Recommendation: To better ensure FEMA's regional activities effectively support individuals with disabilities, the Secretary of Homeland Security should direct the FEMA Administrator to take steps to establish written procedures for how regions should involve the Office of Disability Integration and Coordination in clarifying disability integration staff's roles, evaluating staff performance, and setting expectations for how staff communicate with headquarters and the regions.

Agency: Department of Homeland Security
Status: Open

Comments: FEMA agreed with this recommendation and FEMA's Office of Disability Integration and Coordination (ODIC) is in the process of establishing a working group that will clarify and codify the roles, responsibilities, and expectations among the various agency offices and personnel involved in carrying out the agency's disability integration mission. In January 2018, FEMA reported that it had created Regional Integration Teams in the regions to improve the efficiency and efficacy of mission delivery. In August 2018, ODIC reported its goal to meet with Regional Administrators and other senior leaders across the agency by the end of CY 2018 to refine the role for disability integration staff. The reported intent of refining the role is to better align it with the FEMA Administrator's goal of empowering emergency managers in states, localities, tribes, and territories. In June 2019, ODIC officials reported plans to convene a workgroup to examine the role of the Regional Disability Integration Specialist, including their reporting chain and their roles and responsibilities in each of FEMA's ten regions. The workgroup will meet over two months and develop recommendations to be considered by FEMA's Chief of Staff by August 23, 2019. GAO is encouraged by FEMA's efforts to engage Regional Administrators and other senior leaders in its refinement of the role of disability integration staff, and awaits evidence of FEMA establishing documentation of the agency's procedures for carrying out its disability integration mission.

Recommendation: To help ensure its key training on incorporating access and functional needs into emergency planning reaches a sufficiently wide audience, the Secretary should direct the FEMA Administrator to collect information about the potential pool of participants, set general goals for the number of state and local emergency managers that will take this course, and implement the delivery methods needed to meet these goals.

Agency: Department of Homeland Security
Status: Open

Comments: FEMA agreed with this recommendation and reported that it will work with its regional staff to map potential training participants in each state and set goals for delivery of the course to state and local emergency managers. The agency also reported that it may be able to use data in the State Preparedness Report and states' self-reporting on the need for training on integrating the needs of people with access and functional needs into emergency management. As of January 2018, the Office of Disability Integration and Coordination reported plans to hire a permanent staff person to review, assess, and recommend how FEMA should incorporate disability into all internal and external training. In August 2018, FEMA reported hiring a new Program and Policy Branch Chief in July 2018, and noted that this individual will formulate a plan to incorporate the needs of people with disabilities into internal and external training over several weeks. However, FEMA did not address whether this individual will seek information about the potential pool of external participants, or set goals for the number of state and local emergency managers who could participate in external training. FEMA also reported providing just-in-time training in the field to support field staff in providing services to people with disabilities. The agency anticipates completing these efforts by December 31, 2019 and we will consider closing this recommendation when the agency can document it has addressed the recommendation.

Recommendation: Given DOT's new discretionary grant programs and similar challenges we have found with previous DOT programs, the Secretary of Transportation should issue a directive that governs department-wide and modal administration discretionary grant programs. Such a directive should include requirements to: (1) develop a plan for evaluating project proposals in advance of issuing a notice of funding availability that defines the stages of the process, including how the process will be overseen to ensure a consistent review of applications; (2) document key decisions, including the reason for any rating changes and the officials responsible for those changes, and how high-level concerns raised during the process were addressed; and (3) align stated program purpose and policy priorities with the evaluation and selection process.

Agency: Department of Transportation
Status: Open
Priority recommendation

Comments: DOT concurred with this recommendation and, in March 2019, issued a memo directing secretarial offices and operating administrations involved in awarding discretionary grants to implement our recommendations and to include them in their policies and procedures. In June 2019, we reported that, due to a number of issues, it is unclear how this action will address our recommendation. For example, we found that the memo was essentially limited to a repetition of our recommendation and that DOT did not take steps to ensure that the various affected offices consistently interpret and implement the recommendation. DOT officials told us they wanted to provide the affected offices flexibility to implement the recommendation, but that the Department would assess the need for additional guidance based on revisions to its Financial Assistance Guidance Manual. DOT completed these revisions effective January 2020, and all affected offices are expected to complete developing their policies and procedures by May 2020. We will continue to monitor the Department's actions and assess the extent to which they address our recommendation.

