Federal Emergency Management Agency: Crisis Counseling Grants Awarded to the State of New York after the September 11 Terrorist Attacks
Published: 2005-05-31T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: To help alleviate the psychological distress caused by the September 11, 2001, attacks the Federal Emergency Management Agency (FEMA) awarded the state of New York two grants totaling $154.9 million to provide crisis counseling and public education. Because of questions about whether the program, called Project Liberty, had spent all the funds it received from the federal government, GAO was asked to determine (1) the extent to which the program expended the funds awarded from the federal government, (2) whether the federal government had an effective process in place to determine the amount of funds to provide the program, (3) whether the federal government had adequate financial oversight of the program, and (4) steps taken by the federal government and New York State to assess the program's effectiveness.
section_title: What GAO Found
paragraphs: For the period September 11, 2001, through September 30, 2004, Project Liberty reported that it had expended approximately $121 million, or three-quarters of the $154.9 million in grants awarded by FEMA, leaving a remaining balance of $33.9 million. The majority of the remaining balance, approximately $32 million, related to unresolved issues involving the adequacy of supporting documentation for the New York City Department of Education's (NYC DOEd) expense claims. As of March 31, 2005, city and state officials told GAO they had accepted alternative forms of supporting evidence related to $5.2 million in NYC DOEd expenses; however, this alternative evidence provides only limited assurance of the propriety of the claimed amounts. It is unclear whether similar alternative sources of evidence will be accepted for the remaining $26.8 million in NYC DOEd expense claims. FEMA assisted state officials in developing estimated funding needs for Project Liberty immediately after the terrorist attacks. By necessity, these initial budgets were developed using estimates established during the initial stages of the disaster. However, FEMA never required Project Liberty to prepare adjusted budgets to reflect new information or subsequent changes to the program. As a result, FEMA did not have realistic budget information to assess how city and state officials were planning to spend Project Liberty grant funds. FEMA assigned primary responsibility for oversight and monitoring to the Substance Abuse and Mental Health Services Administration (SAMHSA) through an interagency agreement. Although SAMHSA had procedures in place to monitor Project Liberty's delivery of services, it performed only limited monitoring of financial information reported by Project Liberty about the cost of those services. For example, while SAMHSA received periodic financial reports from Project Liberty, it did not perform basic analyses of expenditures in order to obtain a specific understanding of how the grant funds were being used and, as noted above, did not have updated budget information to gauge how actual spending compared to budgets. As a result, SAMHSA was not in a position to exercise a reasonable level of oversight to ensure that funds were being used efficiently and effectively in addressing the needs of those affected by the September 11 attacks. Both the state of New York and the federal government have taken steps to assess how Project Liberty delivered services. These assessments were ongoing as of March 2005. FEMA plans to consider lessons learned from Project Liberty when conducting its own internal review of the crisis counseling program.

section_title: Letter
paragraphs: To help alleviate the psychological distress in the New York City area  caused by terrorist attacks on September 11, 2001, the Federal Emergency  Management Agency (FEMA) awarded the state of New York two grants  totaling $154.9 million to provide crisis counseling and public education  services.  Specifically, FEMA awarded the state of New York $22.7 million  for an Immediate Services Program (ISP) on September 24, 2001, with  subsequent amendments bringing the ISP total to $22.8 million.  In addition,  FEMA awarded the state of New York $132.1 million for a Regular Services  Program (RSP) on June 14, 2002.
The state of New York operated the crisis counseling and public education  program under the name Project Liberty.  Project Liberty was funded under  FEMA’s Crisis Counseling Assistance and Training Program (CCP), which is  an individual assistance program authorized by the Robert T. Stafford  Disaster Relief and Emergency Assistance Act (Stafford Act).  The CCP is  administered by FEMA and its federal partner, the Substance Abuse and  Mental Health Services Administration (SAMHSA), an agency of the  Department of Health and Human Services (HHS) responsible for  improving the quality and availability of mental health services.  Although  all crisis counseling services for the general public had been phased out by  December 31, 2003, Project Liberty continued to provide these services to  New York City firefighters and schoolchildren through December 31, 2004.
Because of concerns that Project Liberty may be discontinuing services  without having spent all of the funds it received from the federal  government to assist in providing crisis counseling and public education  following the September 11 terrorist attacks, you requested that we review  and report on the use of funds given to the state of New York by the federal  government for crisis counseling services.  In response to this request, we  reviewed the use of funds given to the state of New York by the federal  government by determining (1) the extent to which Project Liberty  expended the funds awarded from the federal government, (2) whether the  federal government had an effective process in place to determine the  amount of funds to provide Project Liberty, (3) whether the federal  government had adequate financial oversight of Project Liberty, and  (4) steps taken by the federal government and the state of New York to  assess the effectiveness of the program in meeting stated objectives and  the results of these assessments.
To address these objectives, we (1) reviewed documentation relating to the  expenditure of Project Liberty funds through September 30, 2004, the most  recent data available as of March 31, 2005, the end of our fieldwork, and  found it sufficiently reliable for the purpose of this report; (2) reviewed the  grant applications and correspondence used to determine funding;  (3) assessed the sufficiency of the federal government’s financial oversight  of Project Liberty in light of GAO’s Standards for Internal Control in the  Federal Government; and (4) reviewed assessments of Project Liberty.  We  performed our work from July 2004 through March 2005 in accordance  with generally accepted government auditing standards.  Our scope and  methodology are discussed in greater detail in appendix I.
We requested written comments on a draft of this report from the Secretary  of Homeland Security.  We received written comments from DHS. The DHS  comments (reprinted in appendix II) incorporate by reference a letter from  SAMHSA to FEMA commenting on the draft (reprinted in appendix III).  We  also provided excerpts of a draft report for technical comment to the New  York State Office of Mental Health (NYS OMH), the New York City  Department of Health and Mental Hygiene (NYC DOHMH), and the New  York City Department of Education (NYC DOEd). NYS OMH technical  comments and the coordinated NYC DOHMH and NYC DOEd technical  comments were incorporated as appropriate.
subsections: section_title: Background
paragraphs: Following the terrorist attacks on September 11, 2001, the President signed  under the authority of the Stafford Act a major disaster declaration for the  state of New York.  The presidential declaration allowed the state of New  York to apply for federal assistance to help recover from the disaster.   FEMA was responsible for coordinating the federal response to the  September 11 terrorist attacks and providing assistance through a variety  of programs, including the CCP.  The CCP was authorized in section 416 of  the Stafford Act to help alleviate the psychological distress caused or  aggravated by disasters declared eligible for federal assistance by the  President.  Through the CCP, FEMA released federal grant awards to  supplement the state of New York’s ability to respond to the psychological  distress caused by the September 11 terrorist attacks through the provision  of short-term crisis counseling services to victims and training for crisis  counselors.
