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United States Government Accountability Office: 
GAO: 

Report to Congressional Requesters: 

February 2012: 

Homeland Security: 

DHS Needs Better Project Information and Coordination among Four 
Overlapping Grant Programs: 

GAO-12-303: 

GAO Highlights: 

Highlights of GAO-12-303, a report to congressional requesters. 

Why GAO Did This Study: 

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. 

What GAO Found: 

What GAO Found
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 recognized 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. 

What GAO Recommends: 

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. 

View [hyperlink, http://www.gao.gov/products/GAO-12-303[. For more 
information, contact David C. Maurer at (202) 512-9627 or 
MaurerD@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Overlap and Other Factors Increase the Risk of Duplication among Grant 
Programs: 

Enhanced Federal Coordination Could Help Reduce the Risk of 
Duplication: 

Some Performance Measures Exist for Individual Grant Programs, but 
Work Remains to Assess Grant Effectiveness: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: FEMA Grants Portfolio: 

Appendix II: Comments from the Department of Homeland Security: 

Appendix III: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: SHSP, UASI, PSGP, and TSGP Funding for Fiscal Years 2002-2011: 

Table 2: Purpose, Project Type, and Eligible Applicants of SHSP, UASI, 
PSGP, and TSGP: 

Table 3: Description of Project Information to Which FEMA Has Access 
for Four Projects in One Jurisdiction: 

Table 4: Description of Project Information to Which FEMA Has Access--
Example #2: 

Table 5: Selected DHS Grant Program Initiatives to Develop Outcome-
Based Performance Measures: 

Table 6: FEMA Initiatives to Evaluate Overall Effectiveness across 
Grant Programs: 

Figures: 

Figure 1: General Grant Life Cycle: 

Figure 2: Involved Federal Agencies and Grant Funding Paths and 
Processes of SHSP, UASI, PSGP, and TSGP: 

Abbreviations: 

BSIR: Biannual Strategy Implementation Report: 

CBRNE: Chemical, biological, radiological, and nuclear detection 
equipment: 

DHS: Department of Homeland Security: 

FA: Fiduciary Agent: 

FEMA: Federal Emergency Management Agency: 

GPD: Grant Programs Directorate: 

HSPD-8: Homeland Security Presidential Directive-8: 

IJ: Investment Justification: 

NAPA: National Academy of Public Administration: 

ND Grants: Non disaster grant management system: 

NPAD: National Preparedness Assessment Division: 

NPD: National Preparedness Directorate: 

OIG: DHS Office of Inspector General: 

PPD-8: Presidential Policy Directive-8: 

PSGP: Port Security Grant Program: 

SAA: State Administrative Agency: 

SHSP: State Homeland Security Program: 

THIRA: Threat and Hazard Identification Risk Assessment: 

TSA: Transportation Security Administration: 

TSGP: Transit Security Grant Program: 

UASI: Urban Areas Security Initiative: 

UAWG: Urban Area Working Group: 

USCG: U.S. Coast Guard: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

February 28, 2012: 

Congressional Requesters: 

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.[Footnote 1] 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.[Footnote 2] 

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),[Footnote 3] Biannual Strategy 
Implementation Reports (BSIR),[Footnote 4] 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,[Footnote 5] 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,[Footnote 6] various members of Urban Area 
Working Groups (UAWG),[Footnote 7] 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.[Footnote 8] 

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.[Footnote 9] 

We conducted this performance audit from October 2010 through February 
2012 in accordance with generally accepted government auditing 
standards.[Footnote 10] Those standards require that we plan and 
perform 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. 

Background: 

Overview of DHS Preparedness Grant Programs: 

Within DHS, FEMA manages a diverse portfolio of grant programs 
including a variety of preparedness grants. (See app. I for a diagram 
of FEMA's grants portfolio.) According to FEMA, the overarching goal 
of the preparedness grants is to enhance 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. Responsibility 
for administering federal preparedness grants has shifted numerous 
times within DHS.[Footnote 11] In fiscal year 2003, DHS's Office of 
Domestic Preparedness administered grant programs; since then, at 
different times other DHS offices have administered the programs, such 
as the Office for State and Local Government Coordination and 
Preparedness and the Office of Grants and Training. However, since its 
creation in April 2007, FEMA's GPD has been responsible for the 
program management of DHS's preparedness grants.[Footnote 12] 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. 

Grant Funding for Preparedness Programs: 

From fiscal years 2002 through 2011, DHS distributed approximately 
$20.3 billion through four grant programs: SHSP, UASI, PSGP, and 
TSGP.[Footnote 13] See table 1 for a breakdown of the funding for 
these programs. 

Table 1: SHSP, UASI, PSGP, and TSGP Funding for Fiscal Years 2002-2011: 

Fiscal year: 2002; 
SHSP: $316 million; 
UASI: N/A; 
PSGP: $93 million; 
TSGP: N/A. 