Recommendation: To help NMFS and the Councils incorporate climate information into the fisheries management process and better manage climate-related risks, the Secretary of Commerce should direct NOAA's Assistant Administrator for Fisheries to, in finalizing the regional action plans for implementing the NOAA Fisheries Climate Science Strategy, (1) incorporate the key attributes associated with successful performance measures in the final performance measures developed for the plans and (2) assess whether agency-wide performance measures may be needed to determine the extent to which the objectives of the Strategy overall are being achieved, and develop such measures, as appropriate, that incorporate the key attributes of successful performance measures.

Agency: Department of Commerce
Status: Open

Comments: The Department of Commerce and NOAA agreed with this recommendation. In October 2019, NOAA provided GAO with a written update on actions taken in response to this recommendation, including the development of agency-wide metrics for the NOAA Fisheries Climate Science Strategy. In September 2020, NOAA informed GAO that it plans to update the performance metrics for the regional action plans to include our key attributes in 2021. We will continue to monitor NOAA's progress on this effort and will review the updated performance metrics to assess the extent to which the agency has addressed our recommendation.

Recommendation: To enable a more effective approach in working with states to adopt the NDRF, the Secretary of Homeland Security should direct the Administrator of FEMA to clarify with regional offices and Federal Disaster Recovery Coordinators (FDRCs) the role of the regional implementation plans in FDRC performance plans and how they will be used to assess NDRF regional implementation efforts.

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, to achieve greater integration of FEMA's field leadership components, FEMA's Field Operations Directorate (FOD) convened a Field Leadership Working Group of senior subject matter experts to conduct a mission analysis of FEMA's Field Leadership function (which includes Federal Disaster Recovery Coordinators as well as Federal Coordinating Officers and Incident Management Assistance Teams team leads). According to FEMA, the Working Group was preparing a Field Leader Manual (FLM) for review by FOD leadership. FEMA officials told us that the 2018 Hurricane season led to the deployment of many of FEMA's FOD leaders. These deployments allowed FOD leaders to experience first-hand the connection between regional implementation plans and FDRC performance plans and FEMA said that this knowledge is being integrated into edits of the FLM. In February 2020, FEMA told us that the FOD leadership responsible for the oversight of FDRCs is still determining the timeline to update the FLM based on a realignment of the Field Leadership Cadre. This update will integrate the Federal Coordinating Officers (FCOs) and FDRCs into a single FCO title with professional development specializations in response or recovery. This integration will support all FCOs in having a common baseline of training and experience in both response and recovery. In an August 2020 update, FEMA stated that while they continue to work toward implementing this recommendation, the FOD is currently focused on COVID-19 response efforts and planning for a more severe than average hurricane season. We will continue to monitor FEMA's efforts to see what additional actions the agency takes in response to this recommendation.

Recommendation: To enable a more effective approach in working with states to adopt the NDRF, the Secretary of Homeland Security should direct the Administrator of FEMA to align the annual FDRC performance expectations with clearly defined organizational goals and priorities, consistent with key management practices.

Agency: Department of Homeland Security
Status: Open

Comments: DHS concurred with this recommendation and said it would take steps to implement it. According to FEMA, the Field Leadership Working Group will implement the elements of this recommendation alongside efforts to clarify the role of the regional National Disaster Recovery Framework implementation plans. FEMA told us that the 2018 Hurricane season led to the deployment of many of FEMA's field leaders and these deployments allowed leaders to experience first-hand the connection between FDRC performance expectations and FEMA's organizational goals. According to FEMA, this knowledge is being integrated into edits of the Field Leader Manual (FLM). In February 2020, FEMA told us the FOD leadership responsible for the oversight of FDRCs is working with their partners in FEMA's Recovery and Resilience sections, as well as with the Regions to define performance expectations for steady-state recovery planning and preparedness under the NDRF. This will include identifying who is functionally accountable for these activities, any gaps, and best practices across Regions. In an August 2020 update, FEMA stated that while they continue to work toward implementing this recommendation, the FOD is currently focused on COVID-19 response efforts and planning for a more severe than average hurricane season. We will continue to monitor FEMA's efforts to see what additional actions the agency takes in response to this recommendation.