FEMA relied on SAMHSA to provide expertise related to crisis counseling  and public education for Project Liberty.  FEMA assigns SAMHSA’s  responsibilities for the CCP through an annual interagency agreement.   These responsibilities included, among other things, providing technical  assistance, monitoring the progress of programs conducted under the CCP,  and performing program oversight. Within SAMHSA, the Center for Mental  Health Services (CMHS) carried out these responsibilities for Project  Liberty.  CMHS received support from SAMHSA’s Division of Grants  Management, which provides grant oversight.
NYS OMH established Project Liberty under the CCP to offer crisis  counseling and public education services throughout the five boroughs of  New York City and 10 surrounding counties free of charge to anyone  affected by the World Trade Center disaster and its aftermath.  The areas  served by Project Liberty are shown in the shaded areas of figure 1.
The state of New York’s primary role was to administer, oversee, and guide  Project Liberty’s program design, implementation, and evaluation and pay  service providers, but not to provide services itself.  New York City and the  surrounding counties contracted with over 200 service providers and were  responsible for overseeing day-to-day activities.  Figure 2 shows the  organization structure of Project Liberty at the federal, state, and local  levels.
Under the CCP, Project Liberty’s goal was to serve New York City and the  10 surrounding counties by assisting those affected by the September 11  terrorist attacks to recover from their psychological reactions and regain  predisaster level of functioning.  The CCP supports services that are short- term interventions with individuals and groups experiencing psychological  reactions to a presidentially declared disaster and its aftermath.  Crisis  counseling services were primarily delivered to disaster survivors through  outreach, or face-to-face contact with survivors in familiar settings (e.g.,  neighborhoods, churches, community centers, and schools).  Although the  CCP does not support long-term, formal mental health services such as  medications, office-based therapy, diagnostic services, psychiatric  treatment, or substance abuse treatment, FEMA approved an enhanced  services program for Project Liberty.  This enhanced services program  allowed for an expansion of services, including enhanced screening  methods; a broader array of brief counseling approaches; and additional  training, technical assistance, and supervision to a set of service providers.   These enhanced services were intended to address the needs of individuals  who continued to experience trauma symptoms and functional impairment  after initial crisis counseling but did not need long-term mental health  services.
Project Liberty was funded through two separate, but related, grant  programs:  the ISP and RSP.  The ISP grant was designed to fund Project  Liberty for the first 60 days following the disaster declaration.  Because  there was a continuing need for crisis counseling services, the ISP was  extended to last about 9 months, until the RSP began.  The RSP grant was  awarded and was designed to continue to provide funding for an additional  9 months of crisis counseling services, but was extended to last for 2 ½  years.  Figure 3 shows key milestones for Project Liberty.
For the approved ISP application, FEMA made funds available directly to  the state. Under the RSP, after approval, funds were transferred from  FEMA to SAMHSA, which awarded the grant to the state of New York  through SAMHSA’s grants management process.  The state of New York, in  turn, disbursed funds to the service providers and local governments  through the Research Foundation for Mental Hygiene, Inc. (RFMH), a not- for-profit corporation affiliated with the state of New York that assists with  financial management of federal and other grants awarded to NYS OMH.   Figure 4 shows the flow of funds for Project Liberty’s ISP and RSP.
Service providers were required to submit claims and supporting  documentation to receive reimbursement for expenses incurred to provide  services.  As shown in figure 5, these claims were to have multiple levels of  review to determine whether the expenses claimed were allowable under  the CCP’s fiscal guidelines.  This review structure, which placed primary  responsibility for reviewing claims on the local government units, was  based on the state of New York’s existing grant management policies.   Additional controls for Project Liberty included (1) NYS OMH site visits to  service providers in New York City and surrounding counties; (2) closeout  audits by independent auditors of certain New York City service providers  to test whether claims were documented and allowable; and (3) annual  audits of New York City and surrounding counties conducted under the Single Audit Act, which requires independent auditors to provide an  opinion on whether the financial statements are fairly presented, a report  on internal control related to the major programs, and a report on  compliance with key laws, regulations, and the provisions of the grant  agreements.
Our publication, Standards for Internal Control in the Federal  Government, provides a road map for entities to establish control for all  aspects of their operations and a basis against which entities can evaluate  their control structures.  The five components of internal control are as  follows:  Control environment.  Creating a culture of accountability within the  entire organization—program offices, financial services, and regional  offices—by establishing a positive and supportive attitude toward the  achievement of established program outcomes.
Risk assessment.  Identifying and analyzing relevant problems that  might prevent the program from achieving its objectives. Developing  processes that can be used to form a basis for measuring actual or  potential effects of these problems and manage their risks.
Control activities.  Establishing and implementing oversight processes  to address risk areas and help ensure that management’s decisions— especially about how to measure and manage risks—are carried out and  program objectives are met.
Information and communication.  Using and sharing relevant, reliable,  and timely information on program-specific and general financial risks.   Such information surfaces as a result of the processes—or control  activities—used to measure and address risks.
Monitoring.  Tracking improvement initiatives over time and identifying  additional actions needed to further improve program efficiency and  effectiveness.
SAMHSA and FEMA were responsible for providing oversight to ensure  that the state of New York had a reasonable level of controls in place.   Although FEMA retained responsibility for providing leadership and  direction for Project Liberty, it assigned primary responsibility to SAMHSA  for oversight and monitoring through an interagency agreement.
section_title: Remaining Grant Funds Primarily Relate to Unresolved Issues at NYC DOEd
paragraphs: Approximately $121 million, more than three-quarters of the $154.9 million  in federal funds provided to Project Liberty, were reported as expended as  of September 30, 2004, leaving a remaining balance of $33.9 million.  About  $32 million of the $33.9 million pertain to unresolved NYC DOEd expense  claims.  According to NYS OMH, NYC DOEd had not been reimbursed for  the Project Liberty expenses it incurred throughout the program because  NYC DOEd had not been able to provide support for these expenses that  met the CCP documentation standards for reimbursement under federal  grants.  NYS OMH began considering alternative indirect forms of evidence,  including internal control summary memos prepared by NYC DOEd, to  begin paying NYC DOEd’s expense claims.  As of March 31, 2005, NYS OMH  had accepted alternative forms of supporting evidence to pay $5.2 million  of NYC DOEd expense claims; however, this type of alternative evidence  provides only limited assurance of the propriety of the claimed amounts.   NYS OMH was not sure when and how the remaining NYC DOEd expense  claims would be resolved.
subsections: section_title: Timing of Reported Expenditures
paragraphs: For the period September 11, 2001, through September 30, 2004, Project  Liberty reported that it had expended all of the $22.8 million ISP grant and  about $98.2 million of the $132.1 million RSP grant for total reported  expenditures of approximately $121 million, leaving a remaining balance  $33.9 million.  Although crisis counseling services had been phased out as  of December 31, 2004, Project Liberty will continue to use the remaining  grant funds to process claims for reimbursement of program-related  expenses incurred through December 31, 2004, and to cover administrative  expenses during the closeout period, which at the end of our fieldwork,  was scheduled to end on May 30, 2005.  Table 1 and figure 6 show the  timing and amount of expenditures reported by Project Liberty for the ISP  and RSP grants by quarter through September 30, 2004, compared to the  total CCP grant awards for Project Liberty.