Fiscal year: 2003; 
SHSP: $2.066 billion; 
UASI: $596 million; 
PSGP: $244 million; 
TSGP: N/A. 

Fiscal year: 2004; 
SHSP: $1.675 billion; 
UASI: $671 million; 
PSGP: $179 million; 
TSGP: N/A. 

Fiscal year: 2005; 
SHSP: $1.062 billion; 
UASI: $855 million; 
PSGP: $141 million; 
TSGP: $108 million. 

Fiscal year: 2006; 
SHSP: $528 million; 
UASI: $711 million; 
PSGP: $168 million; 
TSGP: $131 million. 

Fiscal year: 2007; 
SHSP: $509 million; 
UASI: $747 million; 
PSGP: $311 million[A]; 
TSGP: $251 million. 

Fiscal year: 2008; 
SHSP: $863 million; 
UASI: $782 million; 
PSGP: $389 million; 
TSGP: $356 million. 

Fiscal year: 2009; 
SHSP: $861 million; 
UASI: $799 million; 
PSGP: $539 million[B]; 
TSGP: $498 million[C]. 

Fiscal year: 2010; 
SHSP: $842 million; 
UASI: $833 million; 
PSGP: $288 million; 
TSGP: $253 million. 

Fiscal year: 2011; 
SHSP: $527 million; 
UASI: $663 million; 
PSGP: $235 million; 
TSGP: $200 million. 

Fiscal year: Total; 
SHSP: $9.249 billion; 
UASI: $6.657 billion; 
PSGP: $2.587 billion; 
TSGP: $1.797 billion. 

Source: GAO analysis of FEMA grant guidance. 

[A] This figure includes $201 million in funding pursuant to the 
fiscal year 2007 appropriation and an additional $110 million in 
funding pursuant to the 2007 supplemental appropriation. 

[B] This figure includes $389 million in funding pursuant to the 
fiscal year 2009 appropriation and an additional $150 million in 
funding pursuant to appropriations in the American Recovery and 
Reinvestment Act. Pub. L. No. 111-5, 123 Stat. 145, 164 (2009). 

[C] Includes $150 million in funding pursuant to appropriations in 
American Recovery and Reinvestment Act. Id. 

[End of table] 

Overview of Grant Cycle: 

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. 

Figure 1: General Grant Life Cycle: 

[Refer to PDF for image: illustration] 

Stage: 1. Announcement stage (preaward): 

Agency processes: Announce opportunity; 
* Provide administrative and technical support; 
Grantee processes: Find opportunity; 
* Identify potential opportunity; 
* Develop proposal. 

Stage: 2. Application stage (preaward): 

Agency processes: Receive applications; 
* Authenticate applicant, apply business rules, and ensure 
administrative compliance; 
Grantee processes: Submit application; 
* Submit application package for competitive grant or other preaward 
documents for noncompetitive grant. 

Agency processes: Review and decision; 
* Conduct reviews (administrative, budget, policy, merit, business, 
application, certifications, and assurances); 
Grantee processes: Status review; 
* Check status of application. 

Stage: 3. Award stage:   

Agency processes: Award notification; 
* Notify the grantee and Congress and publicly announce the award; 
Grantee processes: Receive notification of award; 
* Complete award acceptance documents, if required. 

Stage: 4. Postaward stage: 

Agency processes: Disburse payment; 
* Process payments to grantee; 
Grantee processes: Request and receive payment; 
* Request disbursement of grant funds. 

Agency processes: Management and oversight; 
* Conduct site visits and review grantee reports; 
Grantee processes: Perform grant requirements and submit reports; 
* Comply with award terms and conditions, including general 
administrative requirements and cost principles; 
* Submit appropriate financial, performance, and other reports 

Stage: 5. Closeout stage: 
Agency processes: Closeout; 
* Review and reconcile final audit and other reports; 
Grantee processes: Closeout; 
* Submit final audit and other reports, as required. 

Source: GAO. 

[End of figure] 

Grant Programs Are Tied to Broader National Preparedness Initiatives: 

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.[Footnote 14] 

* 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.[Footnote 15] 

- 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.[Footnote 16] FEMA 
officials noted that the National Preparedness System affirms the all-
hazards risk-based approach to national preparedness.[Footnote 17] 
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.[Footnote 18] 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.[Footnote 19] 

Overlap and Other Factors Increase the Risk of Duplication among Grant 
Programs: 

Grant Programs Have Similar Goals, Fund Similar Projects, and Exist in 
the Same Urban Areas, Which Increases the Risk of Duplication: 

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 risk 
of terrorist attack.[Footnote 20] However, many jurisdictions within 
designated 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. 
[Footnote 21] Identifying and mitigating the risk of duplication could 
help 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. 