Recommendation: To enable FEMA to and more effectively respond to disasters, the Secretary of Homeland Security should direct the FEMA Administrator to develop a workforce strategy to manage and improve retention that includes a process for systematically gathering attrition data and a plan to retain IMAT Cadre-of On-Call Response Employees.

Agency: Department of Homeland Security
Status: Open

Comments: In August 2019, FEMA provided an update on the status of actions taken in response to our report. As of April 2019, FEMA stated that they are continuing to work on two actions. One, the development of a new organizational structure. FEMA is still refining and assessing the impact of the new IMAT structure. Two, in April 2019, FEMA delivered a new IMAT Program Orientation to nineteen new IMAT members. FEMA plans to analyze the impact of these changes along with attrition information. It plans to develop a high-level blueprint of the actions taken by FEMA to better manage the IMAT program and retain staff. Until completion of the action items, this recommendation will remain open. FEMA officials plan to provide a status update and finalize their efforts by September 2019. As of July 2020, FEMA officials have not completed steps to implement a revised IMAT structure. FEMA anticipates completing several actions by September 2020 and finalizing their plan by December 2020. However, due to COVID-19, the agency may face additional delays in doing so.

Recommendation: To promote forward-looking construction and rebuilding efforts while FEMA phases out most subsidies, the Secretary of the Department of Homeland Security should direct FEMA to consider amending NFIP minimum standards for floodplain management to incorporate, as appropriate, forward-looking standards, similar to the minimum standard adopted by the Hurricane Sandy Rebuilding Task Force.

Agency: Department of Homeland Security
Status: Open

Comments: In August 2019, a FEMA official stated that FEMA intends to implement the recommendation in full eventually, but it is unlikely that it will happen as a cohesive effort in 2020, given other ongoing flood insurance reforms. As of August 2020, the status of this recommendation remains unchanged.

Recommendation: To proactively prepare for oversight of future disaster relief funding, the Director of OMB should develop standard guidance for federal agencies to use in designing internal control plans for disaster relief funding. Such guidance could leverage existing internal control review processes and should include, at a minimum, the following elements: (1) robust criteria for identifying and documenting incremental risks and mitigating controls related to the funding and (2) requirements for documenting the linkage between the incremental risks related to disaster funding and efforts to address known internal control risks.

Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Priority recommendation

Comments: To address the recommendation, OMB should issue guidance on internal control for disaster relief funding, including criteria for identifying additional risks and mitigating controls related to the funding and a requirement to link these incremental risks to ongoing efforts to address known internal control risks. On July 15, 2016, OMB issued the revised Circular No. A-123, Management's Responsibility for Enterprise Risk Management and Internal Control. The Circular requires agencies to implement enterprise risk management, which includes the development of a risk profile that analyzes the risks faced in achieving strategic objectives and identifies options for addressing them. In April 2017, OMB staff stated that they believe that the implementation of enterprise risk management through Circular No. A-123 satisfies the intent our recommendation. Because the responsibility for implementing enterprise risk management lies with agency management, Circular No. A-123 does not include specific guidance for identifying risks related to disaster funding. Further discussion and documentation to support OMB's position that the revised Circular addresses our recommendation will be necessary. The Bipartisan Budget Act of 2018, Sec. 21208(c) requires OMB to issue standard guidance for Federal agencies to use in designing internal control plans for disaster relief funding in order to proactively prepare for oversight of future disaster relief funds. The Act states this guidance shall leverage existing internal control review processes and shall include, at a minimum, (1) robust criteria for identifying and documenting incremental risks and mitigating controls related to the funding, and (2) guidance for documenting the linkage between the incremental risks related to disaster funding and efforts to address known internal control risks. GAO reviewed OMB's actions to implement the law. On June 28, 2019, GAO, 2017 Disaster Relief Oversight: Strategy Needed to Ensure Agencies' Internal Control Plans Provide Sufficient Information, GAO-19-479 (Washington, D.C.: Jun 28, 2019) reported the 2013 recommendation remains open and that we plan to continue monitoring OMB's progress in implementing this priority recommendation. Further, the report stated that OMB did not have an effective strategy to ensure that agencies timely submitted internal control plans; and OMB's Memorandum M-18-14, Implementation of Internal Controls and Grant Expenditures for the Disaster-Related Appropriations lacked specific instructions to agencies on what to include in their internal control plans. As such, a new recommendation was warranted. As of February 2020, OMB has not provided any new status updates for this recommendation.