According to NYS OMH officials, the expenditures reported by Project  Liberty from September 11, 2001, through September 30, 2004, included  expenses incurred as well as amounts advanced to service providers.   During the RSP, Project Liberty made advances to 109 service providers, for  a total of about $25.8 million.  As of September 30, 2004, the outstanding advance balance was $5.8 million; however, according to an NYS OMH  official, the balance had been reduced to $1.2 million as of March 31, 2005.
section_title: NYC DOEd Expense Claims Not Fully Resolved
paragraphs: The vast majority of remaining Project Liberty funds related to unresolved  expense claims of NYC DOEd.  As of March 31, 2005, NYS OMH  officials told us that NYC DOEd had submitted claims for a portion of the  $32 million that was budgeted to NYC DOEd to provide crisis counseling  services to New York City school children, and planned to ultimately  submit claims for the full amount.
NYS OMH and NYC DOHMH had not approved the majority of NYC DOEd  claims for reimbursement incurred during the RSP because NYC DOEd had  not provided support for these expenses that met the CCP documentation  standards for reimbursement under federal grants.  These standards  require that the expenditure of grant funds be supported by detailed  documentation, such as canceled checks, paid bills, time and attendance  records, and contract and subgrant award documents.  According to NYC  DOEd officials, they could not meet the documentation standards  established by NYS OMH because (1) NYC DOEd reorganized on July 1,  2003, which coincided with the delivery of crisis counseling services under  the Project Liberty grant, resulting in significant loss of staff, loss of  institutional knowledge, and therefore lost or diminished ability to retrieve  supporting documentation, and (2) NYC DOEd’s complex financial systems  cannot produce the type of transaction-specific documentation required by  NYS OMH and makes the process of retrieving supporting documentation  unwieldy and administratively burdensome.
A SAMHSA official told us SAMHSA was aware of issues involving the  supporting documentation for the NYC DOEd expense claims; however,  because officials viewed it as a grantee issue, they have had limited  involvement with NYS OMH’s efforts to resolve these issues.  NYS OMH  decided to consider alternative evidence, including supplemental  supporting documentation in the form of internal control summary memos  prepared by NYC DOEd that describe the controls over payments for  personnel, other-than-personnel, and community-based organization expenses.  Personnel expenses include NYC DOEd workers while the  other-than-personnel expenses include other costs incurred directly by  NYC DOEd.  The community-based organization expenses are those  incurred by other service providers on behalf of NYC DOEd.
Although NYC DOEd’s Chief Financial Officer has signed an attestation  stating that the controls described in the summary memos for personnel  and other-than-personnel expenses were in place and working during  Project Liberty, the level of assurance provided by these internal control  summary memos is limited for several reasons.  First and foremost, the  memos do not provide the type of supporting documentation necessary to  verify the validity of the claimed expenses as required by the federal  documentation standards.  Second, the memos are not certified by an  external source, such as an independent auditor.  Third, the memos were  prepared solely to support NYC DOEd’s Project Liberty expenses and may  not represent written policies and procedures that existed during the time  the claimed expenditures were incurred.  And lastly, the memos were  prepared toward the end of the program by officials who did not, in all  cases, have firsthand knowledge of the controls that existed during the  program.
As of March 31, 2005, NYS OMH and NYC DOHMH had reviewed and  accepted internal control summary memos that describe the controls over  payments for personnel and other-than-personnel expenses, and NYS OMH  had used these memos and other alternative forms of evidence to  reimburse NYC DOEd for $5.2 million in expense claims.  These other  forms of evidence included observations of services being provided during  site visits, the existence of encounter logs evidencing that some services  had been provided, and general familiarity with service providers.  NYS  OMH officials were not sure when they would complete the review of the  memo covering the controls over payments for community-based  organization expenses and how this memo, along with other alternative  forms of evidence, would be used to resolve the remaining $26.8 million in  NYC DOEd expense claims.
As part of its approval process for expense claims, NYS OMH relied upon  NYC DOHMH to certify that the claims submitted were valid and met the  CCP documentation requirements. However, because NYC DOEd did not  provide the required supporting documentation, NYC DOHMH could not  perform the same level of review as it did for the claims of the other Project  Liberty service providers.  Further, although NYC DOHMH contracted  with independent auditors to perform audits of expense claims of certain  service providers for Project Liberty, there were no audits performed of  NYC DOEd claims, which are expected to total approximately $32 million.
At the end of our audit fieldwork, it was not clear when and how the  remaining expense claims would be resolved.  However, if the internal  control summary memos and other alternative evidence continue to be the  primary supporting documentation for $32 million in NYC DOEd expense  claims, the federal government will have only limited assurance that these  payments are an appropriate use of Project Liberty grant funds.
section_title: Improvements Needed in the Process for Determining Federal Funding
paragraphs: FEMA’s process for determining funding is designed to be implemented  quickly after a state requests federal assistance to recover from a  presidentially declared disaster.  The state of New York’s grant applications  for Project Liberty were developed during the initial dynamic stages of the  recovery effort when damage reports and response plans were subject to  frequent change.  The budgets submitted with the grant applications were  revised by the grantee to satisfy certain conditions of grant award.   However, we found that although the budgets were developed using  estimates established during the initial stages of the disaster, FEMA and  SAMHSA never required the state of New York to formally submit revised  budget requests to reflect new information and significant changes to the  program that occurred as the needs of the affected population became  better identified.  As a result, FEMA and SAMHSA did not have realistic  budget information that could be used to effectively assess how  responsible city and state officials planned to spend Project Liberty grant  funds.
subsections: section_title: Federal Assistance Application Process
paragraphs: The grant applications that the state of New York submitted to FEMA for  Project Liberty were prepared with assistance from FEMA and SAMHSA  and included a needs assessment, plan of services, and budget.  The needs  assessment, which was based on a formula developed by SAMHSA, was the  state’s estimate of the number of people who would need crisis counseling.  The plan of services described the state’s plan for treating the identified  population, including segments of the population needing special services  or outreach methods such as counseling and training in various languages.  The budget was developed based on the estimated cost to treat the  population identified in the needs assessment through the program  outlined in the plan of services.