Table 2: Purpose, Project Type, and Eligible Applicants of SHSP, UASI, 
PSGP, and TSGP: 

Purpose of the grant program; 
State Homeland Security Grant Program (SHSP): SHSP provides funding to 
support states' implementation of homeland security strategies to 
address the identified planning, organization, equipment, training, 
and exercise needs at the state and local levels to prevent, protect 
against, respond to, and recover from acts of terrorism and other 
catastrophic events; 
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. 

Types of projects funded; 
State Homeland Security Grant Program (SHSP): 
* Planning; 
* Organization; 
* Equipment; 
* Training; 
* Exercises; 
Urban Areas Security Initiative (UASI): 
* Planning; 
* Organization; 
* Equipment; 
* Training; 
* Exercises; 
Port Security Grant Program (PSGP): 
* Port resiliency and recovery efforts; 
* Maritime domain awareness efforts; 
* Planning; 
* Equipment; 
* Training; 
* Exercises; 
Transit Security Grant Program (TSGP): 
* Capital infrastructure projects; 
* Operational activities; 
* Planning; 
* Equipment; 
* Training; 
* Exercises. 

Eligible applicants; 
State Homeland Security Grant Program (SHSP): SAA/50 states, DC, and 
territories; 
* SAA may allocate SHSP funds to Designated Urban Areas; 
Urban Areas Security Initiative (UASI): SAA/31 Designated Urban Areas 
(2 Tiers based on risk)[A]; 
* Urban Areas may allocate UASI funds to port and transit stakeholders; 
Port Security Grant Program (PSGP): Port Areas: Groups I and II 
(highest risk); Group III and "All Other Port Areas" (lower risk)[B]; 
Transit Security Grant Program (TSGP): Selected transit agencies and 
ferry systems within high risk urban areas. 

Source: FEMA grant guidance. 

[A] 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. 

[B] 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. 

[End of table] 

Differences in Administrative Processes among the Four Grant Programs 
Result in Varied Levels of Information on Which Award Decisions Are 
Based: 

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. 

Figure 2: Involved Federal Agencies and Grant Funding Paths and 
Processes of SHSP, UASI, PSGP, and TSGP: 

[Refer to PDF for image: illustration] 

Grant program: SHSP; 
Federal agencies involved: FEMA; 
Path of grant funds from FEMA to final recipient: 3 steps:  
* FEMA: 
- SAA; 
- Local units of government; 
- Final grant recipient; 
Application and award process: 
* FEMA announces funding allocation available to each state and opens 
application period; 
* FEMA awards funds to the SAA based on the project applications 
submitted through the SAA by local stakeholders; 
* The SAA distributes funds to local stakeholders and funds are 
received by final grant recipients.  

Grant program: UASI; 
Federal agencies involved: FEMA; 
Path of grant funds from FEMA to final recipient: 3 steps:  
* FEMA: 
- SAA; 
- Urban Areas; 
- Final grant recipient; 
Application and award process: 
* FEMA announces funding allocation available to each eligible urban 
area and opens application period; 
* FEMA awards funds to the SAA based on the project applications 
submitted through the SAA by the Urban Area Working Group[A]; 
* The SAA distributes funds to the Urban Area Working Groups and funds 
are received by final grant recipients.  

Grant program: PSGP; 
Federal agencies involved: FEMA/USCG; 
Path of grant funds from FEMA to final recipient: 2 steps: 
* FEMA: 
- Port Area Fiduciary Agent[B]; 
- Final grant recipient; 
Application and award process: 
* FEMA announces funding allocation available to each port area and 
opens application period; 
* FEMA awards funds to Groups I and II port area fiduciary agents; 
* A committee of port stakeholders reviews and ranks project proposals 
and recommends projects for funding to local USCG leadership; 
* Group III and "All Other Port Areas" submit projects directly to 
FEMA for award decisions. A panel of federal subject-matter experts    
reviews each project for funding decisions; 
* All projects from all groups are reviewed at the local field level 
and at the national level.  

Grant program: TSGP:
Federal agencies involved: FEMA/TSA; 
Path of grant funds from FEMA to final recipient: 1 step: 
* FEMA: 
- Final grant recipient; 
Application and award process: 
* FEMA announces funding allocation available to all eligible transit 
stakeholders for competitive grants and opens application period; 
* TSA sets the parameters for and approves the transit security 
strategies and final project selection is based on TSA approval; 
* FEMA awards funds directly to selected transit stakeholders.
    
Source: GAO analysis of FEMA grant guidance. 

[A] The Urban Area Working Groups develop the methodology for 
allocating funding and make decisions, based on consensus, on all UASI 
funding allocations. 

