMA’s full suite of 

17 fiscal year 2010 preparedness programs, including these four 

programs, and noted that FEMA needed to improve oversight and 

coordination of its grant awards to identify and address any unnecessary 

overlap and duplication, among other things.2

For the purposes of this report and our analysis of the four grant

programs, we considered “duplication” to occur when two or more 

agencies or programs were engaged in the same activities or provided 

the same services to the same beneficiaries. We used the term “overlap” 

when multiple agencies or programs had similar goals, engaged in similar 

activities or strategies to achieve them, or targeted similar beneficiaries. 

The presence of overlap can suggest the need to look closer at the 

potential for unnecessary duplication. However, determining whether and 

to what extent project funding is actually duplicative requires project-level 

information, which we collected for a sample of grant projects as 

discussed below.

You requested that we evaluate these four grant programs, including the 

administrative coordination and effectiveness of these programs. This 

report addresses the extent to which:

1. overlap, if any, among the four selected grant programs and other 

factors impact the risk that duplication may occur within and across 

the programs;

2. federal, state, and local mechanisms exist that enhance coordination 

and reduce the risk of unnecessary duplication, and how DHS and 

other stakeholders are implementing these mechanisms; and

3. DHS has implemented performance measures to evaluate the 

effectiveness of these grant programs.

To determine the extent to which overlap, if any, among the four selected 

grant programs and other factors impact the risk that duplication may 

 

2 GAO, Opportunities to Reduce Potential Duplication in Government Programs, Save Tax 

Dollars, and Enhance Revenue, GAO-11-318SP (Washington, D.C.: Mar. 1, 2011).
 

Page 3 GAO-12-303 Preparedness Grant Programs

occur within and across the programs, we analyzed FEMA grant guidance 

and information for each program throughout the grants cycle, including 

grant recipients, project types, and funding amounts. To determine the 

eligible recipients, grant program purposes, and allowable projects, we 

analyzed federal grant guidance. To establish the various methods that 

DHS used to distribute grant funds, we analyzed the grant guidance and 

applicable federal statutes. Then, to understand how these various 

distribution methods affected coordination within and across the grant 

programs, we interviewed FEMA’s federal partners—USCG and TSA—

both of which play important roles in program management for PSGP and 

TSGP, respectively. To determine the extent to which DHS components 

were involved with the project selection process, we analyzed grant 

guidance, applicable federal statutes and regulations, state and urban 

area homeland security strategies, and other documents that describe 

local project selection processes. We also spoke with federal, state, and 

local officials and collected documentation on distribution methods during 

site visits to five urban areas: Houston, Texas; Jersey City/Newark, New 

Jersey; New York City, New York; San Francisco, California; and Seattle, 

Washington. We used specific criteria to select these urban areas, 

including their levels of grant funding for all four grant programs, 

recommendations from stakeholders familiar with the programs such as 

FEMA program officials and association groups, and their diversity of 

terrorism and disaster threats. While the information we obtained from 

these urban areas and corresponding states cannot be generalized, it 

provided insights into projects initiated using grant funding across the 

grant programs we reviewed.

To assess the extent to which SHSP, UASI, PSGP, and TSGP funds 

could have been allocated to unnecessarily duplicative projects, we 

reviewed FEMA Investment Justifications (IJ),3 Biannual Strategy 

Implementation Reports (BSIR),4

 

3 Investment Justifications (IJ) are one component of SHSP, UASI, PSGP, and TSGP 

applications for grant funding. They provide narrative information on proposed activities 

(investments) that will be accomplished with the grant funds and are described in more 

detail later in this report. The IJ must demonstrate how proposed investments address 

gaps and deficiencies in current capabilities, and also demonstrate adherence to program 

guidance. 

and other FEMA files, such as 

4 The Biannual Strategy Implementation Report (BSIR) is a reporting requirement 

submitted by states to FEMA on the progress of certain grants. These reports are 

described in more detail later in this report. 
 

Page 4 GAO-12-303 Preparedness Grant Programs

spreadsheets related to PSGP and TSGP awards. We also reviewed a 

DHS Office of Inspector General (OIG) report on DHS preparedness 

grant funding that reported on each of the programs we reviewed. We 

reviewed the methodology and findings of this work and determined the 

findings to be sufficiently reliable to be included in this report. We also 

analyzed every project submitted by the selected five urban areas for all 

four programs for fiscal years 2008 through 2010, which totaled 1,957 

projects. For our project analysis, we defined overlap as any projects that 

appeared to have the same purpose, the same project type, or the same 

entities receiving funds. Projects were defined as unnecessarily 

duplicative if they overlapped and FEMA had no evidence of coordination 

between the recipients or in certain cases, between different FEMA 

divisions. We did not regard projects that used different funding streams 

for different aspects of a single project to be duplicative. Using this 

definition, we analyzed FEMA information on grant projects and 

categorized overlapping projects that had the same or similar project type 

and description and were within the same jurisdiction. We used BSIR 

data categories as the foundation for our analysis. Port and transit 

projects are not included in the BSIR, thus information for these two grant 

programs was obtained from FEMA spreadsheets and recategorized 

according to the BSIR for comparison. The accuracy of the categorization 

of the projects was confirmed independently by two GAO analysts. For 

the purposes of our report, we concluded that FEMA’s project information 

was sufficiently reliable for each of the programs we reviewed. For 

projects identified as potentially duplicative, we obtained and analyzed 

additional information from state officials, including coordination plans, 

project ledgers, equipment inventory lists, planning and training rosters, 

and expanded project descriptions, to evaluate the extent to which any 

funded activities were actually duplicative. To determine if the information 

maintained by FEMA allowed the agency to meet its goals, we compared 

the results of our data analysis to Standards for Internal Control in the 

Federal Government. 

To determine the extent to which mechanisms exist to enhance 

coordination and prevent unnecessary duplication within and across the 

four selected grant programs, we reviewed national planning documents, 

such as the National Preparedness Guidelines,5

 

5 Among other things, the National Preparedness Guidelines are intended to organize and 

synchronize national—including federal, state, local, tribal, and territorial—efforts to 

strengthen national preparedness.

along with grant 
 

Page 5 GAO-12-303 Preparedness Grant Programs

guidance and federal statutes that establish linkages across grant 

programs. In addition, we interviewed FEMA officials from the grants 

divisions responsible for administering each of the programs, along with 

USCG and TSA officials involved with administering PSGP and TSGP. To 

assess state and local coordination of grant programs in each of the five 

selected urban areas, we interviewed State Administrative Agency (SAA) 

officials,6 various members of Urban Area Working Groups (UAWG),7

PSGP fiduciary agents (FA), local USCG officials, and transit system 

officials familiar with the TSGP. We also reviewed state, urban area, port, 

and regional transit homeland security strategies for the selected areas, 

along with other state or local guidelines related to the administration of 

the grants programs, such as membership charters for the UAWGs. We 

also reviewed FEMA guidance to states and urban areas on aligning their 

homeland security strategies with national preparedness objectives. We 

assessed coordination efforts against best practices described in our prior 

reports.8

To determine the extent to which DHS has implemented performance 

measures to evaluate the effectiveness of these four grant programs, we 

analyzed DHS and FEMA documents from 2011 related to current 

performance measures as well as performance measures under 

development. This analysis included FEMA’s Performance Measure 

Implementation Plan, a document that provides FEMA’s general 

approach to performance measurement including effectiveness 

measures, as well as a list of key milestones to implement new 

performance measures and refine existing measures. We interviewed 

grant officials from FEMA’s Grant Programs Directorate (GPD) and 

FEMA’s National Preparedness Directorate (NPD) to determine what 

 

6 A designated State Administrative Agency (SAA) is responsible for managing the SHSP 

and UASI programs at the state level. This management includes processing project 

applications prior to submitting them to FEMA, “passing though” federal funds to regional 

or local entities, and ensuring that local grant recipients comply with various statutory and 

grant requirements.

7 The Urban Area Working Groups (UAWG), in the UASI regions, develop the 

methodology for allocating funding and make decisions, based on consensus, on all UASI 

funding allocations.

8 See GAO, Transit Security Grant Program: DHS Allocates Grants Based on Risk, but Its 

Risk Methodology, Management Controls, and Grant Oversight Can Be Strengthened, 

GAO-09-491 (Washington, D.C.: June 8, 2009) and Results-Oriented Government: 

Practices That Can Help Enhance and Sustain Collaboration among Federal Agencies, 

GAO-06-15 (Washington, D.C.: Oct. 21, 2005).
 

Page 6 GAO-12-303 Preparedness Grant Programs

grant performance measurement data FEMA had collected or planned to 

collect in the future. In addition, we compared DHS and FEMA efforts to 

evaluate the performance of selected grant programs and FEMA’s 

Performance Measure Implementation Plan with guidance on 

performance measurement contained in our previous reports and 

standards contained in Project Management Institute best practices.9

We conducted this performance audit from October 2010 through 

February 2012 in accordance with generally accepted government 

auditing standards.10 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 on our audit 

objectives. We believe the evidence obtained provides a reasonable 

basis for our findings and conclusions based on our audit objectives.

Within DHS, FEMA manages a diverse portfolio of grant programs 

including a variety of preparedness grants. (See app. I for a diagram of 

FEMA’s grants portfolio.) According to FEMA, the overarching goal of the 

preparedness grants is to enhance the capacity of state and local 

emergency responders to prevent, respond to, and recover from a 

terrorism incident involving chemical, biological, radiological, nuclear, or 

other explosive devices, or cyber attacks. Responsibility for administering 

federal preparedness grants has shifted numerous times within DHS.11

 

9 See GAO, Port Security Grant Program: Risk Model, Grant Management, and 

Effectiveness Measures Could Be Strengthened,

In 

fiscal year 2003, DHS’s Office of Domestic Preparedness administered 

grant programs; since then, at different times other DHS offices have 

administered the programs, such as the Office for State and Local 

Government Coordination and Preparedness and the Office of Grants

GAO-12-47 (Washington, D.C.: Nov. 17, 

2011) and GAO-09-491; and Project Management Institute, The Standard for Program 

Management, © (2006).