FEMA and SAMHSA provided the state of New York the flexibility to  submit grant applications that reflected its identified and estimated needs,  which were based on information available at the time.  In preparing the  budget, the state of New York relied on SAMHSA’s Budget Estimating and  Reporting Tool, which was designed to assist states in developing budgets  consistent with FEMA guidelines.  The state of New York took two  different approaches in constructing the ISP and RSP budgets for Project  Liberty. The ISP budget used estimates of administrative costs and a simple  direct services cost calculation. The direct services costs were based on  the estimated number of people needing crisis counseling services, the  estimated average length of treatment each person would need, the  estimated hourly rate for crisis counselors, and the estimated length of the  ISP. The RSP budget, on the other hand, was prepared by the state of New  York based on estimates provided by NYS OMH, each of the New York City  boroughs, and the 10 surrounding counties eligible for CCP grant funding.
Once the state of New York submitted its ISP and RSP grant applications,  FEMA had processes in place to review and approve them.  Although the  processes differed, both shared common elements. The first step for both  applications was a technical review conducted by the FEMA regional office  with jurisdiction over the state of New York to ensure that the applications  had a direct link to the September 11 terrorist attacks.  Once this technical  review was completed, the applications were sent to FEMA headquarters  and to SAMHSA for review and comment. In addition, the RSP was  reviewed by a panel of mental health professionals who had experience  with CCP grants. The ISP and RSP review processes also differed in that  FEMA’s regional office had final decision authority for the ISP application  while FEMA headquarters had final decision authority for the RSP  application. Figure 7 shows the application processes for the ISP and RSP.
After the reviews conducted by FEMA and SAMHSA were completed,  FEMA awarded the state of New York $22.7 million for the ISP on  September 24, 2001, with subsequent amendments bringing the ISP total  to $22.8 million.  In addition, FEMA awarded the state of New York  $132.1 million for the RSP immediately after the ISP ended on June 14,  2002.
section_title: Budgets Were Not Adjusted to Reflect New Information or Program Changes
paragraphs: Because FEMA’s process for determining funding is designed to be  implemented quickly after presidential disaster declarations and official  loss numbers were not known at the time the Project Liberty applications  were prepared, the state of New York used estimates of the number of  people who would need crisis counseling services, the length of the  program, and the services that would be provided.  However, FEMA and  SAMHSA never required the budgets to be modified to reflect new  information or significant changes to the program.
The estimates used by the state of New York to develop its initial needs  assessment, or number of people it believed would need crisis counseling  services, included several risk factors and loss categories. In keeping with  existing CCP policy, FEMA and SAMHSA encouraged the state of New York  to modify the needs assessment formula by adjusting the loss categories of  affected persons and the risk factors for each of those loss categories to  better reflect the situation in New York. The state of New York also  estimated the number of direct victims in each loss category because  official numbers were not available.  For example, the official number of  deaths was not known until more than 2 years after the disaster.  As a result  of these estimates, the needs assessment for the state of New York’s ISP  application determined that 2.3 million people would need crisis  counseling services as a result of the terrorist attacks on September 11,  2001.  With the RSP application, the needs assessment formula was  modified to estimate the pervasive reactions to the disaster and to update  the loss category numbers, such as the number of people dead, missing, or  hospitalized.  These modifications increased the estimate of the people  who would need crisis counseling to 3.4 million.
We found that based on the approved budgets for the ISP and RSP, Project  Liberty estimated that it would need $154.9 million to provide crisis  counseling and public education to the estimated 3.4 million people and  training for Project Liberty staff who would be delivering these services, at  a cost of approximately $46 per person.  In its report for the period ending  September 30, 2004, Project Liberty estimated that it had provided crisis  counseling to 1.5 million people at a cost of $121 million, or approximately  $83 per person.
Another estimate used in preparing the grant applications was the length of  time needed to carry out the services identified in the plan of services. The  state of New York used the maximum length of service provision allowed  by FEMA regulations in its ISP and RSP applications, 60 days and 9 months,  respectively.  However, crisis counseling services were actually provided  for approximately 9 months under the ISP and over 30 months under the  RSP.
In addition, the state of New York initially understood that crisis counseling  and public education services offered by Project Liberty would be limited  to the services normally allowed by the CCP, such as short-term individual  and group crisis counseling, community outreach, and training for crisis  counselors.  However, in August 2002, Project Liberty was authorized to  adjust the program to include enhanced services and began providing these  services in May 2003.
Other significant changes, which were not reflected in Project Liberty’s  budget, included a reallocation from New York City’s budget to the NYC  DOEd, which increased NYC DOEd’s budget from $8.9 million to $40  million and subsequent reductions of NYC DOEd’s budget to $32 million.   Despite these major changes in the program, FEMA and SAMHSA did not  require and Project Liberty did not prepare adjusted budgets to reflect their  revised plans for meeting the needs of the victims of September 11.  Therefore, New York State and City officials did not have realistic budget  information to use as a tool to manage program funds, and FEMA and  SAMHSA were not in a position to effectively assess the planned use of the  funds.
section_title: Federal Oversight of Project Liberty’s Financial Information Was Limited
paragraphs: While SAMHSA provided oversight of Project Liberty’s delivery of services,  it provided only limited oversight of financial information reported by  Project Liberty about the cost of those services.  SAMHSA received  periodic financial reports but did not perform basic analyses of  expenditures to obtain a specific understanding of how Project Liberty was  using federal funds.  In addition, as discussed above, budget information  was outdated and therefore an ineffective tool to monitor actual  expenditures.  SAMHSA’s limited level of oversight over Project Liberty’s  financial information was driven in part by its assessment that the program  was not high risk, but this assessment did not fully consider the magnitude,  complexity, and unique nature of the program and was not revisited even  after significant program changes occurred.  As a result, SAMHSA was not  in a position to exercise a reasonable level of oversight to ensure that funds  were used efficiently and effectively in addressing the needs of those  affected by the September 11 terrorist attacks.