[B] For Group I and Group II port areas--the highest risk port areas--
money is passed from FEMA to the final grant recipient through the 
designated fiduciary agent as described in the table. However, for 
Group III and the All Other Port Areas Group, funding is passed 
directly from FEMA to the final grant recipient. 

[End of figure] 

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,[Footnote 22] 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).[Footnote 23] However, according to FEMA officials, states' 
capacities to effectively administer and coordinate their grants vary 
considerably. 

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.[Footnote 24] 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 Also Affect the Level of 
Federal Involvement in Award Decisions: 

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 2007 through 2010 were selected by regional working groups. 
[Footnote 25] The 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. 

Similarly, the USCG, and in particular the Captain of the Port, 
[Footnote 26] 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,[Footnote 27] 
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.[Footnote 28] 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.[Footnote 29] 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. 

FEMA Makes Award Decisions Using Varying Levels of Information Which 
Contributes to the Risk of Funding Duplicative Projects: 

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.[Footnote 30] 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.[Footnote 31] 

[Side bar: Washington State Investment Justification: 
Washington State's fiscal year 2010 Homeland Security Grant Program 
(HSGP) Investment Justification (IJ) proposed 11 broad investments, 9 
of which used SHSP funding totaling about $18 million. One proposed 
SHSP investment, $2 million for "Law Enforcement," contained a brief 
high-level description of the investment's goals and how it supports 
the state's homeland security strategy. The investment also lists 
proposed funding to target capabilities and broad solution areas, such 
as $200,000 for "On-site Incident Management" and about $1.5 million 
for "Equipment." More specific data on funding or subrecipient 
projects are not included. According to FEMA, in fiscal year 2008, the 
average state/territory HSGP IJ encompassed over 250 individual 
projects, although these specific projects were not detailed in the IJ 
itself. Source: GAO analysis of FEMA information. End of side bar] 

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.[Footnote 32] 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." 

FEMA Is Considering Additional Action and Taking Steps to Enhance 
Grant Information, but Further Efforts Are Needed to Avoid the Risk of 
Duplication: 

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.[Footnote 33] 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.[Footnote 34] 
If this recommendation is implemented, the policy of 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. 

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.[Footnote 35] 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. 

Table 3: Description of Project Information to Which FEMA Has Access 
for Four Projects in One Jurisdiction: 

Grant: UASI; 
Year: 2009; 
Project type: Critical Infrastructure Protection; 
Project title: Public Safety Video Initiative - assess vulnerability 
of and/or harden/protect critical infrastructure and key assets; 
Recipient: Urban Area Working Group; 
Description: Beginning with the 2006 UASI Grant period, the City[A] 
began the development of a public safety video system to improve 
situational awareness of public venues, critical assets, 
transportation and commerce corridors, and public safety areas of 
interest. 

Grant: SHSP; 
Year: 2009; 
Project type: Critical Infrastructure Protection; 
Project title: Assess vulnerability of and/or harden/protect critical 
infrastructure and key assets; 
Recipient: City/County Governmental Organization; 
Description: This will support the expansion of the Public Safety 
Video Program that is currently under development. 

Grant: SHSP; 
Year: 2009; 
Project type: Critical Infrastructure Protection; 
Project title: Assess vulnerability of and/or harden/protect critical 
infrastructure and key assets; 
Recipient: City/County Governmental Organization; 
Description: This project will assist the County Sheriff's Office in 
achieving the goal of reducing vulnerability of a Critical 
Infrastructure/Key Resource adjacent to a specific critical waterway. 

Grant: PSGP; 
Year: 2009; 
Project type: Maritime Domain Awareness/Improvised Explosive Device 
Prevention, Protection, Response, and Recovery Capabilities[B]; 
Project title: CCTV Surveillance Cameras Replacement Program[C]; 
Recipient: Port Authority; 
Description: Many of the CCTV surveillance cameras that have been 
installed at the Port Authority's facilities are at or near the end of 
their useful life. This program will initiate the systematic 
replacement of these CCTV cameras. 

Source: FEMA BSIR for UASI and SHSP; FEMA IJ for PSGP. 

[A] Identifying information was removed. 

[B] PSGP project types are not directly comparable to BSIR project 
type categories. 

[C] "CCTV" refers to Closed Circuit Television. 

[End of table] 

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. 

Table 4: Description of Project Information to Which FEMA Has Access--
Example #2: 

Grant: SHSP; 
Year: 2009; 
Project type: Enhance capabilities to respond to all-hazards events; 
Project title: Project A - CBRNE Support; 
Recipient: City/County Governmental Organization; 
Description: Purchase of equipment to support response capabilities 
for CBRNE events. 

Grant: TSGP; 
Year: 2009; 
Project type: Equipment[A]; 
Project title: Install CBRNE in Subway; 
Recipient: Transit Agency; 
Description: Install CBRNE in subway. 

