FEMA preparedness grant management is composed of different financial and programmatic management functions. FEMA created GPD in April 2007, to consolidate oversight of all FEMA grants. GPD, in FEMA headquarters, provides subject matter expertise in response to regional office and stakeholder inquiries; develops grant guidance; and delivers policy, training, and systems and data analysis. The 10 FEMA regions are responsible for financial monitoring, implementing corrective action plans, as well as other follow-up activities with grantees. Financial management functions include monitoring grantee expenditures, amending financial terms of grants, and closing out grants. Program management includes developing grant application packages creating program standards, and monitoring grantee activities to ensure alignment with homeland security strategies. FEMA’s regional offices have program management responsibility for various legacy programs primarily because they managed those programs prior to the establishment of GPD. The largest of these legacy programs is the Emergency Management Performance Grant (EMPG), which provided over $350 million in fiscal year 2015 to assist local, tribal, territorial, and state governments in enhancing and sustaining all-hazards emergency management capabilities. GPD has management responsibility for the Homeland Security Grant Program, which provides more than $1 billion annually to help strengthen the nation against risks associated with acts of terrorism and other catastrophic events. FEMA works with state and local stakeholders to implement NIMS, a comprehensive, national approach to incident management that is applicable at all jurisdictional levels and across functional disciplines and the full spectrum of potential incidents, hazards, and impacts, regardless of size, location, or complexity. DHS established NIMS in 2004 to improve coordination and cooperation between public and private entities in a variety of incident management activities and provide a common standard for overall incident management. NIMS implementation consists of training, using a standardized way of defining and categorizing emergency resources known as resource typing, and incorporating a standardized organizational emergency response structure called the Incident Command System into emergency management plans, policies and procedures, among other things. States, tribes, and local jurisdictions are required to adopt and self-assess their level of NIMS implementation, and certify their compliance and report it to FEMA through the URT in order to receive preparedness grant funding from FEMA. Additionally, states receiving preparedness grants are required to develop and maintain an exercise program consistent to the degree practical with HSEEP in support of the National Exercise Program. HSEEP exercises identify exercise objectives and align them to FEMA’s 32 “core capabilities” for evaluation during the exercise. In order to report on the required exercises, states receiving preparedness grants are required to prepare after-action reports—evaluations of performance—on core capabilities assessed in the exercise, and to submit those to FEMA. FEMA established the NIC in 2004. The NIC, a division of FEMA’s National Preparedness Directorate, is responsible for the ongoing management and maintenance of NIMS, including developing guidance to define and categorize the resources and job position qualifications requested, deployed, and used in incidents. Specifically, the NIC is to coordinate with state and local stakeholders to develop national standards, guidelines, and protocols for incident management. In 2008, FEMA established new regional positions for federal preparedness coordinators (FPC), who direct and coordinate the activities of each regional national preparedness division to ensure regional implementation of national preparedness programs, policies, goals, and objectives. FPCs are to evaluate preparedness program activities to assess their effectiveness; changes in risk or capability; and the performance of preparedness program activities including after-action reports, training evaluations, lessons learned, and corrective actions. For example, FPCs are responsible for monitoring NIMS compliance and implementation, in addition to other national preparedness initiatives. Further, FPCs are to proactively engage stakeholders and acquire an understanding of their preparedness efforts and also assist in the planning, design, execution, and evaluation of federal, state, local, and regional exercises. FEMA regional NIMS coordinators act as subject matter experts regarding NIMS for the local, state, territorial, and tribal nation governments within their FEMA regions, as well as for the FEMA regional administrator and staff. The Post-Katrina Act requires that each FEMA regional administrator establish a RAC with members from state, local, and tribal entities to provide advice on emergency management issues specific to the region. While the Post-Katrina Act does not specify how many members a RAC should have, the law states that a state, local, or tribal government located within the geographic area served by the regional office may nominate officials, including emergency managers, to serve as members. Each of the 10 FEMA regional offices established a RAC after the Post- Katrina Act was enacted in 2006. In August 2011, FEMA developed a RAC charter template that each of the regional offices voluntarily adopted; the charters require that RACs meet twice annually in order to provide