SAMHSA’s oversight for Project Liberty included review of service delivery  information and identification of unusual items included in Project  Liberty’s program reports, eight site visits, and routine communication with  NYS OMH and FEMA.  These oversight activities helped SAMHSA gain  assurance that NYS OMH was delivering appropriate services.  However,  SAMHSA’s oversight of these services did not directly link with, and  therefore did not provide assurance related to, financial information  reported by Project Liberty.  In addition to requiring Project Liberty to  submit budgets to show how it planned to use federal funds, FEMA  regulations also required Project Liberty to periodically submit financial  reports to show how funds were actually spent.  Required financial reports  included quarterly expenditure reports, a final accounting of funds, and a  final voucher.  SAMHSA officials told us they did some high-level review of  the financial information provided to determine how quickly the program  was using grant funds and when the grant funds should be made available  to NYS OMH.  However, they did not perform basic analyses of  expenditures to obtain a specific understanding of how Project Liberty was  using federal funds.
We found that SAMHSA did not use financial information submitted by  Project Liberty to conduct basic analytical reviews of how funds were  being spent and whether this spending was consistent with the budgeted  program expenditures.  Table 2 illustrates a basic analysis we performed of  Project Liberty’s reported and budgeted expenditures for the period  June 14, 2002, through September 30, 2004, which identified significant  differences by category between reported expenditures and budget.
Notwithstanding the fact that budgets were not updated for major program  changes, several of these differences should have raised questions about  whether Project Liberty was using federal funds within allowable  categories and within its approved budget.  For example, the Project  Liberty personnel budget was over $93 million; however, as of  September 30, 2004, over 26 months into the program that was initially  planned for completion in 9 months, it had reported personnel  expenditures of only about $26 million, for a difference of about $67  million.  A SAMHSA official said that because of the way Project Liberty  reported its expenditures, SAMHSA officials could not track its financial  reports to its budget.  As a result, we found that SAMHSA was not aware of  the significant variations between Project Liberty’s reported expenditures  and budget and did not make inquiries of Project Liberty officials to obtain  an understanding of why these variations were occurring. Some of the  differences between reported and budgeted expenditures may have  resulted from the fact that Project Liberty was not required to formally  adjust the initial program budget to reflect significant changes.  However,  the differences may also have raised questions about whether SAMHSA’s  understanding of how the program was planning to spend funds was  consistent with actual spending patterns.   Comparisons between Project  Liberty’s reported budget and expenditures could have helped SAMHSA  better assess the status of the program to allow it to take effective action to  ensure that Project Liberty was using federal funds to provide the most  value for victims of the September 11 terrorist attacks.
The differences between Project Liberty’s reported budget and  expenditures may also have been caused by inconsistencies in financial  information submitted by Project Liberty.  FEMA and SAMHSA did not  provide detailed guidance on how to classify CCP expenditures but instead  left Project Liberty to interpret how expenditures should be classified.  We  found that Project Liberty expenditures were not always consistently  reported to FEMA and SAMHSA.  For example, Project Liberty did not  consistently classify evaluation expenditures.  If an NYS OMH employee  was evaluating the program, the expenditure was classified as personnel,  but if the work was contracted to someone outside of NYS OMH, the  expenditure was classified as evaluation.  As a result, SAMHSA could not  reliably use Project Liberty’s financial reports to determine how much it  cost to evaluate the program.  By obtaining a better understanding of how  federal funds were spent by Project Liberty, SAMHSA would have improved  its ability to determine whether funds were used most efficiently and  effectively in carrying out the objectives of the program.
SAMHSA’s limited oversight of Project Liberty’s financial information was  driven in part by its own assessment that the program was not high risk.   SAMHSA’s oversight of Project Liberty included an initial assessment of the  risk associated with the grantee.  SAMHSA applied risk factors identified in  HHS regulations regarding grants, including financial management issues,  such as financial stability and experience in handling federal grants, to  RFMH, the fiscal agent for NYS OMH responsible for making payments to  service providers.  For example, SAMHSA reviewed the result of RFMH’s  fiscal year 2001 financial audit that was required by the Single Audit Act  and found that RFMH received an unqualified audit opinion while handling  a total of about $62 million in federal funds.  SAMHSA concluded that  RFMH had a strong track record for handling federal funds and classified  RFMH as not high risk.  Based in part on this risk assessment, SAMHSA  officials told us staff with financial backgrounds were not actively involved  in the oversight of Project Liberty.
However, we found that SAMHSA’s risk assessment only considered risks  associated with RFMH and did not consider other potential risks  associated with the Project Liberty grant.  For example, the assessment did  not consider all significant interactions in the complex federal, state, and  local government environment that existed for Project Liberty; the amount  of the RSP grant award, which was the largest RSP grant ever made by  FEMA; or the geographic complexities of the program, including the size of  the area affected and the diversity of the community being served.  In  addition, SAMHSA did not revisit its initial risk assessment even after the  program encountered significant changes and challenges, including the  design of the first-ever enhanced services program and the documentation  issues with NYC DOEd expenses, which have yet to be resolved. As a  result, SAMHSA’s level of oversight was not in line with the challenges and  complexities that increased the risks associated with Project Liberty.
Based in part on its risk assessment process, SAMHSA’s oversight of  Project Liberty was primarily carried out by its programmatic staff who  focused on activities that did not directly link to the financial information  being reported by NYS OMH.  Without useful financial information,  including updated budgets, and without analyses of the financial  information Project Liberty was reporting, SAMHSA was not in a position  to exercise a reasonable level of oversight to ensure that grant funds were  effectively used to address the needs of those affected by the September 11  terrorist attacks.
section_title: Assessments of Project Liberty Ongoing
paragraphs: Both the state of New York and the federal government have taken steps to  assess how Project Liberty delivered services.  NYS OMH is conducting its  own assessment of Project Liberty and partnered with NYAM to obtain  information from telephone surveys.  SAMHSA contracted with NCPTSD, a  center within the Department of Veterans Affairs, to conduct a case study  of New York’s response to the terrorist attacks on September 11, with a  primary focus on Project Liberty.  Both NYS OMH and NCPTSD’s overall  assessments of the program were ongoing as of March 2005.  FEMA plans  to consider lessons learned from NYS OMH and NCPTSD when conducting  its own internal review of the CCP.