Source: FEMA BSIR for SHSP; FEMA IJ for TSGP. 

[A] TSGP project types are not directly comparable to BSIR project 
type categories. 

[End of table] 

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.[Footnote 
36] 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.[Footnote 37] However, 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. 

We believe that the recommendation of the FEMA report to better use 
more specific project-level data through the BSIR,[Footnote 38] 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. 

Enhanced Federal Coordination Could Help Reduce the Risk of 
Duplication: 

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.[Footnote 39] The Director of GPD's 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. 

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.[Footnote 40] 

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.[Footnote 41] 

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. 

Some Performance Measures Exist for Individual Grant Programs, but 
Work Remains to Assess Grant Effectiveness: 

DHS Has Some Performance Measures, but Until Additional Measures Are 
Implemented It Cannot Assess Grant Effectiveness: 

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[Footnote 42] 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[Footnote 43] 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. 
[Footnote 44] Additionally, the National Infrastructure Protection 
Plan instructs 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. 

Table 5: Selected DHS Grant Program Initiatives to Develop Outcome-
Based Performance Measures: 

Grant program affected: SHSP; 
Grant program affected: UASI; 
Initiative name: National Academy of Public Administration (NAPA) 
Study; 
Initiative description: The Redundancy Elimination and Enhanced 
Performance for Preparedness Grants Act[B] directed 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. 

Grant program affected: PSGP[A]; 
Grant program affected: TSGP; 
Initiative name: FEMA Task Force on Performance Measures; 
Initiative description: 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; 
Expected result: Development of program-specific performance measures 
for PSGP and TSGP; 
Status: 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[C]. 

Source: GAO analysis of FEMA information. 

[A] For more information about FEMA's efforts to measure the 
effectiveness of the PSGP, see GAO-12-47. 

[B] Pub. L. No. 111-271, § 2(a), 124 Stat. 2852 (2010) (codified at 6 
U.S.C. § 613(d)). 

[C] 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. 

[End of table] 

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.[Footnote 45] 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, 
[Footnote 46] 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.[Footnote 47] 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. 

DHS Has Initiatives under Way to Evaluate Overall Effectiveness across 
Grant Programs, but Has Not Completed These Efforts: 

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. 

Table 6: FEMA Initiatives to Evaluate Overall Effectiveness across 
Grant Programs: 

Action/program: Revising Preparedness Guidance; 
Grants affected (in this review): SHSP, UASI, PSGP, TSGP; 
Description: Presidential Policy Directive-8 (PPD-8) replaces HSPD-8 
and requires that a new national preparedness system include a 
comprehensive system to assess national preparedness; 
Expected result: DHS is responsible for measuring the readiness of 
current national capabilities with clear, objective and quantifiable 
performance measures. The structure of this measurement system will 
drive the development of any future performance measures; 
Status: In November 2011, FEMA released the National Preparedness 
System description, which is designed to lay the groundwork for 
strengthening the nation's resilience against all threats and hazards. 
The system description is the second deliverable called for by PPD-8. 
According to a DHS publication, further details on how the National 
Preparedness System will be implemented will be provided as the 
remaining PPD-8 deliverables are developed. 

Action/program: Implementing the ND Grants System; 
Grants affected (in this review): SHSP, UASI, PSGP, TSGP; 
Description: ND Grants is a web-based system intended to provide FEMA 
and its stakeholders with a system that supports the grants management 
lifecycle and consolidates grant information; 
Expected result: According to FEMA, the ND Grants system is intended 
to consolidate FEMA's disparate data systems and improve the ability 
of FEMA grant managers to track grants through the review and approval 
process, a capability that will also assist with evaluating grant 
performance; 
Status: In fiscal year 2011, FEMA implemented portions of the ND 
Grants system. At this time, ND Grants cannot collect or provide 
comprehensive information across grant programs. According to FEMA, 
the system is scheduled for completion in fiscal year 2014. 

Action/program: Implementing Threat Hazard Identification Risk 
Assessment (THIRA); 
Grants affected (in this review): SHSP, UASI; 
Description: THIRA requires jurisdictions to add a threat evaluation 
to the existing Hazard Identification Risk Assessment mitigation 
process; 
Expected result: The goal of THIRA is to create a standardized system 
that establishes baseline risks and capabilities at the local level 
and provides a justification for investments in preparedness; 
Status: The THIRA was first called for as part of the fiscal year 2011 
Homeland Security Grant Program. 

Source: GAO analysis of FEMA information. 

[End of table] 

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. 

Conclusions: 

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. 

Recommendations for Executive Action: 

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. 

Agency Comments and Our Evaluation: 

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 [hyperlink, 
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. 