Recommendation: To increase the efficiency and effectiveness of the process for disaster declarations, the FEMA Administrator should develop and implement a methodology that provides a more comprehensive assessment of a jurisdiction's capability to respond to and recover from a disaster without federal assistance. This should include one or more measures of a jurisdiction's fiscal capacity, such as TTR, and consideration of the jurisdiction's response and recovery capabilities. If FEMA continues to use the PA per capita indicator to assist in identifying a jurisdiction's capabilities to respond to and recover from a disaster, it should adjust the indicator to accurately reflect the annual changes in the U.S. economy since 1986, when the current indicator was first adopted for use. In addition, implementing the adjustment by raising the indicator in steps over several years would give jurisdictions more time to plan for and adjust to the change.

Agency: Department of Homeland Security: Directorate of Emergency Preparedness and Response: Federal Emergency Management Agency
Status: Open
Priority recommendation

Comments: On January 20, 2016, FEMA published an Advanced Notice of Proposed Rulemaking to solicit comments on an option FEMA is considering to establish a disaster deductible, which would require a predetermined level of financial or other commitment from a recipient, generally the state or territorial government, before FEMA would provide assistance under the Public Assistance Program. According to FEMA, the agency received 150 responses during the 60-day public comment period, which ended on March 21, 2016, and used this input to develop a plan for further engagement on a more detailed proposal for public comment. The Supplemental Advanced Notice of Proposed Rulemaking, published on January 12, 2017, provided another opportunity for stakeholder input prior to any changes to the Public Assistance program. This proposal included an explanation of how deductible amounts might be calculated, identified specific credits that states could apply for, and detailed how the deductible would be applied post-declaration. According to FEMA officials, the comments received, in part, raised concerns about the complexity of the proposed deductible model. FEMA agreed with the concerns raised that the proposal was too complicated, and in August 2018, told us that it is no longer pursuing that option. However, FEMA is considering options that leverage similar approaches but does not have an estimated completion date for implementation. On October 5, 2018, the Disaster Recovery Reform Act of 2018 (DRRA), was signed into law. DRRA (section 1239) directs the FEMA Administrator to initiate a rulemaking to update the factors considered when evaluating a request for a Major Disaster Declaration for Public Assistance, specifically the estimated cost of assistance (i.e. the per capita indicator). FEMA is working to implement this provision pursuant to the law, and this effort represents one of the top priorities of the agency; however, the estimated completion date is still "to be determined." Until FEMA implements a new methodology, FEMA will not have an accurate assessment of a jurisdiction's capabilities to respond to and recover from a disaster without federal assistance and runs the risk of recommending that the President award Public Assistance to jurisdictions that have the capability to respond and recover on their own.

Recommendation: To the extent that the CDBG program continues to be the primary vehicle used to provide post-disaster assistance for permanent housing, Congress may wish to consider providing more specific direction regarding the distribution of disaster-related CDBG assistance that states are to provide for homeowners and renters. If Congress wishes to change the proportion of assistance directed to homeowners and rental property owners in future recovery efforts, Congress could, for example, require states to demonstrate to HUD that they are adequately addressing the needs of both homeowners and renters with their CDBG allocation and other resources as a condition for receiving funds. Alternatively, Congress could direct HUD to develop a formula that accounts for the housing needs of both homeowners and renters. Such a formula could be used by states to determine the proportions of their disaster CDBG funds that should be used for housing, specifically rental housing. Further, the formula could also reflect the anticipated production levels of other programs that provide permanent housing assistance, such as the Low-Income Housing Tax Credit program.