NYS OMH is conducting an evaluation of Project Liberty, which includes  designated funding for program evaluation.  This nonstatistical evaluation  consists of several components, including analysis of data collected by  service providers documenting services delivered through encounter data  forms, recipient feedback through written questionnaires and telephone  surveys, provider feedback through written reports and staff surveys,  and other initiatives. The data collected by service providers was the  primary method used to assess the services delivered by the program.   Based on these data, NYS OMH preliminarily found that Project Liberty had  reached a large number of people affected by the September 11 terrorist  attacks and that it was successful in reaching many diverse communities.   NYS OMH reported that 95 percent of providers who responded to its  surveys rated the overall quality of services provided as good or excellent.   NYS OMH also reported that the majority of respondents to its recipient  surveys indicated that they have returned to their predisaster mental health  condition, a goal of Project Liberty.  However, according to NYS OMH, the  recipient surveys were made available beginning in July 2003 to  organizations providing crisis counseling for distribution to individuals  receiving services and therefore may not be representative of all Project  Liberty recipients.  NYS OMH did not report the number of providers who received surveys and reported a low response rate for recipients.   Because the number of surveys offered to providers was not disclosed and  because of low response rates for the recipient surveys, we were unable to  determine the level of coverage provided by these surveys.
NYS OMH also partnered with NYAM, a not-for-profit organization  dedicated to enhancing public health through research, education, public  policy, and advocacy.  NYAM conducted nonstatistical telephone surveys in  2001 and 2002 of New Yorkers to assess the magnitude and duration of the  mental health effects of the terrorist attacks.  NYS OMH worked with  NYAM to assess the reach and recognition of Project Liberty by adding  questions to NYAM's ongoing September 11 telephone surveys.  NYAM and  NYS OMH reported that 24 percent of the respondents interviewed were  aware of Project Liberty and, among respondents who had heard of the  program, 67 percent had a good impression of the program.  However,  because the sampling methodology for the NYAM phone surveys was not  disclosed and because of low response rates, we were unable to determine  the survey coverage.
Based on these evaluation activities, as well as their own experience with  Project Liberty, NYS OMH officials have begun to identify lessons to be  learned.  For example, they found that emergency mental health plans and  resources in place prior to September 11 were insufficient to fully respond  to the mental health impact of the terrorist attacks.  Much of the  infrastructure needed to implement Project Liberty, such as data collection  procedures and public education materials, had to be developed in the  immediate aftermath of the terrorist attacks.  In addition, NYS OMH found  that the services covered by the CCP were not sufficient to meet the mental  health needs of the minority of individuals who developed severe and  persistent symptoms that substantially interfered with day-to-day  functioning.  Although the state of New York was given permission to  develop and implement an enhanced services program to meet the needs of  the more severely affected individuals, similar intensive interventions are  not currently routinely included as part of the FEMA CCP.  NYS OMH  officials told us that when their evaluation is completed, they expect that  they will have comprehensively identified best practices and obstacles  encountered and that they will make recommendations to FEMA and  SAMHSA for actions needed to better organize a mental health response to  future disasters funded by the CCP.
SAMHSA entered into an interagency agreement with NCPTSD, a center  within the Department of Veterans Affairs, to conduct a case study of New  York’s response to the September 11 terrorist attacks.  The primary purpose  of the NCPTSD case study was to identify lessons to be learned from New  York’s experience that could be useful to other communities that might  have to respond to major disasters, including acts of terrorism.  As part of  its study, NCPTSD interviewed 103 individuals, including service providers  and management from 50 public and private provider organizations in New  York City and the surrounding counties.  NCPTSD used a qualitative  methodology to analyze the data to develop findings and  recommendations.  According to SAMHSA, the NCPTSD report is expected  to be issued as soon as all stakeholders’ comments have been received and  considered.
FEMA officials told us they plan to consider lessons learned from the  NCPTSD and NYS OMH assessments of Project Liberty through FEMA’s  internal review of the CCP that was ongoing as of March 2005.  This  internal review is being conducted in partnership with SAMHSA and,  according to FEMA, will consider whether aspects of FEMA’s CCP,  including its regulations and guidance, need to be improved.  For example,  FEMA plans to work with SAMHSA to consider the extent to which the  enhanced services should be included as a permanent part of the CCP.    FEMA officials told us that the internal review will have to be completed in  conjunction with their primary work responding to disasters; therefore,  they have not established a timetable to complete this review.  Given that  Project Liberty was awarded the largest RSP grant in the history of FEMA’s  CCP and that FEMA provided funding to the state of New York to evaluate  Project Liberty, the timely assessment of lessons learned from this program  would be beneficial to future CCPs.
section_title: Conclusions
paragraphs: FEMA and SAMHSA’s limited oversight of the planned and actual spending  of Project Liberty impeded their ability to monitor whether the grant funds  were being used in the most efficient and effective way to meet the needs  of those affected by the terrorist attacks of September 11, 2001.  Further,  until recently, FEMA and SAMHSA had limited involvement in efforts to  resolve issues surrounding the outstanding NYC DOEd expense claims;  additional oversight in this area could help bring appropriate and timely  resolution to these issues.  FEMA will have an opportunity to address these  oversight issues, as well as lessons learned identified by NYS OMH and  NCPTSD, as part of its ongoing internal review of its CCP.
section_title: Recommendations for Executive Action
paragraphs: In order to address the issues identified in our report, we recommend that  the Secretary of Homeland Security direct the Under Secretary of  Emergency Preparedness and Response to take the following eight actions: To help ensure proper and timely expenditure of the remaining Project  Liberty funds, FEMA should work with SAMHSA to  provide assistance to New York City and State officials in appropriately  resolving issues surrounding the NYC DOEd expense reimbursements  and  determine whether an independent review of the propriety of the use of  funds for payments to the NYC DOEd is needed.
To strengthen federal financial oversight of future CCP grants, FEMA  should work with SAMHSA to  require the recipients of CCP grants to submit updated budgets to  reflect approved changes to the program;  revise the current risk assessment process to comprehensively identify  and assess risks associated with CCP grants;  establish a process to update the risk assessment for significant   consider developing formal requirements for consistent classifications  of expense data; and  develop formal procedures to perform more detailed analyses of  financial reports, including comparing actual expenditures and budgets  to identify variations and obtain an understanding of the reasons for any  unusual variations.
To help ensure that the lessons learned from Project Liberty will be used to  help improve future programs funded by the CCP, FEMA should establish a  clear time frame to complete its internal review of the CCP as expeditiously  as possible.
section_title: Agency Comments and Our Evaluation
paragraphs: We received written comments on a draft of this report from DHS who  generally concurred with our recommendations but expressed reservations  regarding our assessment of the adequacy of FEMA and SAMHSA  oversight.  SAMHSA in a separate comment letter to FEMA, did not object  to our recommendations but did take issue with our assessment of its  oversight, particularly given the unprecedented circumstances that led to  the establishment of Project Liberty.  SAMHSA also provided additional  information on the NYC DOEd claim issue.  DHS’s comment letter  (reprinted in appendix II) incorporates by reference SAMHSA’s letter  (reprinted in appendix III).  We also received technical comments from  NYS OMH, NYC DOHMH, and NYC DOEd on excerpts of the report, which  we incorporated as appropriate.