10 This work was done in conjunction with a separate review of the Port Security Grant 

Program. See GAO-12-47. 

11 Prior to DHS’s formation in 2003, agencies such as the Department of Justice and the 

Department of Health and Human Services administered various preparedness-related 

grants.

Background 

Overview of DHS 

Preparedness Grant 

Programs
 

Page 7 GAO-12-303 Preparedness Grant Programs

and Training. However, since its creation in April 2007, FEMA’s GPD has 

been responsible for the program management of DHS’s preparedness 

grants.12

From fiscal years 2002 through 2011, DHS distributed approximately 

$20.3 billion through four grant programs: SHSP, UASI, PSGP, and 

TSGP.

GPD consolidated the grant business operations, systems, 

training, policy, and oversight of all FEMA grants and the program 

management of preparedness grants into a single entity. GPD works 

closely with other DHS entities to manage several grants, including the 

USCG for the PSGP and TSA for the TSGP.

13

Table 1: SHSP, UASI, PSGP, and TSGP Funding for Fiscal Years 2002-2011 

See table 1 for a breakdown of the funding for these programs.

(Dollars in millions) 

Fiscal year SHSP UASI PSGP TSGP

2002 $316 N/A $93 N/A

2003 $2,066 $596 $244 N/A

2004 $1,675 $671 $179 N/A

2005 $1,062 $855 $141 $108

2006 $528 $711 $168 $131

2007 $509 $747 $311 $251 a

2008 $863 $782 $389 $356

2009 $861 $799 $539 $498 b

2010

c

$842 $833 $288 $253

2011 $527 $663 $235 $200

Total $9,249 $6,657 $2,587 $1,797

Source: GAO analysis of FEMA grant guidance.

a

This figure includes $201 million in funding pursuant to the fiscal year 2007 appropriation and an 

additional $110 million in funding pursuant to the 2007 supplemental appropriation.

b

 

12 The Post-Katrina Emergency Management Reform Act transferred most of the 

Preparedness Directorate to FEMA, effective on March 31, 2007. Pub. L. No. 109-295, 

120 Stat. 1355, 1394 (2006). 

This figure includes $389 million in funding pursuant to the fiscal year 2009 appropriation and an 

additional $150 million in funding pursuant to appropriations in the American Recovery and 

Reinvestment Act. Pub. L. No. 111-5, 123 Stat. 145, 164 (2009).

13 In fiscal year 2011, FEMA distributed funds to a total of 16 preparedness grant 

programs including SHSP, UASI, PSGP, and TSGP.

Grant Funding for 

Preparedness Programs
 

Page 8 GAO-12-303 Preparedness Grant Programs

c

Includes $150 million in funding pursuant to appropriations in American Recovery and Reinvestment 

Act. Id.

Federal grants, including SHSP, UASI, PSGP, and TSGP generally follow 

the grant life cycle shown in figure 1 of announcement, application, 

award, postaward, and closeout. A grant program may be established 

through legislation––which may specify particular objectives, eligibility, 

and other requirements—and a program may also be further defined by 

the grantor agency. For competitive grant programs, the public is notified 

of the grant opportunity through an announcement, and potential grantees 

must submit applications for agency review. In the application and award 

stages, the agency identifies successful applicants or legislatively defined 

grant recipients and awards funding to them. The postaward stage 

includes payment processing, agency monitoring, and grantee reporting, 

which may include financial and performance information. The closeout 

phase includes preparation of final reports and any required accounting 

for property. Audits may occur multiple times during the life cycle of the 

grant and after closeout. 

Overview of Grant Cycle
 

Page 9 GAO-12-303 Preparedness Grant Programs

Figure 1: General Grant Life Cycle

SHSP, UASI, PSGP, and TSGP are specific grant programs nested under 

a larger framework of national preparedness. The broader initiatives 

described below, some of which are in development, are intended to help 

determine preparedness goals and the capabilities necessary to achieve 

these goals. Grants programs such as the four we reviewed can then help 

facilitate specific investments to close identified capability gaps. The 

purpose and status of the larger preparedness framework affects SHSP, 

Grant Programs Are Tied 

to Broader National 

Preparedness Initiatives
 

Page 10 GAO-12-303 Preparedness Grant Programs

UASI, PSGP, and TSGP in a number of ways, including the development 

of grant performance metrics to assess the effectiveness of the programs.

• In December 2003, the President issued Homeland Security 

Presidential Directive-8 (HSPD-8), which called on the Secretary of 

Homeland Security to coordinate federal preparedness activities and 

coordinate support for the preparedness of state and local first 

responders, and directed DHS to establish measurable readiness 

priorities and targets.

• In October 2006, the Post-Katrina Emergency Management Reform 

Act was enacted, which requires FEMA to develop specific, flexible, 

and measurable guidelines to define risk-based target preparedness 

capabilities and to establish preparedness priorities that reflect an 

appropriate balance between the relative risks and resources 

associated with all hazards.14

• In September 2007, DHS published the National Preparedness 

Guidelines. The purposes of the guidelines are to: organize and 

synchronize national—including federal, state, local, tribal, and 

territorial—efforts to strengthen national preparedness; guide national 

investments in national preparedness; incorporate lessons learned 

from past disasters into national preparedness priorities; facilitate a 

capability-based and risk-based investment planning process; and 

establish readiness metrics to measure progress and a system for 

assessing the nation’s overall preparedness capability to respond to 

major events, especially those involving acts of terrorism. Each of the 

grant programs in our review has specific strategies that are aligned 

with the overall federal national preparedness guidelines, as the 

following examples illustrate.

• State and Urban Area Homeland Security Strategies (all four 

grants): These strategies are designed to (1) provide a blueprint 

for comprehensive, enterprise wide planning for homeland 

security efforts; and (2) provide a strategic plan for the use of 

related federal, state, local, and private resources within the state

and/or urban area before, during, and after threatened or actual 

domestic terrorist attacks, major disasters, and other 

emergencies. State and urban area homeland security strategies 

 

14 6 U.S.C. § 746.
 

Page 11 GAO-12-303 Preparedness Grant Programs

are required by FEMA for receiving SHSP and UASI funding.

• Port-Wide Risk Mitigation Plan (PSGP): The primary goal of 

these plans is to provide a port area with a mechanism for 

considering its entire port system strategically as a whole, and to 

identify and execute a series of actions designed to effectively 

mitigate risks to the system’s maritime critical infrastructure. FEMA 

requires a Port-Wide Risk Mitigation Plan for receiving PSGP 

funding for the high-risk ports, known as Groups I and II, as 

discussed in table 2.

15

• Regional Transit Security Strategy (TSGP): These strategies 

serve as the basis on which funding is allocated to address 

regional transit security priorities, and are the vehicles through 

which transit agencies may justify and access other funding and 

available resources. TSA requires a Regional Transit Security 

Strategy for receiving TSGP funding.

• On March 30, 2011, the President issued Presidential Policy 

Directive-8 (PPD-8), which directs the development of a national 

preparedness goal and the identification of the core capabilities 

necessary for preparedness. PPD-8 replaces HSPD-8.16 FEMA 

officials noted that the National Preparedness System affirms the allhazards risk-based approach to national preparedness.17

 

15 Based on risk, each port area is placed into one of three funding groups—Group I, 

Group II, or Group III. Groups I and II port areas are the highest risk port areas that 

receive the bulk of the PSGP grant funding.

FEMA 

officials further noted that PPD-8 looks to build on the efforts already 

in place, including those that supported the Post-Katrina Emergency 

Management Reform Act and the 2009 National Infrastructure 

16 PPD-8 states, “This directive replaces Homeland Security Presidential Directive 

(HSPD)-8 (National Preparedness), issued December 17, 2003, and HSPD-8 Annex I 

(National Planning), issued December 4, 2007, which are hereby rescinded, except for 

paragraph 44 of HSPD-8 Annex I. Individual plans developed under HSPD-8 and Annex I 

remain in effect until rescinded or otherwise replaced.”

17 The national preparedness system is designed to help guide the domestic efforts of all 

levels of government, the private and nonprofit sectors, and the public to build and sustain 

national capabilities. The national preparedness system is to include guidance for 

planning, organization, equipment, training, and exercises to build and maintain domestic 

capabilities. It is intended to provide an all-of-nation approach for building and sustaining a 

cycle of preparedness activities over time.
 

Page 12 GAO-12-303 Preparedness Grant Programs

Protection Plan.18 PPD-8 has specific deadlines for deliverables: 180 

days for the National Preparedness Goal, 240 days for a description 

of the National Preparedness System, and 1 year for a National 

Preparedness Report.19

The four grant programs in our review—SHSP, UASI, PSGP, and 

TSGP—have overlapping goals, project types, and funding jurisdictions, 

which increases the risk of duplication among the programs. Although the 

specifics of the four programs vary, they share the overarching goal of 

enhancing the capacity of state and local emergency responders to 

prevent, respond to, and recover from a terrorism incident involving 

chemical, biological, radiological, nuclear, or other explosive devices, or 

 

18 In accordance with the Homeland Security Act and in response to HSPD-7, DHS 

issued, in June 2006, the first National Infrastructure Protection Plan, which provides the 

overarching approach for integrating the nation’s critical infrastructure and key resource 

protection initiatives into a single effort. DHS issued a revised Plan in January 2009. The 

Plan sets forth a risk management framework and details the roles and responsibilities of 

DHS, sector-specific agencies, and other federal, state, regional, local, tribal, territorial, 

and private sector partners, including how they should use risk management principles to 

prioritize protection activities within and across sectors. 