Signed by: 

David C. Maurer: 
Director, Homeland Security and Justice Issues: 

List of Requesters: 

The Honorable John D. Rockefeller IV: 
Chairman: 
Committee on Commerce, Science and Transportation: 
United States Senate: 

The Honorable Joseph Lieberman: 
Chairman: 
The Honorable Susan Collins: 
Ranking Member: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Thomas Coburn: 
Ranking Member: 
Permanent Subcommittee on Investigations: 
Committee on Homeland Security and Governmental Affairs: 
United States Senate: 

The Honorable Peter King: 
Chairman: 
Committee on Homeland Security: 
House of Representatives: 

The Honorable Gus Bilirakis: 
Chairman: 
Subcommittee on Emergency Preparedness, Response, and Communications: 
Committee on Homeland Security: 
House of Representatives: 

[End of section] 

Appendix I: FEMA Grants Portfolio: 

[Refer to PDF for image: chart] 

[This report focuses on the 4 highlighted preparedness grants below] 

FEMA Grant: 
* Disaster-Specific; 
* Hazard-Related; 
* Non-Disaster; 
* National: 
- Fire: 
-- Assistance to Firefighters Grant; 
-- Staffing for Adequate Fire and Emergency; 
-- Fire Prevention and Safety Grants; 
- Non-Fire: 
-- State Homeland Security Program[A][highlighted]; 
-- Tribal Homeland Security Grant Program; 
-- Urban Areas Security Initiative[A][highlighted]; 
-- Regional Catastrophic Preparedness Grant; 
-- Metropolitan Medical Response System[A]; 
-- Operation Stonegarden[A]; 
-- Citizen Corps Program[A]
-- Emergency Management Performance; 
-- Emergency Operations Center Grant Program; 
-- Interoperable Emergency Communications; 
-- Driver's License Security Grant Program; 
-- Buffer Zone Protection Program; 
-- Transit Security Grant Program [highlighted]; 
-- Port Security Grant Program [highlighted]; 
-- Intercity Passenger Rail Security; 
-- Freight Rail Security Grant Program; 
-- Intercity Bus Security Grant Program. 

Source: FEMA. 

[A] AHSP, 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. 

[End of figure] 

[End of section] 

Appendix II: Comments from the Department of Homeland Security: 

U.S. Department of Homeland Security: 
Washington, DC 20528 

February 21, 2011: 

David C. Maurer: 
Director, Homeland Security and Justice Issues: 
U.S. Government Accountability Office: 
441 G Street, NW: 
Washington, DC 20548: 

Re: Draft Report GAO-12-303, "Homeland Security: DHS Needs Better 
Project Information and Coordination Among Four Overlapping Grant 
Programs" 

Dear Mr. Maurer: 

Thank you for the opportunity to review and comment on this draft 
report. The U.S. Department of Homeland Security (DHS) appreciates the 
U.S. Government Accountability Office's (GAO's) work in planning and 
conducting its review and issuing this report. 

The Department is pleased to note that GAO's analysis did not identify 
any duplication among the grant projects sampled. We also appreciate 
GAO's positive acknowledgment of actions the Federal Emergency 
Management Agency (FEMA), as well as state and local stakeholders, 
have taken to improve coordination in administering the four grant 
programs reviewed. DHS remains committed to eliminating any 
potentially duplicative homeland security preparedness grant program 
investments and working with its partners throughout all levels of 
government, law enforcement, private industry, and in the public to 
ensure the safety, security, and resilience of our Nation. 

The draft report contained three recommendations, with which the 
Department concurs. 

Specifically, GAO recommended that the FEMA Administrator: 

Recommendation 1: Take steps, when developing ND Grants and responding 
to the Working Group 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 this data. 

Response: Concur. In Fiscal Year (FY) 2012 the DHS Secretary 
Napolitano used her discretionary authority in not funding seven 
programs that were previously funded, either as carve-outs of larger 
programs or as stand-alone programs. These were the Metropolitan Medical
Response System, Citizen Corps Program, Interoperable Emergency 
Communication Grant Program, Drivers License Security Grant Program, 
Emergency Operations Centers, Regional Catastrophic Preparedness Grant 
Program, Freight Security Grant Program, and Intercity Bus Security 
Grant Program. At the same time, FEMA expanded allowability for the 
activities that were previously funded under these eliminated programs 
within funded programs. FEMA believes that the FY 2012 funding 
decisions will streamline data collection for applicants. 

In addition, annually FEMA reexamines its data collection requirements 
and looks for opportunities to streamline application and investment 
justification data collection. In FY 2012, for example, FEMA replaced 
the requirement to submit the Semi-Annual Assistance Progress
Report with the Standard Form-Performance Progress Report (SF-PPR) in 
order to better capture program-specific performance measures and 
assess progress toward implementing projects. The SF-PPR offers FEMA 
the flexibility and the level of detail needed to target performance 
measures demonstrated through the progress reported by grantees. 
Through discussions between FEMA's National Preparedness Assessment 
Division (NPAD) and the Grant Programs Directorate (GPO), performance 
measure questions that could be answered from other sources were 
eliminated from the SF-PPR in an effort to ease the burden on grantees. 