DHS stated that our report should give more weight to the unprecedented  conditions that led to Project Liberty, and that it was these unique  circumstances that led to our findings and were the basis for our  recommendations.  It further stated that our recommendations primarily  relate to the use of grant funds by NYC DOEd, and that no similar issues  were identified with respect to the use of funds by other program  subgrantees.
Our report clearly acknowledges the unique and unprecedented  circumstances that led to the establishment of Project Liberty.  These  unique circumstances were largely the basis for our conclusion that Project  Liberty required a high level of federal oversight.  A number of red flags  signaled the need for a heightened federal role, including: the RSP grant  was the largest such grant ever made by FEMA; the program initially  designed to last about a year is now over 3 ½ years old and still ongoing,  with an extension being considered to September 30, 2005; and  reimbursements for approximately $32 million, representing over 20  percent of the total federal funds awarded, remained unresolved as of May  2005.  The fact that the level of federal oversight was not commensurate  with the unprecedented circumstances surrounding Project Liberty was  what led us to our findings and recommendations in this area.
Five of our eight recommendations relate to strengthening federal financial  oversight of future CCP grants; two of the recommendations specifically  address the NYC DOEd use of grant funds; and the remaining  recommendation calls for ensuring that lessons learned from Project  Liberty will be used to improve future programs funded by the CCP.  Thus,  DHS was incorrect in stating that our recommendations primarily relate to  the NYC DOEd issues.
As to FEMA’s statement that we did not identify any other issues about the  use of grant funds, the scope of our work included determining the extent  to which Project Liberty expended grant funds and whether the federal  government had adequate financial oversight of Project Liberty.  Our work  did not address whether payments made, including those made by NYC  DOEd, were a valid use of federal resources.  We have no basis for reaching  the conclusion suggested by FEMA.
SAMHSA’s letter also discussed the unprecedented conditions surrounding  Project Liberty and, as discussed below, strongly disagreed with our  assessment that SAMHSA’s financial oversight was limited.  SAMHSA also  stated that during a recent site visit, NYC DOEd’s Chief Financial Officer  indicated that documentation was available to support claims as necessary.   SAMHSA further stated that it will be recommending that the NYS OMH  conduct an independent audit of these claims as one of the conditions of  approving an extension of the grant to September 30, 2005.  During our  fieldwork, we were consistently told by NYC DOHMH officials that NYC  DOEd had not been able to produce documentation for the majority of  expenses it incurred on behalf of Project Liberty that met the  documentation standards for reimbursement under federal grants. Given  ongoing questions about the existence of documentation supporting NYC  DOEd claims, the sufficiency of this documentation, or both, we agree that  an independent audit is appropriate.
SAMHSA stated that overall, the federal oversight of Project Liberty was  appropriate, reasonable, and responsive to state and local needs.  SAMHSA  outlined several factors to support this statement, including that it received  financial data from the state of New York on a routine basis and monitored  the allocability, allowability, and reasonableness of project expenditures.   While SAMHSA acknowledged that project budget data were not updated  comprehensively, it stated that it did request and receive updated budget  information in several instances, particularly in conjunction with project  extensions.  SAMHSA further stated that we had not cited any problems  with program expenditures but instead seemed to focus on differences  between classification of budgeted and reported expenditures.  SAMHSA  acknowledged that the budget was not prepared in the same format as  reported expenditures, and stated that inconsistent categorization of  expense accounts were largely the reason for the classification  discrepancies we highlighted in our report.
Our conclusion that SAMHSA’s oversight of Project Liberty’s financial  information was limited was based in large part on the fact that the  SAMHSA did not have a basis to reliably monitor how Project Liberty was  using federal funds, since, as SAMHSA acknowledged, it did not have  updated budget information and the reported expenditure data were not  accurate due to classification discrepancies.  At the time of our review,  SAMHSA was not aware of these discrepancies because it had not been  conducting basic analyses, such as comparisons between Project Liberty’s  budgeted and reported expenses.  Further, there were no staff with  financial backgrounds involved with the oversight of Project Liberty  expenditures.  SAMHSA’s limited oversight was based in part on the fact  that it did not deem the project high risk from a financial standpoint,  despite the complex federal, state, and local environment, the fact that this  was by far the largest RSP grant ever awarded by FEMA, the size and  diversity of the community being served, and the overall challenging and  changing circumstances of September 11.  Overall, we found that  SAMHSA’s level of oversight was not in line with these challenges and  complexities associated with Project Liberty.
SAMHSA went on to state that in its opinion, classification of Project  Liverty as high risk simply based on total estimated project expenditures  would be inappropriate.  It further noted that there is no regulatory  mechanism allowing SAMHSA to assess risk on a complex federal, state,  and local government environment as was specified in our report.
We did not suggest that the risk classification should simply be based on  total estimated project expenditures.  As discussed above, our report  clearly delineates a number of different risk factors that should have been  considered in the risk classification.  Further, we disagree that the current  regulatory mechanism would not allow SAMHSA to consider these risk  factors in making its risk assessment of Project Liberty.  While current  regulations do not require SAMHSA to consider programmatic factors in its  risk assessment, they do not prevent SAMHSA from considering risk  factors other than those delineated in its regulations in its overall  assessment of the program and its operations.  As noted by SAMHSA in its  written comments, Project Liberty was by far the largest and most complex  effort in the 30-year history of the CCP and presented unique and  unprecedented challenges for government authorities at all levels.  We  believe these should have been key factors in SAMHSA’s risk assessment  and should have triggered heightened financial oversight of Project Liberty.
As agreed with your offices, unless you publicly announce its contents  earlier, we plan no further distribution of this report until 30 days from its  date.  At that time, we will send copies to appropriate House and Senate  committees; the Secretary of Homeland Security; the Under Secretary of  Homeland Security for Emergency Preparedness and Response; the  Administrator, Substance Abuse and Mental Health Services  Administration; the Director, Office of Management and Budget; and other  interested parties.  We will make copies available to others upon request. In  addition, the report will be available at no charge on the GAO Web site at  http://www.gao.gov.