19 In September 2011, DHS issued the National Preparedness Goal as directed by PPD-8. 

According to DHS, the goal is “A secure and resilient Nation with the capabilities required 

across the whole community to prevent, protect against, mitigate, respond to, and recover 

from the threats and hazards that pose the greatest risk.” Thirty-two “core capabilities,” 

such as “planning” and “threats and hazard identification,” are listed and defined under 

each of the five broader mission areas named in the goal (“prevent,” “protect against,” 

etc.). These capabilities will be the foundation for measuring overall national preparedness 

and allocating resources to fill preparedness gaps. Additionally, in November 2011, DHS 

released its description of the National Preparedness System that summarizes the 

components of the National Preparedness System, which include: identifying and 

assessing risk, estimating the level of capabilities needed to address those risks, building 

or sustaining the required levels of capability, developing and implementing plans to 

deliver those capabilities, validating and monitoring progress, and reviewing and updating 

efforts to promote continuous improvement.

Overlap and Other 

Factors Increase the 

Risk of Duplication 

among Grant 

Programs

Grant Programs Have 

Similar Goals, Fund 

Similar Projects, and Exist 

in the Same Urban Areas, 

Which Increases the Risk 

of Duplication
 

Page 13 GAO-12-303 Preparedness Grant Programs

cyber attacks. More specifically, each program funds similar projects such 

as training, planning, equipment, and exercises. For example, the four 

programs have overlapping lists of allowable costs, so certain types of 

equipment, such as communication radios, may be purchased through 

each grant program. Further, although the programs target different 

constituencies, such as states and counties, urban areas, and port or 

transit stakeholders, there is overlap across recipients. For example, each 

state and eligible territory receives a legislatively mandated minimum 

amount of SHSP funding to help ensure that all areas develop a basic 

level of preparedness, while UASI explicitly targets urban areas most at 

risk of terrorist attack.20

In March 2011, we reported that overlap among government programs or 

activities can be harbingers of unnecessary duplication. Further, we 

commented on FEMA’s full suite of 17 fiscal year 2010 preparedness 

programs, including the four programs in this review, and noted that 

FEMA needed to improve oversight and coordination of its grant 

awards.

However, many jurisdictions within designated 

UASI areas also apply for and receive SHSP funding. Similarly, a port 

stakeholder in an urban area could receive funding for patrol boats 

through both PSGP and UASI funding streams, and a transit agency 

could purchase surveillance equipment with TSGP or UASI dollars. More 

broadly, any designated high-risk urban area located near major 

waterways can receive funding through SHSP, UASI, PSGP, and TSGP 

sources.

21 Identifying and mitigating the risk of duplication could help 

ensure that these four grant programs, which distributed over $20 billion 

dollars in funding to grant recipients from fiscal years 2002 through 2011, 

are allocating resources effectively. Table 2 below describes the basic 

purposes, the types of projects funded, and the eligible applicants of the 

SHSP, UASI, PSGP, and TSGP programs.

 

20 6 U.S.C. § 605(e); 6 U.S.C. § 604.

21 GAO-11-318SP.
 

Page 14 GAO-12-303 Preparedness Grant Programs

Table 2: Purpose, Project Type, and Eligible Applicants of SHSP, UASI, PSGP, and TSGP 

State Homeland Security 

Grant Program (SHSP)

Urban Areas Security 

Initiative (UASI)

Port Security Grant 

Program (PSGP)

Transit Security Grant 

Program (TSGP)

Purpose of the 

grant program 

SHSP provides funding to 

support states’ 

implementation of 

homeland security 

strategies to address the 

identified planning, 

organization, equipment, 

training, and exercise 

needs at the state and local 

levels to prevent, protect 

against, respond to, and 

recover from acts of 

terrorism and other 

catastrophic events. 

UASI provides federal 

assistance to address the 

unique needs of highthreat, high-density urban 

areas, and assists them 

in building an enhanced 

and sustainable capacity 

to prevent, protect, 

respond to, and recover 

from acts of terrorism. 

PSGP provides federal 

assistance to strengthen 

the security of the nation’s 

ports against risks 

associated with potential 

terrorist attacks by 

supporting increased port 

wide risk management, 

enhanced domain 

awareness, training and 

exercises, and expanded 

port recovery capabilities. 

TSGP provides funds to 

owners and operators of 

transit systems (which include 

intracity bus, commuter bus, 

ferries, and all forms of 

passenger rail) to protect 

critical surface transportation 

infrastructure and the traveling 

public from acts of terrorism 

and to increase the resilience 

of transit infrastructure. 

Types of 

projects funded

• Planning

• Organization

• Equipment

• Training

• Exercises

• Planning

• Organization

• Equipment

• Training

• Exercises

• Port resiliency and 

recovery efforts

• Maritime domain 

awareness efforts

• Planning

• Equipment

• Training

• Exercises

• Capital infrastructure 

projects

• Operational activities

• Planning

• Equipment

• Training

• Exercises

Eligible 

applicants

SAA/ 50 states, DC, and 

territories.

• SAA may allocate 

SHSP funds to 

Designated Urban 

Areas

SAA/ 31 Designated 

Urban Areas (2 Tiers 

based on risk).

• Urban Areas may 

allocate UASI funds 

to port and transit 

stakeholders

a

Port Areas: Groups I and II 

(highest risk); Group III and 

“All Other Port Areas” 

(lower risk).

Selected transit agencies and 

ferry systems within high risk 

urban areas. b

Source: FEMA grant guidance.

a

In fiscal year 2011, Tier I UASI areas included the 11 highest risk urban areas and were allocated 

about 82 percent of the total UASI funding available; Tier II included the other 20 candidate areas and 

were allocated the remaining 18 percent funding. Tier I and II Urban Area are determined using a 

DHS risk model that incorporates threat, vulnerability, and consequence.

b

A DHS risk model determines the port areas at high risk of a terrorist attack and DHS places them in 

either Group I (highest risk group), Group II (next highest risk group) or Group III. In fiscal year 2011, 

there were 7 port areas in Group I and 48 port areas in Group II. Port areas in Group I are considered 

to be the highest risk port areas in the nation. Ports not identified in Group I, II, or III are eligible to 

apply for funding as part of the All Other Port Areas Group. For additional information on the PSGP 

and port area groups, see GAO-12-47. 
 

Page 15 GAO-12-303 Preparedness Grant Programs

FEMA’s ability to track which projects receive funding among the four 

grant programs is varied because the project-level information FEMA has 

available to make award decisions—including grant funding amounts, 

grant recipients, and grant funding purposes—also varies by program. 

This is due to differences in the grant programs’ administrative processes. 

For example, in some cases, FEMA relies on stakeholders to review and 

recommend projects for grant funding—adding layers to the review 

process. Delegating administrative duties to stakeholders reduces 

FEMA’s administrative burden, but also contributes to FEMA having less 

visibility over some grant applications, specifically those funded via SHSP 

and UASI. A combination of federal statutes and DHS policy determine 

specific grant allocation mechanisms and the federal partners involved in 

grants administration. Figure 2 below describes the federal agencies 

involved, the path of the grant funds to the final recipient, and the 

application and award process for each grant, as of fiscal year 2011. 

Differences in Administrative 

Processes among the Four 

Grant Programs Result in 

Varied Levels of Information on 

Which Award Decisions Are 

Based 
 

Page 16 GAO-12-303 Preparedness Grant Programs

Figure 2: Involved Federal Agencies and Grant Funding Paths and Processes of SHSP, UASI, PSGP, and TSGP

a

The Urban Area Working Groups develop the methodology for allocating funding and make

decisions, based on consensus, on all UASI funding allocations.

b

For Group I and Group II port areas—the highest risk port areas—money is passed from FEMA to 

the final grant recipient through the designated fiduciary agent as described in the table. However, for 

Group III and the All Other Port Areas Group, funding is passed directly from FEMA to the final grant 

recipient.
 

Page 17 GAO-12-303 Preparedness Grant Programs

As depicted in figure 2, grant funding follows a different path to final 

recipients depending on the program’s administrative process. For 

example, grant awards made under SHSP and UASI go through three 

steps before the money reaches the final grant recipient. First, DHS 

awards SHSP and UASI funds through FEMA to a designated SAA—

typically a state homeland security or emergency management office. The

SAA then passes funds to subrecipients, such as county or city 

governments or designated urban areas. These subrecipients/local 

governments may then further distribute SHSP and UASI funds to other 

entities, including individual law enforcement agencies. It is these other 

entities that will ultimately spend the grant funds to implement security 

projects. Because state governments are required by the Implementing 

Recommendations of the 9/11 Commission Act of 2007 (9/11

Commission Act) to have a role in the application process and distribution 

of SHSP and UASI funding,22

In delegating significant grants administration duties to the SAA for the 

larger SHSP and UASI programs, FEMA officials recognized the trade-off 

between decreased visibility over grant funding, subrecipients, and 

specific project-level data in exchange for their reduced administrative 

burden. For these two programs, the SAA, as the official grant recipient, 

assumes responsibility for holding subrecipient entities accountable for 

their use of funding, including ensuring that recipients use grant funds to 

pay costs that are allowable (e.g., reasonable and necessary for proper 

performance of the award).

and because of the thousands of individual 

projects that comprise these programs, FEMA relies on the SAAs to 

administer the awards to smaller entities.

23

 

22 6 U.S.C. §§ 604, 605.

However, according to FEMA officials, 

states’ capacities to effectively administer and coordinate their grants vary 

considerably.

