Homeland Security: DHS Needs Better Project Information and Coordination among Four Overlapping Grant Programs
Published: 2012-02-28T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: 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.
section_title: What GAO Found
paragraphs: 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 recogized 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.
section_title: What GAO Recommends
paragraphs: 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.

section_title: Letter
paragraphs: 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. DHS distributed approximately $20.3  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.
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  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), Biannual Strategy  Implementation Reports (BSIR), and other FEMA files, such as  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, along with grant  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, various members of Urban Area Working Groups (UAWG),  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.
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  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.
We conducted this performance audit from October 2010 through  February 2012 in accordance with generally accepted government  auditing standards. 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.
subsections: section_title: Background
subsections: section_title: Overview of DHS Preparedness Grant Programs
paragraphs: This work was done in conjunction with a separate review of the Port Security Grant  Program. See GAO-12-47. and Training. However, since its creation in April 2007, FEMA’s GPD has  been responsible for the program management of DHS’s preparedness  grants. 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.
section_title: Grant Funding for Preparedness Programs
paragraphs: From fiscal years 2002 through 2011, DHS distributed approximately  $20.3 billion through four grant programs: SHSP, UASI, PSGP, and  TSGP. See table 1 for a breakdown of the funding for these programs.
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.
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,  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.
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  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.
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. FEMA  officials noted that the National Preparedness System affirms the all- hazards risk-based approach to national preparedness. 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  Protection Plan. 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.
section_title: Overlap and Other Factors Increase the Risk of Duplication among Grant Programs
subsections: section_title: Grant Programs Have Similar Goals, Fund Similar Projects, and Exist in the Same Urban Areas, Which Increases the Risk of Duplication
paragraphs: 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  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   However, many jurisdictions within designated  risk of terrorist attack.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.
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. 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.
GAO-11-318SP.
Urban Areas Security  Initiative (UASI)  UASI provides federal  assistance to address the  unique needs of high- threat, 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.
Port Security Grant  Program (PSGP)  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.
Transit Security Grant  Program (TSGP)  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.
SAA/ 50 states, DC, and  territories.
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. allocate UASI funds  to port and transit  stakeholders  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.  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.
subsections: section_title: Differences in Administrative Processes among the Four Grant Programs Result in Varied Levels of Information on Which Award Decisions Are Based
paragraphs: 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.
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, and because of the thousands of individual  projects that comprise these programs, FEMA relies on the SAAs to  administer the awards to smaller entities.
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). states’ capacities to effectively administer and coordinate their grants vary  considerably.
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.
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. 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.
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   The  2007 through 2010 were selected by regional working groups. 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.
The regional working groups choose projects for the highest risk Tier 1 regions. The  remaining transit regions’—Tier 2 regions—projects are fully competitive.
Similarly, the USCG, and in particular the Captain of the Port, 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, 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. Thus, for these projects, FEMA is  more involved and has greater information on which to base award  decisions.
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–– 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. 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 local- level 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.
section_title: FEMA Makes Award Decisions Using Varying Levels of Information Which Contributes to the Risk of Funding Duplicative Projects
paragraphs: 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  that the extent to which individuals actually receive the same services  from these programs is unknown due to program data limitations. 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.
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. 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  format meet these statutory requirements, albeit at “a high summary  level.”
section_title: FEMA Is Considering Additional Action and Taking Steps to Enhance Grant Information, but Further Efforts Are Needed to Avoid the Risk of Duplication
paragraphs: 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. 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.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.
If this recommendation is implemented, the policy of  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  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. 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.
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.
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.
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  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 project- level 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. 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.
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. 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.
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.
We believe that the recommendation of the FEMA report to better use  more specific project-level data through the BSIR, 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.
section_title: Enhanced Federal Coordination Could Help Reduce the Risk of Duplication
paragraphs: 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  spending at the local and federal levels.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.
The Director of GPD’s  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  system was included as a best practice in the OIG’s 2011 audit of New  Jersey’s grant programs.
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  grant programs and outline roles and responsibilities for coordinating  applications across grant programs.
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.
section_title: Some Performance Measures Exist for Individual Grant Programs, but Work Remains to Assess Grant Effectiveness
subsections: section_title: DHS Has Some Performance Measures, but Until Additional Measures Are Implemented It Cannot Assess Grant Effectiveness
paragraphs: 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 center analysts that require secret  clearances that have them (or have submitted requests for them); (2) the  percentage of SHSP and UASI funded personnel who are engaged in the  Nationwide Suspicious Activity Reporting Initiative 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.
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. 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.
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).
Initiative description  The Redundancy Elimination  and Enhanced Performance for  Preparedness Grants Actdirected the Administrator of  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.
Expected result  Three to seven  proposed measures and  an implementation  roadmap.
Status  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.
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.
For more information about FEMA’s efforts to measure the effectiveness of the PSGP, see  GAO-12-47.
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.
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. Further, senior FEMA officials have noted 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,  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. 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.
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.
section_title: DHS Has Initiatives under Way to Evaluate Overall Effectiveness across Grant Programs, but Has Not Completed These Efforts
paragraphs: 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.
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  nation as a whole has improved and to better ensure the effective use of  scarce resources.
section_title: Conclusions
paragraphs: 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  have reasonable assurance that these measures will be implemented in a  timely way to help assess the programs’ effectiveness.
section_title: Recommendations for Executive Action
paragraphs: 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.
section_title: Agency Comments and Our Evaluation
paragraphs: 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:
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  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.
section_title: Appendix I: FEMA Grants Portfolio
paragraphs: Appendix I: FEMA Grants Portfolio 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.
section_title: Appendix II: Comments from the Department of Homeland Security
section_title: Appendix III: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: 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.