Disaster Recovery:

Additional Actions Would Improve Data Quality and Timeliness of FEMA's Public Assistance Appeals Processing

GAO-18-143: Published: Dec 15, 2017. Publicly Released: Jan 16, 2018.

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Allison Bawden
(202) 512-6806
bawdena@gao.gov

 

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In both 2016 and 2017, 15 U.S. disasters resulted in losses exceeding $1 billion each. To help recover, state and local governments may apply to FEMA for grants for debris removal, public facility repairs, and similar activities.

Applicants have two chances to appeal grant decisions. However, we found that, from 2014 to July 2017, FEMA processed only 9% of first-level and 11% of second-level appeals within its 90-day limit.

Although FEMA has improved management of the appeals process in the last few years, it still faces challenges. Among other things, we recommended measures to more accurately track appeals and to develop FEMA's workforce.

Summary of FEMA's First- and Second-Level Public Assistance Appeals Process

This graphic summarizes the first- and second-level appeals process under FEMA’s Public Assistance program.

This graphic summarizes the first- and second-level appeals process under FEMA’s Public Assistance program.

Additional Materials:

Contact:

Allison Bawden
(202) 512-6806
bawdena@gao.gov

 

Office of Public Affairs
(202) 512-4800
youngc1@gao.gov

What GAO Found

Weaknesses in the quality of Federal Emergency Management Agency's (FEMA) Public Assistance (PA) appeals data limit its ability to oversee the appeals process. For example, FEMA's data are inaccurate and incomplete because regional offices do not consistently track first-level appeals and FEMA does not have processes to ensure data quality. When GAO discussed these weaknesses with FEMA officials, they acknowledged them and provided GAO with corrected data for January 2014 through July 2017. GAO's analyses of the corrected data show fluctuations in the appeal inventory from year to year depending on the number of disasters declared and delays in processing. For example, as shown in the figure, only 9 percent of first-level and 11 percent of second-level appeals were processed within the 90-day statutory timeframe.

Processing Times for Decided Appeals, Based on Appeals FEMA Received between January 2014 and July 2017

Processing Times for Decided Appeals, Based on Appeals FEMA Received between January 2014 and July 2017

FEMA has taken steps to improve its management of the appeals process—including issues that GAO and the Department of Homeland Security's Office of Inspector General identified in 2008 and 2011. For example, FEMA increased its appeal staffing levels and developed standard operating procedures. Despite these efforts, FEMA continued to face a number of workforce challenges that contributed to processing delays, such as staff vacancies, staff turnover, and delays in training. FEMA has not developed a workforce staffing plan to identify hiring, training, and retention needs across its headquarters and regional offices, though FEMA officials acknowledge the potential benefits of having such a plan and stated that they are focused on filling vacancies. In the absence of a workforce plan, FEMA will continue to experience workforce challenges that could further contribute to delays in processing appeals.

FEMA has not established goals and measures for assessing first-level appeals processing performance, but has done so for second-level appeals. FEMA views establishing these first-level goals and measures as the responsibility of its regional offices. Without goals and measures, FEMA is limited in its ability to assess the efficiency and effectiveness of its overall appeals process and identify and address weaknesses that may lead to delays in making appeal decisions.

Why GAO Did This Study

In both 2016 and 2017, 15 separate U.S. disasters resulted in losses exceeding $1 billion each. FEMA provides PA grants to state and local governments to help communities recover from such disasters. If applicants disagree with FEMA's decision on their PA grant application, they have two chances to appeal: a first-level appeal to be decided by the relevant FEMA regional office and, if denied, a second-level appeal to be decided within FEMA's Recovery Directorate. Each is subject to a 90-day statutory processing timeframe.

GAO was asked to review FEMA's appeals process. This report examines: (1) the extent to which FEMA ensures the quality of its appeals data and what these data show about PA appeals inventory and timeliness; (2) what steps FEMA has taken to improve its management of the appeals process and what challenges, if any, remain; and (3) the extent to which FEMA developed goals and measures to assess program performance. GAO analyzed FEMA policies, procedures, and data on appeals and interviewed officials from headquarters and from regional offices with the highest number of pending appeals. GAO also spoke to state officials from the two states within each of the three regions with the highest number of pending appeals.

What GAO Recommends

GAO is making four recommendations, including that FEMA implement a consistent approach for tracking appeals and ensuring data quality, develop a workforce plan, and develop measurable goals for processing first-level appeals. FEMA concurred with all four recommendations.

For more information, contact Allison Bawden at (202) 512-6806 or bawdena@gao.gov.