23 Among other requirements, grant funds may only be used for allowable costs. 

Allowable costs are those that, among other things, are reasonable and necessary for 

proper and efficient performance and administration of federal awards, and a cost is 

reasonable if, in its nature and amount, it does not exceed that which would be incurred by 

a prudent person under the circumstances prevailing at the time the decision was made to 

incur the cost. See 2 C.F.R. pt. 225. In this report, potential “overlap” and “duplication” 

generally refer to two or more SHSP, UASI, PSGP, or TSGP projects that address the 

same preparedness need and could be redundant or unnecessary if not coordinated. 
 

Page 18 GAO-12-303 Preparedness Grant Programs

In contrast, FEMA receives far fewer applications for TSGP and PSGP 

funds and awards grant funding more directly to the final grant recipients, 

with one and two steps, respectively, rather than three steps. As a result, 

FEMA has a greater ability to track grant funding, specific funding 

recipients, and funding purposes for these two smaller grant programs. 

Beginning in fiscal year 2009, appropriations acts required FEMA to 

award TSGP funds directly to transit authorities instead of through 

SAAs.24

Differences in administrative processes among each of the four grant 

programs also impact the extent to which federal, state and local entities 

share responsibility for prioritizing and selecting the individual 

preparedness projects that will ultimately receive funding. Due to its 

greater involvement with the PSGP and TSGP project selection at the 

local level, DHS generally has more information on specific PSGP and 

TSGP projects than SHSP and UASI projects. For example, DHS 

components—USCG and TSA—are involved with the PSGP and TSGP 

selection process, which provides DHS with additional information over 

the use of grant funds. For instance, TSGP projects from fiscal years 

2007 through 2010 were selected by regional working groups.

Per FEMA policy, the agency distributes PSGP funds to local 

FAs who then distribute grants to local entities within the port area, but 

FEMA is directly involved in this process. Due to the legal and 

departmental policies that establish a more direct award process for 

PSGP and TSGP, along with the smaller scope of those programs, FEMA 

has more information and is better able to track these grants through to 

the end user of the grant monies.

25

 

24 Pub. L. No. 110-329, 122 Stat. 3574, 3671 (2008).

The 

regional groups based their project selection on Regional Transit Security 

Strategies that each transit region had developed. For this grant program 

TSA had better information about the funding as well as influence over 

the project selection because TSA set the parameters for and approved 

the transit security strategies, and final project selection was based on 

TSA approval.

25 The regional working groups choose projects for the highest risk Tier 1 regions. The 

remaining transit regions’—Tier 2 regions—projects are fully competitive.

Differences in Administrative 

Processes Also Affect the Level 

of Federal Involvement in 

Award Decisions 
 

Page 19 GAO-12-303 Preparedness Grant Programs

Similarly, the USCG, and in particular the Captain of the Port,26 exerts 

influence over the PSGP project selection process, given the agency’s 

maritime security expertise and role in the PSGP award process. PSGP 

project applications also undergo a second national review facilitated by 

FEMA that includes the USCG, the Department of Transportation’s 

Maritime Administration,27 and other stakeholders. Along with federal 

stakeholders, numerous local stakeholders are involved with the PSGP 

selection process and in many locations are required to base their grant 

award decisions largely on FEMA-required port security mitigation 

strategies. These strategies also require FEMA approval before PSGP 

grants can be awarded to port areas.28

In contrast, local officials select SHSP and UASI projects with less federal 

involvement, although the projects must comport with various program 

rules, such as those related to allowable activities or costs, and address 

any funding priorities stipulated in the grant guidance. For SHSP, FEMA 

awards funds to states for certain broad purposes, such as interoperable 

communications, but federal law and DHS policies allow states to 

distribute these funds to individual projects or jurisdictions using different 

mechanisms, given different local conditions and needs. One state may 

choose to use a consensus-based approach to disburse the funds to 

counties, for example, while another may distribute funding equally to all 

of its jurisdictions. For example, in Washington State, SHSP grant 

applications are reviewed by four distinct entities––the state’s homeland 

security committee, the all-hazards statewide emergency council, the 

state’s domestic security executive group, and the governor’s office––

Thus, for these projects, FEMA is 

more involved and has greater information on which to base award 

decisions.

 

26 The Captain of the Port (COTP) is a Coast Guard officer responsible for enforcing port 

safety, security and marine environmental regulations within a given port area. The COTP 

also leads the local field-level review of PSGP projects, although the COTP’s actual level 

of involvement in the selection process may vary from port to port depending on local 

conditions. 

27 Programs of the Maritime Administration promote the development and maintenance of 

an adequate, well-balanced United States merchant marine capable of service as a naval 

and military auxiliary in time of war or national emergency. The Maritime Administration 

also seeks to ensure that the United States maintains adequate shipbuilding and repair 

services, efficient ports, effective intermodal water and land transportation systems, and 

reserve shipping capacity for use in time of national emergency.

28 For more detailed information on PSGP program requirements and processes see 

GAO-12-47. 
 

Page 20 GAO-12-303 Preparedness Grant Programs

prior to the state making risk-informed allocation decisions. In contrast, 

one regional government council in Texas allocated SHSP funds equally 

to all eligible jurisdictions within its region regardless of their risk level.

For UASI grants, FEMA requires each region to create its own UAWG, 

but does not participate in these groups.29 The UAWGs convene to select 

individual projects for UASI funding based on the FEMA-identified grant 

priorities for that grant year that are also consistent with the area’s grant 

application and state and urban area strategic plans. For example, in 

2009 the New York City UAWG identified protecting critical infrastructure 

and key resources as one of eight goals in its homeland security strategic 

plan, received UASI funding for this purpose, and selected and allocated 

funds to specific projects in the urban area related to this goal. FEMA 

approves all applications and strategic plans, which give the agency a 

broad idea of what grant applicants intend to accomplish at the state and 

local level. However, selection of specific projects occurs through locallevel working groups. As a result of the differing levels of DHS 

involvement in project selection for each of the grants programs, DHS 

generally has more project information for specific PSGP and TSGP 

projects than SHSP and UASI projects.

When making preparedness grant awards, FEMA decisions are based on 

less specific project-level information for SHSP and UASI programs than 

for PSGP and TSGP, which puts the agency at greater risk of funding 

unnecessarily duplicative projects across all programs. In our prior work 

on overlap and duplication, we identified challenges agencies face in 

collecting and analyzing the information needed to determine whether 

unnecessary duplication is occurring. For example, we identified 44 

federal employment and training programs that overlap with at least 1 

other program in that they provide at least one similar service to a similar 

population. However, our review of 3 of the largest 44 programs showed 

 

29 FEMA directs each UASI region to create its own regional working group, which 

FEMA’s grant guidance refers to as an urban area working group. Grant guidance 

requires the working group to determine representation from the jurisdictions and 

response disciplines that comprise the UASI region. Beginning in fiscal year 2008, UASI 

grant guidance recommended to urban areas that they consider for UASI working group 

membership those counties within which the cities included in the UASI region reside, 

contiguous jurisdictions, and jurisdictions within the region’s Metropolitan Statistical Area 

(MSA). An MSA is a geographic entity defined by the Office of Management and Budget 

that contains an urban core population of 50,000 or more.

FEMA Makes Award 

Decisions Using Varying 

Levels of Information 

Which Contributes to the 

Risk of Funding 

Duplicative Projects
 

Page 21 GAO-12-303 Preparedness Grant Programs

that the extent to which individuals actually receive the same services 

from these programs is unknown due to program data limitations.30 We 

found similar data limitations in this review as FEMA bases its awards for 

SHSP, UASI, PSGP, and TSGP in part upon IJs which contain limited 

information. For the SHSP and UASI programs, states and eligible urban 

areas submit IJs for each program with up to 15 distinct investment 

descriptions that contain general proposals to address capability gaps in 

wide-ranging areas such as interoperability communications or critical 

infrastructure protection. Each IJ may encompass multiple specific 

projects to different jurisdictions or entities, but project-level information, 

such as a detailed list of subrecipients or equipment costs, is not required 

by FEMA. According to FEMA, data system limitations, the high volume of 

individual SHSP and UASI projects, and the desire to give states and 

urban areas increased flexibility to add or modify specific projects after 

the award period contributed to less detailed IJs.31

In contrast, FEMA makes PSGP and TSGP award decisions based on 

federal reviews of IJs that contain information about specific projects, 

providing FEMA officials with more detailed knowledge of what is being 

requested and what is being funded by these programs. Furthermore, 

before awards are made, FEMA directs PSGP and TSGP applicants to 

submit detailed budget summaries, but does not call for such information 

from SHSP and UASI applicants. The 9/11 Commission Act establishes 

minimum application requirements for SHSP and UASI, such as a 

description of how funds will be allocated, but the act does not call for 

specific project data.32

 

30

For example, with SHSP, the statute requires 

states to include in their grant applications the purpose for the grant 

funds, a description of how they plan to allocate funds to local 

governments and Indian tribes, and a budget showing how they intend to 

expend the funds. FEMA officials stated that the SHSP and UASI IJ 

GAO-11-318SP. 

31 Regarding FEMA’s data limitations, FEMA is currently using a grants management 

system “on-loan” from the Department of Justice. This involves a number of disparate 

systems and spreadsheets. FEMA is in the process of transitioning to a new system called 

ND (non disaster) Grants. ND Grants is slated to be a one-stop shop for programmatic 

and financial information on DHS grants, as well as monitoring and payment. ND Grants 

was introduced in 2011 but is still several years away from having full functionality, 

according to FEMA. 

32 6 U.S.C. §§ 604, 605.
 

Page 22 GAO-12-303 Preparedness Grant Programs

format meet these statutory requirements, albeit at “a high summary 

level.” 