Agency: Congress
Status: Open

Comments: Since 1993, Congress has appropriated Community Development Block-Disaster Recovery (CDBG-DR) funding in the wake of numerous presidentially-declared disasters, including, most recently, $2.431 billion in Public Law 116-20, the majority of which amount is for disasters that occurred in 2018 and 2019. Similar to previous CDBG-DR appropriations, the CDBG-DR appropriation in Public Law 116-20, enacted June 6, 2019, neither requires states to demonstrate to HUD that they adequately addressed the needs of both homeowners and renters nor, alternatively, directs HUD to develop a formula that accounts for the housing needs of both homeowners and renters. A bill introduced and reported out of committee in the 115th Congress, HR 4557, required HUD to disapprove a state action plan that detailed a grantee's use of funds if, among other reasons, the plan did not provide an equitable allocation of resources among homeowners, renters, and persons experiencing homelessness. A draft bill, whose provisions were essentially identical to HR 4557, was the focus of a hearing during the 116th Congress.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to take steps to ensure that its rate-setting methods and the data it uses to set rates result in full-risk premiums rates that accurately reflect the risk of losses from flooding. These steps should include, for example, verifying the accuracy of flood probabilities, damage estimates, and flood maps; ensuring that the effects of long-term planned and ongoing development, as well as climate change, are reflected in the flood probabilities used; and reevaluating the practice of aggregating risks across zones.

Agency: Department of Homeland Security
Status: Open
Priority recommendation

Comments: In April 2018, FEMA officials told us they had begun to redesign NFIP's risk rating system to help ensure policy rates better reflect the risk of flooding. The redesign, known as Risk Rating 2.0, includes efforts to use catastrophe models, stochastic approaches, and updated map information to better reflect the variation in flood risk. These reforms are also intended to improve how FEMA's rating process accounts for general and specific factors that affect flood probabilities and damage. While FEMA initially announced that new rates for all single-family homes would go into effect nationwide on October 1, 2020, it announced in November 2019 that it would defer implementation to October 1, 2021. FEMA said this would allow it to conduct a comprehensive analysis of the proposed rating structure so as to protect policyholders and minimize any unintentional negative effects of the transition, and that the new implementation date would cover all NFIP policies.

Recommendation: The Secretary of the Department of Homeland Security should direct FEMA to ensure that information is collected on the location, number, and losses associated with existing and newly created grandfathered properties in NFIP and to analyze the financial impact of these properties on the flood insurance program.

Agency: Department of Homeland Security
Status: Open

Comments: As of February 2020, FEMA officials said they had finished identifying properties with grandfathered premium rates and that they planned to analyze their economic implications as part of their efforts to update their premium rate setting approach, known as Risk Rating 2.0. FEMA plans to implement this redesign on October 1, 2021.

Recommendation: In order to put the Emergency Relief program on a sound financial footing, Congress may wish to consider the expected future demands on the program and reexamine the appropriate level and sources of funding--including whether to increase the $100 million annual authorized funding and whether the Highway Trust Fund, the General Fund, or some combination would allow the program to accomplish its purpose in a fiscally sustainable manner.

Agency: Congress
Status: Open

Comments: As of November 2019, Congress has not yet taken action on this recommendation. The Emergency Relief Program is due to be reauthorized in 2020.

Recommendation: Congress may also wish to consider tightening the eligibility criteria for Emergency Relief funding, either through amending the purpose of the Emergency Relief program, or by directing FHWA to revise its program regulations. Revised criteria could include limitations on the use of Emergency Relief funds to fully finance projects with scope and costs that have grown as a result of environmental and community concerns.

Agency: Congress
Status: Open

Comments: As of November 2019, Congress has not yet taken action on this recommendation. The Emergency Relief Program is due to be reauthorized in 2020.