the types of advice on emergency preparedness in their regions to the FEMA regional administrators listed in the Post-Katrina Act. In addition to the RACs, the Post-Katrina Act also required that FEMA establish the National Advisory Council (NAC) to ensure effective and ongoing coordination of federal preparedness efforts, among other things. The NAC advises the FEMA Administrator on all aspects of emergency management, and incorporates state, local, and tribal governments; nonprofit; and private sector input in the development and revision of the National Preparedness Goal, the National Preparedness System, the National Incident Management System, and other related plans and strategies. FEMA’s 10 regional offices are the principal conduit for delivery of preparedness programs and activities to state, tribal, and local partners; non-governmental organizations; the private sector; and citizens. Such preparedness activities include, among other things, stakeholder coordination and information sharing, consulting, planning support, capability assessments and reporting, exercise performance and evaluation, and internal and external training. Figure 1 shows FEMA’s 10 regions and the states and territories that compose each region (the District of Columbia is in Region III). Currently FEMA uses a hybrid management model for preparedness grant programs, with shared responsibilities between headquarters and the regions. In October 2009, in response to a congressional request, the National Academy of Public Administration (NAPA) conducted a study and recommended that FEMA transfer all preparedness grant authorities to its regional offices. Similarly, in May 2010, FEMA’s Office of Policy and Program Analysis (OPPA) reported that FEMA’s hybrid grants management model created significant inconsistencies in managing preparedness grants, and recommended that programmatic management functions for preparedness grants should be transferred to the regional offices. In September 2010, GPD’s Regional Implementation of Grants (RIG) task force also reported that programmatic grant management functions for grants should be moved to the 10 regional offices, because of considerations of customer service, efficiency, people, processes, and systems. In July 2011, we reported that GPD’s efforts to regionalize management responsibilities for preparedness grants were consistent with internal control standards. On the basis of the results of our review of FEMA’s plans and efforts to regionalize grant management functions, we did not make recommendations at that time. FEMA’s Deputy Administrator for Protection and National Preparedness, in consultation with FEMA’s Administrator, decided in early 2012 against pursuing further regionalization of grant management functions, according to FEMA’s Assistant Administrator for Grant Programs. The Assistant Administrator said their decision was based on, among other things, estimates that the costs of regionalization would be greater than the annual savings identified in the earlier OPPA study and FEMA management’s belief that risks associated with the change, such as inconsistent program implementation across the regions, outweighed the potential benefits. As a result, FEMA continues to use its hybrid management model for preparedness grant programs, with shared responsibilities between headquarters and the regions. Long-standing challenges associated with the separation of management functions under the hybrid model of grant management, including the lack of coordination of grant-monitoring visits, and coordination and implementation of guidance provided by headquarters officials to state officials, continue to create challenges. In 2010, GPD’s RIG task force report cited examples of how programmatic and financial monitoring visits, conducted by FEMA GPD staff and regional offices respectively, occurred independently of one another and were disruptive to the state emergency management agency’s day-to-day operations. In response to the lack of coordination in monitoring site visits, GPD’s Deputy Assistant Administrator sent a memorandum to staff in 2011 citing concerns that it had become “apparent GPD HQ staff continue to do program monitoring visits without proper notification to the regional offices” and directing that headquarters personnel conduct all monitoring visits in conjunction with regional staff, changing the dates of any planned headquarters visits to accommodate regional staff schedules. While the memorandum called for disciplinary action against any GPD personnel who did not follow the directive, GPD officials did not identify any instances where disciplinary action had been taken. We also found challenges in the coordination of site visits. Officials in 3 of 9 states we talked with on grants issues stated that monitoring visits from FEMA GPD and the regional offices do not appear to be well coordinated. For example, officials in 1 state said that in September 2014, GPD and regional grants staff conducted site visits during the same week; however, neither the GPD staff nor the regional staff knew that the other was conducting a monitoring visit that week. The state officials stated that they had to leave one monitoring meeting early to go to another monitoring meeting by a different group of grant management staff. Similarly, regional grants officials in 2 of the 4 regions we visited said in 2015 that they may or may not receive information on monitoring activities undertaken by GPD officials, depending on who is conducting the monitoring activities.