To improve the level of information that FEMA has available for making 

grant award decisions, FEMA is considering collecting more detailed 

information on proposed grant projects. In May 2011, a FEMA report 

based on the work of a Reporting Requirements Working Group 

recommended collecting additional project information at the application 

stage. 33 Specifically, the FEMA report recommended that the agency

modify the IJ format for SHSP and UASI applications to include a detailed 

project list. This project list would contain information that is currently 

collected through the BSIR later in the grant cycle after FEMA makes 

grant awards.34

To make this determination, we reviewed the type of information that 

FEMA would have available at the application stage if it implemented the 

report recommendation. Specifically, we reviewed IJ and BSIR 

information for the 1,957 grant projects awarded through the four grant 

programs to five urban areas––Houston, Jersey City/Newark, New York

City, San Francisco, and Seattle––for fiscal years 2008 through 2010. 

Our analysis determined that 140 of the projects, or 9.2 percent of the 

overall funding associated with these projects––about $183 million––

lacked sufficient detail to determine whether these projects were 

unnecessarily duplicative or had involved coordination during the state’s 

If this recommendation is implemented, the policy of 

collecting additional information at the application stage could be initiated 

in the fiscal year 2013 grant cycle, according to FEMA. Although 

collecting this additional information may be useful to FEMA, we 

determined that the level of information contained in the BSIR alone 

would not provide sufficient project information to identify and prevent 

potentially unnecessary duplication within or across grant programs.

 

33 FEMA, Redundancy Elimination and Enhanced Performance for Preparedness Grants 

Act: Initial Report to Congress (Washington, D.C.: May 23, 2011). In August 2009, FEMA 

established the Reporting Requirements Working Group to compile a list of select grant 

reporting activities, collect grant stakeholder feedback, and make recommendations on

future data collection policies. The May 2011 Initial Report to Congress is based on the 

Working Group’s research and outlines recommendations and implementation actions 

related to grant application criteria and data integration, among other things. 

34 BSIRs are submitted electronically by SAAs to FEMA for the life of the award to account 

for the use of grant funding. All funds provided to the SAA must be accounted for and 

linked to one or more projects in the BSIR.

FEMA Is Considering 

Additional Action and 

Taking Steps to Enhance 

Grant Information, but 

Further Efforts Are 

Needed to Avoid the Risk 

of Duplication
 

Page 23 GAO-12-303 Preparedness Grant Programs

planning or selection processes to prevent any unnecessary duplication. 

Table 3 further illustrates the challenge that FEMA would face in 

identifying potential duplication using the BSIR data for SHSP and UASI 

as recommended by the report.

35

Table 3: Description of Project Information to Which FEMA Has Access for Four Projects in One Jurisdiction

For example, table 3 contains SHSP, 

UASI, and PSGP project information from a single jurisdiction in one of 

the five urban areas we reviewed and shows the level of detail that FEMA

would have available to compare projects. The overlap in the descriptions 

of the project types and titles suggest that duplication could be occurring 

among three of the four grant programs, and warranted further analysis.

Grant Year Project type Project title Recipient Description

UASI 2009 Critical Infrastructure 

Protection

Public Safety Video 

Initiative - assess 

vulnerability of and/or 

harden/protect critical 

infrastructure and key 

assets

Urban Area Working 

Group

Beginning with the 2006 UASI 

Grant period, the Citya

SHSP 

began the 

development of a public safety 

video system to improve situational 

awareness of public venues, critical 

assets, transportation and 

commerce corridors, and public 

safety areas of interest.

2009 Critical Infrastructure 

Protection

Assess vulnerability of 

and/or harden/protect 

critical infrastructure and 

key assets

City/County 

Governmental 

Organization

This will support the expansion of 

the Public Safety Video Program 

that is currently under development.

SHSP 2009 Critical Infrastructure 

Protection

Assess vulnerability of 

and/or harden/protect 

critical infrastructure and 

key assets

City/County 

Governmental 

Organization 

This project will assist the County 

Sheriff’s Office in achieving the goal 

of reducing vulnerability of a Critical 

Infrastructure/Key Resource 

adjacent to a specific critical 

waterway.

PSGP 2009 Maritime Domain 

Awareness/Improvised 

Explosive Device

Prevention, Protection, 

Response, and Recovery 

Capabilities

CCTV Surveillance 

Cameras Replacement 

Program

b

Port Authority

c

Many of the CCTV surveillance 

cameras that have been installed at 

the Port Authority’s facilities are at 

or near the end of their useful life. 

This program will initiate the 

systematic replacement of these 

CCTV cameras.

Source: FEMA BSIR for UASI and SHSP; FEMA IJ for PSGP.

 

35 Port and transit projects are not included in the BSIR, thus information was obtained 

from spreadsheets which contain IJ data. According to a FEMA section chief, the BSIR 

system was designed for state-level reporting as opposed to reporting from the variety of 

different subrecipients that receive PSGP and TSGP funds more directly. TSGP projects 

were listed in the BSIR prior to fiscal year 2009 when they were administered by state 

SAAs. 
 

Page 24 GAO-12-303 Preparedness Grant Programs

a Identifying information was removed.

b

PSGP project types are not directly comparable to BSIR project type categories.

c 

After identifying the projects that appeared to be potentially duplicative, 

we contacted the SAA and FA for this state, and officials provided us with 

extended narratives, coordination details, and subrecipient lists. It was not 

until we reviewed this additional, more detailed information that we could 

ascertain that these four projects were not duplicative, but rather were 

part of a larger, coordinated public safety interoperability and video 

initiative taking place in the region.

“CCTV” refers to Closed Circuit Television.

Table 4 below contains a second example of project data associated with 

BSIR and IJ information from a single jurisdiction in one of the five urban 

areas we reviewed. Again, we identified the potential for duplication 

because of the similarities in funded projects for both the SHSP and 

TSGP. Both of the projects identified below are related to the purchase of 

chemical, biological, radiological, and nuclear detection equipment 

(CBRNE). However, upon examining additional state-provided information 

and the TSGP IJ, we had sufficient information to determine that these 

projects were distinct and involved separate equipment. However, as with

the previous example in table 3, FEMA would not be able to make these 

determinations using only BSIR data.

Table 4: Description of Project Information to Which FEMA Has Access—Example #2

Grant Year Project type Project title Recipient Description

SHSP 2009 Enhance capabilities to 

respond to all-hazards 

events

Project A – CBRNE Support City/County 

Governmental 

Organization 

Purchase of equipment to support 

response capabilities for CBRNE 

events.

TSGP 2009 Equipment Install CBRNE in Subway a Transit Agency Install CBRNE in subway.

Source: FEMA BSIR for SHSP; FEMA IJ for TSGP.

a

Based on our analysis using BSIR and IJ project data, we were able to 

ascertain that over 90 percent of the projects we reviewed had sufficient 

detail to determine that the projects (1) were substantively different and 

not likely duplicative, or (2) involved coordination to prevent any 

unnecessary duplication. Furthermore, our subsequent analysis using 

additional information from state and local grant recipients indicated that 

none of these projects were duplicative. Nonetheless, we believe that 

more detailed project information could be of value to FEMA in its grant 

review process since, as demonstrated above, the information currently 

TSGP project types are not directly comparable to BSIR project type categories.
 

Page 25 GAO-12-303 Preparedness Grant Programs

being considered does not always allow for the necessary differentiation 

between projects funded by the four grant programs. Moreover, FEMA––

through its own internal analysis––and the OIG have both separately 

concluded in recent years that FEMA should use more specific projectlevel data in making grant award decisions, especially for SHSP and 

UASI, in order to identify and mitigate potential duplication. Specifically, in 

a March 2010 report, the OIG noted that the level of detail in IJs and in 

other grant program applications was not sufficient for FEMA to identify 

duplication and redundancy.36

FEMA has acknowledged the agency’s difficulties in effectively using

grants data and is taking steps to improve its data collection and 

utilization through resolving staffing shortages by filling key grants 

management personnel vacancies, and taking steps to implement a new 

data management system. As part of this effort, FEMA introduced a new 

non disaster grant management system (ND Grants) for the fiscal year 

2011 grant cycle, and the system is scheduled for completion by fiscal 

year 2014. Agency officials stated that this system, once completed, will 

help FEMA to manage all of its preparedness grants, and has an explicit 

goal of enhancing project-level data collection. In addition, the ND Grants 

system is anticipated to consolidate data from multiple systems and 

facilitate greater utilization and sharing of information.

In its written comments to the OIG, the 

DHS Office of Infrastructure Protection concurred with this assessment, 

noting that a SHSP IJ “was little more than a checklist of previous funding 

with a brief strategy narrative.” Further, Standards for Internal Control in 

the Federal Government state that program managers need operational 

and financial data to determine whether they are meeting their goals for 

accountability for effective and efficient use of resources.

37

 

36 DHS, Efficacy of DHS Grant Programs, OIG-10-69 (Washington, D.C.: Mar. 22, 2010).

However, 

according to FEMA documentation, FEMA has not yet determined all of 

its specific data needs for ND Grants. As FEMA continues to develop the 

ND Grants system it will be important that it collects the level of data 

needed to compare projects across grant programs to limit the risk of 

funding duplicative projects.

37 This system will replace the 13 legacy grant data systems and other processes that 

FEMA inherited from agencies that previously administered homeland security 

preparedness grants, such as the Department of Justice.
 

Page 26 GAO-12-303 Preparedness Grant Programs

We believe that the recommendation of the FEMA report to better use

more specific project-level data through the BSIR,38 for the SHSP and 

UASI programs, is a step in the right direction, although our analysis 

demonstrated BSIR data alone do not include enough detail needed to 

identify potential duplication. The Director of GPD’s Preparedness Grants 

Division reported in September 2011 that the report recommendations 

were still under consideration and thus FEMA had not yet determined the 

specifics of future data requirements. Thus, the agency’s goal to improve 

data collection by collecting project-level information through its ND 

Grants system is a worthwhile action. This effort could provide the level of 

detail that FEMA needs to identify possible unnecessary duplication 

within and across all four grant programs. We recognize that collecting 

more detailed project information through ND Grants could involve 

additional costs. However, collecting information with this level of detail 

could help FEMA better position itself to assess applications and ensure 

that it is using its resources effectively.

