Transit Security Grant Program
DHS Allocates Grants Based on Risk, but Its Risk Methodology, Management Controls, and Grant Oversight Can Be Strengthened
GAO-09-491, Jul 8, 2009
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From fiscal years 2006 through 2008, the Department of Homeland Security (DHS) has allocated about $755 million dollars to transit agencies through its Transit Security Grant Program (TSGP) to protect transit systems and the public from terrorist attacks. GAO was asked to evaluate the extent to which (1) TSGP funds are allocated and awarded based on risk; (2) DHS has allocated, awarded, and distributed TSGP grants in accordance with statutory deadlines and leading practices for collaborating agencies; and (3) DHS has evaluated the effectiveness of the TSGP and its investments. To address these objectives, GAO reviewed the TSGP risk model, fund allocation methodology and program documents, such as TSGP guidance, and interviewed DHS and transit officials, among other steps.
DHS has used a risk analysis model to allocate TSGP funding and award grants to higher-risk transit agencies, although transit agency officials have expressed concerns about changes that have occurred since the TSGP's inception, such as revised priorities. The TSGP risk model includes all three elements of risk--threat, vulnerability, and consequence--but can be strengthened by measuring variations in vulnerability. DHS has held vulnerability constant, which limits the model's overall ability to assess risk and more precisely allocate funds. Although the Transportation Security Administration (TSA) allocated about 90 percent of funding to the highest-risk agencies, lower-risk agency awards were based on other factors in addition to risk. In addition, TSA has revised the TSGP's approach, methodology and funding priorities each year since 2006. These changes have raised predictability and flexibility concerns among transit agencies because they make engaging in long-term planning difficult. DHS met the statutory timeline requirements for allocating and awarding grants, but the two agencies that manage the TSGP--TSA and Federal Emergency Management Agency (FEMA)--lack defined roles and responsibilities, and only 3 percent of the funds awarded for fiscal years 2006 through 2008 have been spent as of February 2009. There is no documentation articulating the roles and responsibilities of the agencies, and grant information has not been passed between the two agencies which affected TSA's ability to share grant status information with transit agencies. DHS met statutory deadlines for releasing grant guidance and acting upon applications, but management and resource issues have resulted in delays in approving projects and making funds available, including (1) lengthy project negotiations between transit agencies and TSA; (2) a backlog of required environmental reviews; and (3) a reported lack of personnel to conduct required reviews. As a result, according to FEMA records, as of February 2009, transit agencies have spent about $21 million of the $755 million that has been awarded for fiscal years 2006 through 2008. This spending rate is, in part, caused by agencies receiving authorization to spend grant dollars late in the grant period. Despite concerns over delays, FEMA has not communicated time frames for providing funding. In April 2004, GAO reported that timely grant awards are imperative to provide intended benefits. DHS has reported taking some actions to address delays, including shortening project approval times and hiring staff, but the effectiveness of these efforts is unknown. Although FEMA has taken initial efforts to develop measures to assess the effectiveness of its grant programs, TSA and FEMA lack a plan and related milestones for developing measures specifically for the TSGP, and thus DHS does not have the capability to measure the effectiveness of the program or its investments. Without such a plan, it will be difficult for TSA and FEMA to provide reasonable assurance that measures are being developed to assess the effectiveness of the program as intended. While FEMA is responsible for the financial controls and audits of the TSGP, it does not have a mechanism to systematically collect data and track grant projects throughout the grant process. As a result, FEMA cannot assess whether awards are timely or funds are being used effectively to reduce risk and increase transit system security
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Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
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Recommendations for Executive Action
Recommendation: To help strengthen the implementation and oversight of the TSGP, the Secretary of Homeland Security should direct FEMA to establish a time frame for revising environmental regulations to be more inclusive of nondisaster homeland security grant programs.