Looking forward to FY 2013, FEMA proposes significant modifications to 
the preparedness grant portfolio in order to reduce redundancy and 
duplication in both the administration and execution of the 
preparedness grant portfolio. These modifications culminate into the 
National Preparedness Grant Program (NPGP), a single grant program 
that supports state, local, and regional preparedness efforts. The 
proposal seeks to restructure all preparedness grant programs except 
the Emergency Management Performance Grants and the Assistance to 
Firefighters Grant under the one program. Again, FEMA expects that the 
NPGP concept will further reduce or eliminate the potential for 
duplication and result in meeting the intent of the above 
recommendation. 

On the basis of efforts currently underway for FY 2012, the proposed 
changes for FY 2013, and the extensive work being undertaken jointly 
between FEMA's NPAD and GPD, FEMA requests that this recommendation be 
considered resolved and closed. 

Recommendation 2: 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.
Response: Concur. GPO is an active participant in the Intra-agency 
Grants Task Force (Task Force). The Task Force was established by FEMA 
senior leadership to provide a clear and concise strategic connection 
among the FEMA grant programs, determine common elements, and ensure 
accountability and credibility with the FEMA stakeholders. It is 
designed to enhance communication with partners throughout the Agency, 
while seeking areas for collaboration and partnership. The Task Force 
is a cross-cutting forum that facilitates the exchange of ideas and 
information and identifies consistencies and efficiencies, eliminates 
duplication, and strengthens the organization. The Task Force serves 
multiple FEMA stakeholders by: 

* Providing a forum for collaboration and partnership for the FEMA 
staff in headquarters and the Regions. 

* Improving customer service by recommending standardized processes to 
improve support and services provided to grantees. 

* Identifying weaknesses in Agency grants management. 

* Evaluating and strengthening Agency grant compliance issues. 

* Improving communication for internal and external stakeholders 
through increased transparency of grants information, processes and 
resources. 

GPD is also working with DHS-level task force initiatives to improve 
grants management across the Department. This task force initiative, 
titled The Deputy Secretary's Initiative to Improve the Health of DHS 
Financial Assistance, is being conducted to assess and identify 
highrisk/exposure areas and other issues across the Department in 
grants management. Four working groups were identified and focus on 
the following critical areas: (1) Pre-Award and Program Development, 
(2) Award, (3) Post-Award Administration and Reporting, and (4) Award 
Closeout. Part of this effort involves looking for ways to reduce 
redundancies and grantee burden across the Department's grant 
activities. 

Finally, the development, management, and oversight of GPD's 
preparedness program portfolio are executed in collaboration with a 
number of partners within FEMA, across DHS, and throughout the Federal 
Government. GPD has formal written memoranda of understanding (MOU) 
with partner agencies/offices that communicate the scope, roles, and 
responsibilities of both agencies in relation to specific grant 
programs. GPD is committed to expanding these partnerships and 
developing new ones through formal MOUs, collaborative planning 
efforts, and joint outreach efforts to the larger grantee and 
stakeholder community. GPD's relationships with these organizations 
and our joint commitment to our emergency management and homeland 
security community strengthen FEMA's programs and the positive impact 
they have on the Nation. GPD continues to be engaged in developing 
memoranda of understanding with the various DHS Components for work 
executed under programs whose success depends on those partnerships. 

These activities are all part of GPD's commitment to enhance our 
internal coordination and administration of the programs in order to 
identify and mitigate the potential for any unnecessary
duplication. On the basis of the scope and current engagement of these 
partnerships, FEMA requests that this recommendation be considered 
resolved and closed. 

Recommendation 3: 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. 

Response: Concur. NPAD in the National Preparedness Directorate, 
working with GPD, has been making progress on developing measures for 
FEMA's NPGP programs as described in the Performance Measure 
Implementation Plan. NPAD has completed the key milestones, including 
development of the performance measures list. New measures and a plan 
for collection of the data are presently in draft form. NPAD will 
provide an update to the Performance Measure Implementation Plan once 
a decision has been finalized. As part of the FY 2013 Budget, the
Administration has proposed a new vision for the grant programs 
designed to develop, sustain, and leverage core capabilities across 
the Nation. Decisions on measures of grant effectiveness will be 
informed by alignment with the key objectives outlined in the new 
vision, as appropriate. 

Again, thank you for the opportunity to review and comment on this 
draft report. We look forward to working with you on future Homeland 
Security issues. 