FEMA, as well as state and local stakeholders, have taken steps to 

improve coordination in selecting and administering the four grant 

programs, but additional FEMA action could help reduce the risk of 

duplication among these programs. Federal efforts to improve 

coordination range from improving visibility across grants to gathering 

additional information about grant spending. The Director of GPD’s 

Preparedness Grants Division discussed multiple projects that FEMA had 

initiated to potentially improve coordination in the grants management 

area. He told us that at the federal level, there is an effort within FEMA to 

increase planning and training exercises in order to increase its ability to 

track what projects are being funding by which grants. He added that this 

FEMA-led initiative is currently assessing public information on grants to 

reduce the risk of duplication. FEMA has a variety of reporting tools and

guidelines that FEMA personnel have recently been working with to 

improve coordination and linkages between programs. For example, 

FEMA has started using Threat and Hazard Identification Risk 

Assessments (THIRA) as a way to increase FEMA’s ability to link 

 

38 As noted above, FEMA would collect more specific BSIR data at the application stage 

of the grants cycle instead of higher level “investment” descriptions. This more specific 

project-level data could include more detailed data elements related to funding; target 

capabilities addressed; and proposed solution categories, such as planning, organization, 

training, exercises, equipment, and management and administration. 

Enhanced Federal 

Coordination Could 

Help Reduce the Risk 

of Duplication
 

Page 27 GAO-12-303 Preparedness Grant Programs

spending at the local and federal levels.39

Officials in four of the five states we visited had taken steps to improve 

coordination across grant programs. State steps to improve coordination 

range from tracking equipment purchases to enhancing administrative 

tools. For example, in Texas, jurisdictions must register all deployable 

equipment purchased through a homeland security grant and costing 

more than $5,000 on a statewide registry known as the Texas Regional 

Response Network. The purpose of the network is to raise awareness 

about the assets that neighboring jurisdictions might have available for 

use by another jurisdiction during an emergency. According to a Texas 

official familiar with the initiative, the registry was established with the 

recognition that sharing deployable equipment would be cost effective 

since it would be difficult for every jurisdiction to maintain every piece of 

equipment that might be needed in an emergency. In New Jersey, the 

SAA’s office developed a Grants Tracking System, a web-enabled 

application to capture and track each subgrantee’s state-approved 

Homeland Security Grant Program–funded projects which includes SHSP 

and UASI. The Grant Tracking System is the state’s primary oversight 

mechanism to monitor the progress of each county, city, and state agency 

toward completing or procuring their budgeted projects or equipment. The 

system permits the SAA to review every program that receives funding, 

which allows for increased coordination across grants and efficiencies in 

procurement and helps alleviate the risk of funding duplicative grants. The 

The Director of GPD’s 

Preparedness Grants Division said that the guidance for reporting this 

linkage to the local level is still being discussed, with NPD taking the lead, 

as it currently is only required at the state level.

 

39 Threat and Hazard Identification Risk Assessments (THIRA) establish a foundation to 

justify and guide preparedness activities and investments. THIRAs should include the 

range of threats and hazards faced by an applicant. The assessment should be based on 

analysis of the relative consequences of the various threats and hazards with 

consideration of empirical data to the maximum degree possible. An effective THIRA will 

allow the applicant to compare and prioritize risks, even if they are dissimilar, by 

identifying possible threats and hazards faced with respective probability estimates of their 

occurrence. THIRA findings should be incorporated into each applicant‘s preparedness 

strategy, planning, Investment Justification, and assessment documentation and address

capability gaps identified during the THIRA process. 
 

Page 28 GAO-12-303 Preparedness Grant Programs

system was included as a best practice in the OIG’s 2011 audit of New 

Jersey’s grant programs.40

Officials in all five localities we visited commented that they rely on 

informal structures to coordinate or identify potential unnecessary 

duplication––such as having the USCG Captain of the Port involved in a 

UAWG committee. Additionally, officials from three locations we visited 

also noted having tried to set up more formal coordination structures. For 

example, the UAWG in one Texas locality set up a peer-to-peer network 

with other UASI regions around the state to exchange information. A 

county official from a UAWG in Washington State reported that they have 

set up monthly small group meetings with officials from surrounding 

counties who deal with SHSP and UASI in an effort to exchange 

information and improve coordination.

While FEMA, states, and local government have taken steps to improve 

coordination, our review of FEMA’s internal coordination showed that the 

agency lacks a process to coordinate reviews across the four grant 

programs. GPD has divided the administration of the grant programs into 

two separate branches: UASI and SHSP are administered by the

Homeland Security Grant Program branch while PSGP and TSGP are 

administered by the Transportation Infrastructure Security branch. The 

result of this structure is that grant applications are reviewed separately 

by program but are not compared across each other to determine where 

possible unnecessary duplication may occur. As we noted earlier, each 

grant program we reviewed has similar goals, allowable costs, and 

geographic proximity. Due to this structure, these four programs share 

applicants as state and local entities seek to maximize grant dollars for 

their projects. However, since the review process for grant applications 

falls within each separate branch and grant program––and since there is 

no process in place to ensure that grant information is exchanged in the 

review process—FEMA cannot identify whether grant monies are being 

used for any unnecessary duplicative purposes. Similarly, in 2010, the 

OIG noted that FEMA does not have an overarching policy to coordinate 

 

40 DHS-OIG, The State of New Jersey’s Management of State Homeland Security 

Program and Urban Areas Security Initiative Grants Awarded During Fiscal Years 2007 

through 2009, OIG-11-112 (Sept. 26, 2011). 
 

Page 29 GAO-12-303 Preparedness Grant Programs

grant programs and outline roles and responsibilities for coordinating 

applications across grant programs.41

Standards for Internal Control in the Federal Government call for 

agencies to have the information necessary to achieve their objectives 

and determine whether they are meeting their agencies’ strategic goals. 

FEMA’s strategic goals for fiscal years 2009 through 2011 included 

teaming with internal and external stakeholders to build partnerships and 

increase communication, and to streamline, standardize, and document 

key processes to promote collaboration and consistency across regions 

and programs. Because the four grant programs are being reviewed by 

two separate divisions, yet have similar allowable costs, coordinating the 

review of grant projects internally could allow FEMA to have more 

complete information about grant applications across the four different 

programs. This is necessary to identify overlap and mitigate the risk of 

duplication across grant applications. One of FEMA’s section chiefs noted 

that the primary reasons for the current lack of coordination across 

programs are the sheer volume of grant applications that need to be 

reviewed and FEMA’s lack of resources to coordinate the grant review 

process. She added that FEMA reminds grantees not to duplicate grant 

projects; however, due to volume and the number of activities associated 

with grant application reviews, FEMA lacks the capabilities to cross-check 

for unnecessary duplication. We recognize the challenges associated with 

reviewing a large volume of grant applications, but to help reduce the risk 

of funding duplicative projects, FEMA could benefit from exploring 

opportunities to enhance its coordination of project reviews while also 

taking into account the large volume of grant applications it must process.

 

41 OIG-10-69.
 

Page 30 GAO-12-303 Preparedness Grant Programs

DHS implemented some performance measures for SHSP and UASI in 

the fiscal year 2011 grant guidance, but has not yet implemented 

comparable measures for PSGP and TSGP. Moreover, the type of 

measures DHS published in the SHSP and UASI guidance do not 

contribute to DHS’s ability to assess the effectiveness of these grant 

programs, but instead provide DHS with information to help it measure 

completion of tasks or activities. DHS has efforts underway to develop 

additional measures to help it assess grant program effectiveness; 

however, until these measures are implemented, it will be difficult for DHS 

to determine the effectiveness of grant-funded projects, which totaled 

$20.3 billion from fiscal years 2002 through 2011.

As a part of its risk management framework, the National Infrastructure 

Protection Plan calls for agencies to measure progress in security 

improvements against sector goals using both output measures, which 

track the progression of tasks associated with a program or activity, and 

outcome measures, which help an agency evaluate the extent to which a 

program achieves sector goals and objectives—that is, their 

effectiveness. The measures that DHS implemented for SHSP and UASI 

through the fiscal year 2011 guidance are output measures. For example, 

some of the output measures implemented for SHSP and UASI include: 

(1) the percentage of fusion center42

 

42 Since 2001, all 50 states and some local governments have established fusion centers 

to address gaps in terrorism-related information sharing that the federal government 

cannot address alone and to provide a mechanism for information sharing within the state. 

For more information on fusion centers, see GAO, Information Sharing: Federal Agencies 

Are Helping Fusion Centers Build and Sustain Capabilities and Protect Privacy, but Could 

Measure Results, 

analysts that require secret

clearances that have them (or have submitted requests for them); (2) the 

GAO-10-972 (Washington, D.C.: Sept. 29, 2010).

Some Performance 

Measures Exist for 

Individual Grant 

Programs, but Work 

Remains to Assess 

Grant Effectiveness

DHS Has Some 

Performance Measures, 

but Until Additional 

Measures Are 

Implemented It Cannot 

Assess Grant Effectiveness
 

Page 31 GAO-12-303 Preparedness Grant Programs

percentage of SHSP and UASI funded personnel who are engaged in the 

Nationwide Suspicious Activity Reporting Initiative43

Implementing output measures for the SHSP and UASI grant programs 

provides value and is a step in the right direction because they allow 

FEMA to track grant-funded activities. However, outcome measures 

would be more useful to FEMA in determining the effectiveness of these 

grant programs. As of February 2012, DHS had not implemented 

outcome measures for any of the four grant programs in our review. Our 

previous work has underscored how the absence of outcome measures 

has negatively impacted DHS’s ability to assess the achievement of 

desired program outcomes to further homeland security preparedness 

goals.

and have completed 

the training; and, (3) the approval of a State Hazard Mitigation Plan that 

includes a THIRA that has been coordinated with UASI(s) located in the 

state.