If you or your staffs have any questions about this report, please contact  me at (202) 512-8341 or calboml@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page  of this report. Major contributors to this report are listed in appendix IV.
section_title: Objectives, Scope, and Methodology
paragraphs: To determine the extent to which Project Liberty spent the Immediate  Services Program (ISP) and Regular Services Program (RSP) grant funds  received from the Federal Emergency Management Agency (FEMA), we  did the following:  Reviewed various documents, including quarterly RSP expenditure  reports for the first (June 15, 2002, through September 14, 2002) through  the ninth (June 15, 2004, through September 30, 2004) quarters; a  detailed listing of the outstanding advance balances as of September 30,  2004, obtained from the Research Foundation for Mental Hygiene, Inc.  (RFMH); a summary of expense claims submitted by the New York City  Department of Education (NYC DOEd) as of March 2005; internal  control summaries prepared by NYC DOEd for its personnel and other- than-personnel expenses; a draft internal control summary prepared by  NYC DOEd for its community-based expenses; Crisis Counseling  Assistance and Training Program (CCP) guidance on appropriate uses of  grant funds; and FEMA and Department of Health and Human Services  (HHS) regulations pertaining to the CCP.
Interviewed officials from FEMA’s headquarters and finance office, the  Substance Abuse and Mental Health Services Administration’s  (SAMHSA) Center for Mental Health Services (CMHS), the New York  State Office of Mental Health (NYS OMH), RFMH, the New York City  Department of Health and Mental Hygiene (NYC DOHMH), and NYC  DOEd.
Determined that the total expenditures data obtained from RFMH and  Project Liberty’s quarterly expenditure reports were sufficiently reliable  for the purposes of this report by the following:  Obtaining and reviewing a copy of the independent auditor’s report  of RFMH’s financial statements for fiscal years ending March 31, 2004  and 2003, and Report on Compliance and on Internal Control Over  Financial Reporting Based on an Audit of Financial Statements  Performed in Accordance with Government Auditing Standards as  of March 31, 2004.  We determined that RFMH received a clean  opinion on its fiscal year 2004 and 2003 financial statements.  In  addition, the auditor concluded that its tests of RFMH’s compliance  with certain provisions of laws, regulations, contracts, and grants did  not disclose any instances of noncompliance that are required to be  reported under Government Auditing Standards.  Finally, the  auditor’s consideration of internal control over RFMH’s financial  reporting did not identify any matters involving the internal control  over financial reporting and its operation that it considered to be  material weaknesses.
Analyzing a database obtained from RFMH of the payments made on  behalf of Project Liberty for the ISP and RSP from the first payment  made on September 25, 2001, through September 30, 2004, including  advances made to service providers.
Determining that the amount of the payments included in the  database was consistent with the total reported expenditures in the  ISP final report and the RSP quarterly expenditure reports that were  prepared by Project Liberty and submitted to SAMHSA and FEMA.
Comparing the Project Liberty expenditures as reported by RFMH to  drawdowns reported by SAMHSA on Project Liberty’s RSP grant  award.
Obtaining a written certification of data completeness from the  Managing Director of RFMH that the expenditures reported in the  database were complete and accurate for all payments made for, or  on behalf of, Project Liberty for the ISP and the RSP through  September 30, 2004.
Reviewing Single Audit Act reports for fiscal years 2003 and 2002 of  New York City and surrounding counties.
To determine whether the federal government had an effective process in  place to determine the amount of funds to provide to Project Liberty, we  interviewed officials from FEMA headquarters, SAMHSA’s CMHS, NYS  OMH, and RFMH;  reviewed various documents, including the state of New York’s ISP and  RSP grant applications, the ISP and RSP grant awards, and federal  guidance for the CCP, including the Robert T. Stafford Disaster Relief  and Emergency Assistance Act and FEMA and HHS regulations; and  reviewed correspondence between officials from FEMA, SAMHSA’s  CMHS, NYS OMH, and RFMH.
To assess federal oversight over Project Liberty’s expenditures, we  obtained an understanding of CCP oversight roles and responsibilities  by reviewing FEMA and HHS regulations, FEMA and SAMHSA’s fiscal  year 2004 interagency agreement, CCP fiscal guidelines, HHS’s grants  management manual, summary documents of the CCP’s oversight  structure prepared by SAMHSA, and GAO reports;  reviewed available documentation of oversight performed for Project  Liberty, including Project Liberty’s financial reports and documentation  of site visits conducted by FEMA and SAMHSA;  analyzed Project Liberty’s financial reports and compared them to initial   designed our work to assess the effectiveness of federal oversight and  therefore considered but did not assess the controls over Project Liberty  payments implemented at the state and local levels;  interviewed officials from FEMA headquarters and the FEMA regional  office that serves New York, SAMHSA’s CMHS, SAMHSA’s Division of  Grants Management, NYS OMH, and RFMH to identify policies and  procedures for overseeing Project Liberty; and  reviewed and used Standards for Internal Control in the Federal  Government  as criteria.
To identify the steps that have been taken by the federal government in  partnership with the state of New York to assess Project Liberty, we  reviewed documentation of assessments performed, including a draft of  the National Center for Post-Traumatic Stress Disorder case study of  Project Liberty, NYS OMH summaries of survey results, an article  written by the Deputy Commissioner of NYS OMH on lessons learned  about the mental health consequences of the September 11 terrorist  attacks, articles published by the New York Academy of Medicine, and  documentation from FEMA related to its internal review of the CCP;  reviewed various documents related to Project Liberty including the  grant applications and the response to conditions of the grant award set  out by FEMA and SAMHSA;  reviewed GAO and FEMA Office of Inspector General reports to  determine whether the CCP was evaluated; and  interviewed officials from FEMA headquarters, SAMHSA’s CMHS, and  NYS OMH.
We requested written comments on a draft of this report from the Secretary  of Homeland Security.  We received written comments from DHS.  The DHS  comments (reprinted in app. II) incorporate by reference a letter from  SAMHSA to FEMA commenting on the draft (reprinted in app. III).  We also  provided excerpts of a draft for technical comment to NYS OMH, NYC  DOHMH, and NYC DOEd.  NYS OMH technical comments and the  coordinated NYC DOHMH and NYC DOEd technical comments are  incorporated as appropriate.
We performed our work from July 2004 through March 2005 in accordance  with generally accepted government auditing standards.
subsections: section_title: Organizations Contacted
subsections: section_title: Federal Agencies
section_title: State of New York
paragraphs: New York State Office of Mental Health Research Foundation for Mental Hygiene, Inc.
section_title: New York City
section_title: Comments from the Department of Homeland Security
section_title: Comments from the Substance Abuse and Mental Health Services Administration
section_title: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
paragraphs: Linda Calbom, (202) 512-8341.
section_title: Acknowledgments
paragraphs: Robert Owens (Assistant Director), Donald Neff (Auditor-in-Charge), Lisa  Crye, Edward Tanaka, and Brooke Whittaker made key contributions to  this report.