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: Following the publication of our report, FEMA reported that in June 2018, PAAB implemented a number of actions to address this recommendation. These actions include developing a checklist for PAAB appeals staff and FEMA regional appeals staff to use to review the completeness of first-level appeals data in PAAB's first-level appeals tracker. According to FEMA, this action ensures that all mandatory data fields within PAAB's first-level appeals tracker are completed by regional appeals staff. Using the checklist, regional appeals staff and PAAB appeals staff review the completeness of first-level appeals data in PAAB's own first-level appeals tracker. Regional appeals staff input first-level appeals data that had been missing from mandatory data fields within PAAB's first-level appeals tracker. PAAB appeals staff use quarterly telephone conferences with regional appeals staff to review progress made toward ensuring the completeness of first-level appeals data within PAAB's and the region's first-level appeals trackers. In addition, PAAB has developed additional content in its appeals staff training materials that highlights the importance of data integrity and accuracy in the processing of PA appeals. The training sessions incorporating this additional content were delivered to appeals staff from 9 of FEMA's ten regional offices over the past year. FEMA indicated that it planned to administer training to the remaining regional office in 2019.

    Recommendation: The Assistant Administrator for Recovery should design and implement the necessary processes and procedures to ensure a uniform and consistent approach for tracking first-level appeals data to better integrate regional trackers with the Public Assistance Appeals and Audits Branch's (PAAB) own first-level appeals tracker. (Recommendation 1)

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

  2. Status: Closed - Implemented

    Comments: Following publication of our report, FEMA reported that in May 2018 PAAB began collecting monthly baseline data from PAAB's First-Level Appeals SharePoint tracker to check for erroneous and/or inconsistent data entries. According to FEMA, as part of this effort, PAAB tracks changes in the number of errors and/or inconsistencies in the first-level appeals data. On at least a quarterly basis, PAAB transmits to FEMA regional offices a First-Level Appeals Tracker Data Check Report that contains monthly snapshots of the number and type of errors and inconsistencies associated with first-level appeals data submitted by regional offices. Regional offices then use the First-Level Appeals Tracker Data Check Report to rectify first-level appeals data errors and inconsistencies. In addition, FEMA reported that PAAB has developed and included additional content that highlights the importance of data integrity in its certified appeals analyst training.

    Recommendation: The Assistant Administrator for Recovery should design and implement the necessary controls to ensure the quality of the first-level appeals data collected at and reported from the regional offices to PAAB. (Recommendation 2)

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

  3. Status: Open

    Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, to prepare for the potential production of a detailed regional workforce plan, PAAB (Public Assistance Appeals Branch) has been collecting information from the Regions regarding the percentage of time (on a monthly basis) that each Regional appeals analyst has worked on appeals. In August 2018, PAAB shared with the Regions its preliminary analysis of this information and asked the Regions to provide feedback regarding the methods used to analyze this information. PAAB said that they intend to assess first-level appeals' regional inventory and timeliness issues, as well as the work needed to prepare and finalize a detailed regional workforce plan. According to FEMA, PAAB is also analyzing second-level appeal inventory and timeliness, and will continue to monitor second-level appeal timeliness. In May 2019, FEMA sent us additional information and documentation involving their analysis of appeal inventory and timeliness. As of October 2019, we are evaluating the information provided by FEMA and will be meeting with them to discuss whether they have fully addressed this recommendation.

    Recommendation: The Assistant Administrator for Recovery should develop a detailed workforce plan that documents steps for hiring, training, and retaining key appeals staff. The plan should also address staff transitions resulting from deployments to disasters. (Recommendation 3)

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

  4. Status: Open

    Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, in July 2018, the Public Assistance Division and PAAB transmitted a survey to the Regions containing questions about how each Region establishes goals for processing first-level appeals and how each Region measures and monitors performance with respect to those goals. Thereafter, the Regions provided survey responses to PAAB. According to FEMA, PAAB has begun analyzing the survey responses for the purpose of enabling FEMA's Associate Administrator for the Office of Response and Recovery and FEMA's Chief of Staff to work with all FEMA Regional Administrators to establish and use goals and measures for processing first-level PA appeals to monitor performance and report on progress. In September 2019, FEMA sent us additional information and documentation involving these efforts. We are evaluating the information and documentation provided by FEMA and will be meeting with them to discuss whether they have fully addressed this recommendation.

    Recommendation: The Assistant Administrator for Recovery should work with Regional Administrators in all 10 regional offices, to establish and use goals and measures for processing first-level PA appeals to monitor performance and report on progress. (Recommendation 4)

    Agency Affected: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency

 

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