44 Additionally, the National Infrastructure Protection Plan instructs 

agencies to track progress towards strategic goals and objectives by 

measuring results or outcomes, and it states that aligning outcome 

measures to goals and objectives is the key to performance 

management. As shown in table 5 below, FEMA had efforts under way in 

2010 and 2011 to develop outcome measures for the four grant programs 

in our review.

 

43 The federal government is working with state, local, and tribal government agencies to 

implement the Nationwide Suspicious Activity Reporting initiative. This effort is intended to 

establish a nationwide capability to gather and share information about suspicious 

incidents to enable rapid identification and mitigation of potential terrorist threats. 

44 GAO, DHS Improved its Risk-Based Grant Programs' Allocation and Management 

Methods, But Measuring Programs' Impact on National Capabilities Remains a Challenge, 

GAO-08-488T (Washington D.C.: Mar. 11, 2008).
 

Page 32 GAO-12-303 Preparedness Grant Programs

Table 5: Selected DHS Grant Program Initiatives to Develop Outcome-Based Performance Measures 

Grant program 

affected Initiative name Initiative description Expected result Status 

 SHSP National Academy of 

Public Administration 

(NAPA) Study

The Redundancy Elimination 

and Enhanced Performance for 

Preparedness Grants Actb

Three to seven 

proposed measures and 

an implementation 

directed the Administrator of roadmap.

FEMA to enter into a contract 

with NAPA to assist the 

administrator in studying, 

developing, and implementing 

performance measures to 

assess the effectiveness of 

SHSP and UASI, among other 

things.

NAPA began work on this 

project in January 2011, with 

performance measure 

implementation scheduled for 

December 2011. In October 

2011, NAPA provided FEMA 

with a copy of the final report, 

according to FEMA officials. 

As of December 2011, FEMA 

officials stated that the results 

of the NAPA study are under 

review within FEMA and no 

measures have been 

implemented. 

 UASI 

PSGP FEMA Task Force on 

Performance 

Measures

a In January 2010, GPD formed a 

task force to develop measures 

to assess the effectiveness of

PSGP and TSGP. In December 

2010, this effort was transferred 

to NPD. 

Development of 

program-specific 

performance measures 

for PSGP and TSGP.

As of December 2011, the 

Director of the National 

Preparedness Assessment 

Division (NPAD) within NPD 

told us that NPD had 

developed draft performance 

measures for the PSGP and 

TSGP and that those 

measures were undergoing 

review within FEMA. As a 

result, the official told us that it 

is unclear if FEMA would 

include these measures in its 

fiscal year 2012 grant 

guidance.

TSGP

c

Source: GAO analysis of FEMA information.

a For more information about FEMA’s efforts to measure the effectiveness of the PSGP, see 

GAO-12-47. 

b Pub. L. No. 111-271, § 2(a), 124 Stat. 2852 (2010) (codified at 6 U.S.C. § 613(d)).

c

FEMA has taken steps to develop outcome-based measures through 

these initiatives; however, as of February 2012, FEMA had not completed 

its efforts. According to FEMA officials, DHS leadership has identified 

performance measurement as a high priority issue, and is developing a 

more quantitative approach for using grant expenditure data to monitor 

program effectiveness.

On February 17, 2012, FEMA released the fiscal year 2012 Funding Opportunity Announcement for 

the PSGP and TSGP. However, this guidance did not contain performance measures.

45

 

45

Further, senior FEMA officials have noted 

GAO-08-488T. 
 

Page 33 GAO-12-303 Preparedness Grant Programs

challenges to measuring preparedness. For example, they have noted 

that SHSP and UASI fund a wide range of different preparedness 

activities, which makes it difficult to devise applicable measures. Thus, if 

measures are too broad they are meaningless and if too narrow they may 

not adequately capture the effectiveness of a range of activities. Senior 

FEMA officials noted another challenge in that grant program goals are 

purposefully broad to accommodate a broad constituency. For example, 

SHSP is administered in all states. However, the security conditions and 

preparedness needs of a state such as North Dakota are very different 

from those of New York, yet the grant goals, guidance, and measures 

would be the same for both locales.

FEMA provided us with its Performance Measure Implementation Plan,

46

an internal plan that FEMA uses for developing measures for all 

preparedness grants; however, this plan provides insufficient detail to 

guide these efforts. This plan identifies the output measures that were 

included in the fiscal year 2011 guidance for SHSP and UASI. Further the 

plan notes that NPD’s National Preparedness Assessment Division 

(NPAD) has developed new performance measures that seek to better 

capture the outcomes and overall effectiveness of preparedness grants, 

rather than the outputs captured by current measures; however, it does 

not specify what outcome measures were developed.47

 

46 According to FEMA, the Performance Measure Implementation Plan is an internal plan 

that provides the agency’s general approach to performance measurement as well as a 

key list of milestones for implementing the agency’s new performance measures and 

refining its existing measures related to preparedness grants.

Instead, the 

implementation plan provides a general approach to performance 

measurement as well as a list of key milestones to implement the new

performance measures and refine existing measures. In addition, the 

implementation plan notes that it is NPAD’s goal to develop one or two 

measures per grant program that are both output and outcome based. 

However, the associated activities and milestones listed in the plan do not 

reference specific grant programs or project details. As a result, it is 

unclear what grants, or what measures, are being addressed for each 

milestone. According to FEMA’s current implementation plan, all 

performance measures should have been implemented in December 

2011; however, FEMA officials reported in December 2011 that outcome 

measures for the four programs had not yet been implemented.

47 The National Preparedness Assessment Division (NPAD) is responsible for evaluation 

and assessment of preparedness grant programs, among other things. 
 

Page 34 GAO-12-303 Preparedness Grant Programs

According to the Project Management Institute, best practices for project 

management call for a variety of inputs and outputs when developing a 

project schedule, including the basis for date estimates, a breakdown of 

the work to be conducted for each program, resource capabilities and 

availability, and external and internal dependencies. FEMA’s 

implementation plan does not contain this level of detail and as a result, it 

remains unclear what measures will be implemented for each grant 

program and when this implementation will occur. Establishing 

performance measures for these four programs is important given their 

relatively large size and scope. We recognize the difficulties inherent in 

developing outcome-based performance measures to assess the 

effectiveness of these grant programs. However, DHS should continue to 

work towards the development of these measures to improve its ability to 

assess the effectiveness of these grant programs. Until DHS does so it 

will be difficult for it to determine the extent to which its investment 

through these programs––$20.3 billion from 2002 through 2011—is 

effectively enhancing homeland security. A revised implementation plan 

that includes more specific project schedule information and accurate 

timelines for implementation could help guide efforts and keep the 

development of these measures on track for successful and timely 

implementation.

Apart from developing performance measures for each grant program, 

DHS also has several initiatives under way to measure the collective 

effectiveness of its grant programs in achieving shared program goals, as 

shown in table 6 below.

DHS Has Initiatives under 

Way to Evaluate Overall 

Effectiveness across Grant 

Programs, but Has Not 

Completed These Efforts
 

Page 35 GAO-12-303 Preparedness Grant Programs

Table 6: FEMA Initiatives to Evaluate Overall Effectiveness across Grant Programs

Action/program

Grants 

affected (in 

this review) Description Expected result Status 

Revising 

Preparedness 

Guidance 

SHSP, UASI,

PSGP, TSGP

Presidential Policy 

Directive-8 (PPD-8) 

replaces HSPD-8 and 

requires that a new 

national preparedness 

system include a 

comprehensive system to 

assess national 

preparedness.

DHS is responsible for 

measuring the readiness of 

current national capabilities with 

clear, objective and quantifiable 

performance measures. The 

structure of this measurement 

system will drive the 

development of any future 

performance measures. 

In November 2011, FEMA 

released the National 

Preparedness System 

description, which is designed to 

lay the groundwork for 

strengthening the nation’s 

resilience against all threats and 

hazards. The system description 

is the second deliverable called 

for by PPD-8. According to a 

DHS publication, further details 

on how the National 

Preparedness System will be 

implemented will be provided as 

the remaining PPD-8 

deliverables are developed.

Implementing the 

ND Grants System 

SHSP, UASI,

PSGP, TSGP

ND Grants is a web-based 

system intended to 

provide FEMA and its 

stakeholders with a 

system that supports the 

grants management 

lifecycle and consolidates 

grant information.

According to FEMA, the ND 

Grants system is intended to 

consolidate FEMA’s disparate 

data systems and improve the 

ability of FEMA grant managers 

to track grants through the 

review and approval process, a 

capability that will also assist 

with evaluating grant 

performance. 

In fiscal year 2011, FEMA 

implemented portions of the ND 

Grants system. At this time, ND 

Grants cannot collect or provide 

comprehensive information 

across grant programs. 

According to FEMA, the system 

is scheduled for completion in 

fiscal year 2014. 

Implementing Threat 

Hazard Identification 

Risk Assessment 

(THIRA)

SHSP, UASI THIRA requires 

jurisdictions to add a 

threat evaluation to the 

existing Hazard 

Identification Risk 

Assessment mitigation 

process.

The goal of THIRA is to create a 

standardized system that 

establishes baseline risks and 

capabilities at the local level and 

provides a justification for 

investments in preparedness. 

The THIRA was first called for 

as part of the fiscal year 2011 

Homeland Security Grant 

Program. 

Source: GAO analysis of FEMA information.