Agency Affected: Department of Homeland Security
Status: Closed - Implemented
Comments: DHS implemented a new policy for EHP reviews in July 2010 known as the Programmatic Environmental Assessment (PEA). The PEA is specific to homeland security grant programs and categorizes grant projects into three groups?based on the expected environmental impact of that project. The implementation of the PEA allowed FEMA to tailor the EHP review based on project category.
Recommendation: To help strengthen the implementation and oversight of the TSGP, and to strengthen the administration, oversight, and internal controls of the TSGP, the Secretary of Homeland Security should direct TSA and FEMA to collaborate to develop a plan and milestones for measuring the effectiveness of the TSGP and its administration.
Agency Affected: Department of Homeland Security
Status: Open
Comments: Remains Open: According to FEMA officials in July 2011, GPD and NPD are working together to develop a robust set of performance measures that will capture how well all the GPD grants are managed and the overall effectiveness of the TSGP. These new measures will be incorporated into the FY12 grant guidance. However, in July 2011, the Director of NPAD could not provide draft measures or a specific timeframe for when TSGP measures might be completed.
Recommendation: To help strengthen the implementation and oversight of the TSGP, and to strengthen the administration, oversight, and internal controls of the TSGP, the Secretary of Homeland Security should direct TSA and FEMA to develop an interim solution to systematically collect data and track grant activities until FEMA's grants management system can perform these functions, and ensure that both agencies have access to these data.
Agency Affected: Department of Homeland Security
Status: Open
Comments: Remains Open: FEMA released the ND-Grants system in conjunction with FY11 guidance in May 2011. While ND-Grants was a step in the right direction, much of its functionality will need to be phased in over the course of several years. Until it is fully implemented, FEMA will still have difficulty tracking the lifecycle of TSGP grants.
Recommendation: To help strengthen the implementation and oversight of the TSGP, and to strengthen the administration, oversight, and internal controls of the TSGP, the Secretary of Homeland Security should direct TSA and FEMA to develop a cost-effective plan for monitoring the use of grant funds once projects have been implemented, including a strategy for leveraging resources that could allow TSA surface transportation security inspectors to assist in monitoring the grant projects to ensure that the projects meet the security requirements set out in TSGP guidance.
Agency Affected: Department of Homeland Security
Status: Open
Comments: Remains Open: In February 2011, Senior TSA officials noted that TSA surface inspectors had not been involved in any monitoring activities.
Recommendation: To help strengthen the implementation and oversight of the TSGP, and to strengthen the administration, oversight, and internal controls of the TSGP, the Secretary of Homeland Security should direct TSA and FEMA to define TSA's and FEMA's respective roles and responsibilities for managing the TSGP in a memorandum of understanding (MOU) or similar document.
Agency Affected: Department of Homeland Security
Status: Closed - Implemented
Comments: Closed: In March 2011, TSA and FEMA completed a Memorandum of Agreement (MOA) regarding the Administration of surface transportation security grant programs.
Recommendation: To help strengthen the implementation and oversight of the TSGP, and to strengthen DHS's methodology for determining risk, the Secretary of Homeland Security should develop a cost-effective method for incorporating vulnerability information into future iterations of the TSGP risk model.
Agency Affected: Department of Homeland Security
Status: Open
Comments: Remains Open: A senior TSA official noted in August 2011 that there were no changes to the TSGP risk model for FY11 including for vulnerability. She noted that with all the other changes to the program for FY11, they decided to keep the risk model the same. She added that they are looking into updating for FY12 to enhance the model and make it consistent with HSGP and PSGP.
Recommendation: To help strengthen the implementation and oversight of the TSGP, the Secretary of Homeland Security should direct FEMA to establish and communicate time frames for making funds available to transit agencies once FEMA receives project approvals from TSA.
Agency Affected: Department of Homeland Security
Status: Closed - Implemented
Comments: FEMA has introduced timeframes for the specific steps in the environmental review process, making it easier for grantees to know when they can expect the EHP process to be complete. However, until FEMA is better able to track projects internally, there will still be some uncertainty about how long it is before grantees will receive their funds.