As shown above, FEMA’S efforts to measure the collective effectiveness 

of its grants programs are recent and ongoing and thus it is too soon to 

evaluate the extent to which these initiatives will provide FEMA with the 

information it needs to determine whether these grant programs are 

effectively improving the nation’s security. While each grant program 

strives to identify and mitigate security concerns within its specific 

authority, improving the nation’s overall preparedness is dependent upon 

collectively addressing capability and security gaps across all programs 

and authorities. Thus, it is important to evaluate effectiveness across the 

four grant programs to determine the extent to which the security of the 
 

Page 36 GAO-12-303 Preparedness Grant Programs

nation as a whole has improved and to better ensure the effective use of 

scarce resources.

From fiscal years 2002 through 2011, DHS has distributed about $20.3 

billion through four homeland security preparedness grants that 

specifically target state, urban, port, and transit security. We recognize 

that even when programs overlap, they may have meaningful differences 

in their eligibility criteria or objectives, or they may provide similar types of 

services in different ways. However, because the four DHS programs in 

our review have similar goals, fund similar types of projects, and are 

awarded in many of the same urban areas, it will be important for FEMA 

to take additional measures to help ensure that the risk of duplication is 

mitigated. FEMA has delegated significant administrative duties to the 

SAA for the larger SHSP and UASI programs, and FEMA officials 

recognize the trade-off between decreased visibility over these grants and 

the reduced administrative burden on FEMA. However, the limited 

project-level information on how funds are being used and the lack of 

coordinated reviews of grant applications across programs, increases the 

risk that FEMA could fund duplicative projects. Additional action could 

help mitigate this risk. For example, as FEMA develops the ND Grants 

system, it will be important for the agency to ensure that information 

collected for all grant programs provides enough detail to allow for project 

comparisons in order to identify any unnecessary duplication. In addition, 

while some steps have been taken at the federal, state, and local levels to 

improve coordination in administering the four grant programs, additional 

actions could also help reduce the risk of duplication. For example, 

without a process to coordinate reviews across the four grant programs, 

FEMA lacks the information necessary to identify whether grant monies 

are being used for duplicative purposes, especially since all four grant 

programs are being reviewed separately, yet have similar allowable costs. 

Thus, to reduce the risk of duplication, FEMA could benefit from exploring 

opportunities to enhance its coordination of project reviews across grant 

programs. Additionally, since DHS’s existing output-based performance 

measures for the SHSP and UASI programs do not provide DHS with the 

information it needs to assess grant effectiveness and FEMA has not yet 

implemented outcome-based performance measures for any of the four 

programs, it will be difficult for FEMA to fully assess the effectiveness of 

these grant programs. Because the project plan FEMA has in place to 

guide its efforts to develop measures does not provide adequate 

information to determine what measures will be implemented for each 

grant program and when this implementation will occur, FEMA does not 

Conclusions 
 

Page 37 GAO-12-303 Preparedness Grant Programs

have reasonable assurance that these measures will be implemented in a 

timely way to help assess the programs’ effectiveness.

We are making three recommendations for the four grant programs. Two 

actions are recommended to help reduce the risk of duplication by 

strengthening DHS’s administration and oversight of these programs, and 

one action is recommended to better assess the effectiveness of these 

programs.

To better identify and reduce the risk of duplication through improved data 

collection and coordination, we recommend that the FEMA Administrator:

• take steps, when developing ND Grants and responding to the May 

2011 FEMA report recommendations on data requirements, to ensure 

that FEMA collects project information with the level of detail needed 

to better position the agency to identify any potential unnecessary 

duplication within and across the four grant programs, weighing any 

additional costs of collecting these data; and

• explore opportunities to enhance FEMA’s internal coordination and 

administration of the programs in order to identify and mitigate the 

potential for any unnecessary duplication.

To better assess the effectiveness of these programs, we recommend 

that the FEMA Administrator:

• revise the agency’s Performance Measure Implementation Plan to 

include more specific project schedule information and accurate 

timelines in order to guide the timely completion of ongoing efforts to 

develop and implement outcome-based performance measures for 

the SHSP, UASI, PSGP, and TSGP grant programs.

We provided a draft of this report to DHS for comment. We received 

written comments on the draft report, which are reprinted in appendix II. 

DHS concurred with all three recommendations, and requested that the 

first two recommendations be considered resolved and closed. While we 

believe that DHS’s planned actions, if implemented, address the intent of 

each recommendation, it is too soon to close any recommendation as 

implemented. Specifically:

Recommendations for 

Executive Action

Agency Comments 

and Our Evaluation
 

Page 38 GAO-12-303 Preparedness Grant Programs

• DHS agreed with the recommendation that FEMA take steps to 

ensure that it collects sufficient project information to better identify 

any potential unnecessary duplication, and asked that, based on 

actions currently under way and other proposed changes, the 

recommendation be closed. DHS cited the elimination of seven 

programs in fiscal year 2012 and the proposed restructuring of most 

programs under a single National Preparedness Grant Program in 

fiscal year 2013 as steps to eliminate unnecessary duplication. DHS 

also cited modifying one reporting requirement in fiscal year 2012 to 

better capture program-specific performance measures. While we 

agree that program restructuring and the cited reporting requirement 

change could offer FEMA the opportunity to improve its grants data 

and thus its visibility across programs and projects, it is too soon to 

assess any positive impact, especially given that the outcome of the 

proposed fiscal year 2013 program restructuring is uncertain and is 

reliant on future congressional action. Furthermore, consolidating 

programs alone will not guarantee that the level of project-level detail 

collected by FEMA will be sufficient to identify unnecessary 

duplication of similar efforts in the same geographic areas. We will 

review the status of these efforts and additional supporting evidence 

in the future before closing this recommendation. 

• DHS agreed with the recommendation that FEMA explore 

opportunities to enhance internal coordination and administration of 

the programs to identify and mitigate the potential for any 

unnecessary duplication, and asked that, based on ongoing actions 

and plans, the recommendation be closed. For example, DHS stated 

that FEMA officials participate in an Intra-agency Grants Task Force 

to provide strategic links among FEMA grant programs, as well as a 

DHS-level task force to improve grants management across the 

department. DHS also stated that FEMA has formal memoranda of 

understanding with partner agencies/offices related to various grants 

administration roles and responsibilities, and continues to develop 

additional formal agreements. We view these as positive steps in 

coordinating grants administration within DHS and FEMA. However, it 

is not clear at this time that the various groups or formal agreements 

have specifically addressed preventing potential unnecessary 

duplication across programs or projects, or that this is a goal of the 

initiatives. We will review the status of these efforts and additional 

supporting evidence in the future before closing this recommendation.

• DHS agreed with the recommendation to revise the agency’s 

Performance Measure Implementation Plan and stated that new 
 

Page 39 GAO-12-303 Preparedness Grant Programs

performance measures and a plan for data collection are in draft form. 

DHS also stated it will provide an update to the plan when decisions 

are finalized, and that these decisions will be informed by the outcome 

of the agency’s proposed changes to the fiscal year 2013 grant 

programs. 

DHS also provided technical comments which we incorporated into the 

report where appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Homeland Security, appropriate congressional committees, and other 

interested parties. In addition, the report will be available at no charge on 

the GAO website at http://www.gao.gov. If you or your staff have any 

questions concerning this report, please contact me at (201) 512-9627 or 

maurerd@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs can be found on the last page of this report. 

Key contributors to this report are listed in appendix III. 

David C. Maurer

Director, Homeland Security and Justice Issues
 

Page 40 GAO-12-303 Preparedness Grant Programs

List of Requesters

The Honorable John D Rockefeller IV

Chairman

Committee on Commerce, Science and Transportation

United States Senate

The Honorable Joseph Lieberman

Chairman

The Honorable Susan Collins

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Thomas Coburn

Ranking Member

Permanent Subcommittee on Investigations 

Committee on Homeland Security and Governmental Affairs 

United States Senate

The Honorable Peter King 

Chairman

Committee on Homeland Security

House of Representatives

The Honorable Gus Bilirakis

Chairman

Subcommittee on Emergency Preparedness, Response, and 

Communications

Committee on Homeland Security 

House of Representatives 
Appendix I: FEMA Grants Portfolio

Page 41 GAO-12-303 Preparedness Grant Programs

 

a SHSP, UASI, Metropolitan Medical Response System, Operation Stonegarden, and Citizen Corps 

Program collectively make up what FEMA terms the Homeland Security Grant Program. The 5 

interconnected programs shared the same grant guidance in fiscal year 2011, but each program had 

a separate funding allocation. 

Appendix I: FEMA Grants Portfolio
Appendix II: Comments from the Department 

of Homeland Security

Page 42 GAO-12-303 Preparedness Grant Programs

Appendix II: Comments from the Department 

of Homeland Security
Appendix II: Comments from the Department 

of Homeland Security

Page 43 GAO-12-303 Preparedness Grant Programs
Appendix II: Comments from the Department 

of Homeland Security

Page 44 GAO-12-303 Preparedness Grant Programs
Appendix II: Comments from the Department 

of Homeland Security

Page 45 GAO-12-303 Preparedness Grant Programs
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 46 GAO-12-303 Preparedness Grant Programs

David C. Maurer, (202) 512-9627 or Maurerd@gao.gov

In addition to the contacts above, Dawn Hoff, Assistant Director, and Dan 

Klabunde, Analyst-in-Charge, managed this assignment. Chuck Bausell, 

Juli Digate, David Lutter, Sophia Payind, and Katy Trenholme made 

significant contributions to this report. David Alexander assisted with 

design, methodology, and data analysis. Linda Miller and Jessica Orr

provided assistance with report development, Muriel Brown and Robert 

Robinson provided graphic support, and Tracey King provided legal 

assistance.

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments 

(440972)
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