Sincerely, 

Signed by: 

Jim H. Crumpacker: 
Director: 
Departmental GAO-OIG Liaison Office: 

[End of section] 

Appendix III GAO Contact and Staff Acknowledgments: 

GAO Contact: 

David C. Maurer, (202) 512-9627 or Maurerd@gao.gov: 

Staff Acknowledgments: 

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. 

[End of section] 

Footnotes: 

[1] This total is based on Congressional Research Service data and GAO 
analysis, and includes firefighter assistance grants and emergency 
management performance grants. See Congressional Research Service, 
Department of Homeland Security Assistance to States and Localities: A 
Summary of Issues for the 111th Congress, R40246 (Washington, D.C.: 
Apr. 30, 2010). 

[2] GAO, Opportunities to Reduce Potential Duplication in Government 
Programs, Save Tax Dollars, and Enhance Revenue, [hyperlink, 
http://www.gao.gov/products/GAO-11-318SP] (Washington, D.C.: Mar. 1, 
2011). 

[3] Investment Justifications (IJ) are one component of SHSP, UASI, 
PSGP, and TSGP applications for grant funding. They provide narrative 
information on proposed activities (investments) that will be 
accomplished with the grant funds and are described in more detail 
later in this report. The IJ must demonstrate how proposed investments 
address gaps and deficiencies in current capabilities, and also 
demonstrate adherence to program guidance. 

[4] The Biannual Strategy Implementation Report (BSIR) is a reporting 
requirement submitted by states to FEMA on the progress of certain 
grants. These reports are described in more detail later in this 
report. 

[5] Among other things, the National Preparedness Guidelines are 
intended to organize and synchronize national--including federal, 
state, local, tribal, and territorial--efforts to strengthen national 
preparedness. 

[6] A designated State Administrative Agency (SAA) is responsible for 
managing the SHSP and UASI programs at the state level. This 
management includes processing project applications prior to 
submitting them to FEMA, "passing though" federal funds to regional or 
local entities, and ensuring that local grant recipients comply with 
various statutory and grant requirements. 

[7] The Urban Area Working Groups (UAWG), in the UASI regions, develop 
the methodology for allocating funding and make decisions, based on 
consensus, on all UASI funding allocations. 

[8] See GAO, Transit Security Grant Program: DHS Allocates Grants 
Based on Risk, but Its Risk Methodology, Management Controls, and 
Grant Oversight Can Be Strengthened, [hyperlink, 
http://www.gao.gov/products/GAO-09-491] (Washington, D.C.: June 8, 
2009) and Results-Oriented Government: Practices That Can Help Enhance 
and Sustain Collaboration among Federal Agencies, [hyperlink, 
http://www.gao.gov/products/GAO-06-15] (Washington, D.C.: Oct. 21, 
2005). 

[9] See GAO, Port Security Grant Program: Risk Model, Grant 
Management, and Effectiveness Measures Could Be Strengthened, 
[hyperlink, http://www.gao.gov/products/GAO-12-47] (Washington, D.C.: 
Nov. 17, 2011) and [hyperlink, 
http://www.gao.gov/products/GAO-09-491]; and Project Management 
Institute, The Standard for Program Management, © (2006). 

[10] This work was done in conjunction with a separate review of the 
Port Security Grant Program. See [hyperlink, 
http://www.gao.gov/products/GAO-12-47]. 

[11] Prior to DHS's formation in 2003, agencies such as the Department 
of Justice and the Department of Health and Human Services 
administered various preparedness-related grants. 

[12] The Post-Katrina Emergency Management Reform Act transferred most 
of the Preparedness Directorate to FEMA, effective on March 31, 2007. 
Pub. L. No. 109-295, 120 Stat. 1355, 1394 (2006). 

[13] In fiscal year 2011, FEMA distributed funds to a total of 16 
preparedness grant programs including SHSP, UASI, PSGP, and TSGP. 

[14] 6 U.S.C. § 746. 

[15] Based on risk, each port area is placed into one of three funding 
groups--Group I, Group II, or Group III. Groups I and II port areas 
are the highest risk port areas that receive the bulk of the PSGP 
grant funding. 

[16] PPD-8 states, "This directive replaces Homeland Security 
Presidential Directive (HSPD)-8 (National Preparedness), issued 
December 17, 2003, and HSPD-8 Annex I (National Planning), issued 
December 4, 2007, which are hereby rescinded, except for paragraph 44 
of HSPD-8 Annex I. Individual plans developed under HSPD-8 and Annex I 
remain in effect until rescinded or otherwise replaced." 

[17] The national preparedness system is designed to help guide the 
domestic efforts of all levels of government, the private and 
nonprofit sectors, and the public to build and sustain national 
capabilities. The national preparedness system is to include guidance 
for planning, organization, equipment, training, and exercises to 
build and maintain domestic capabilities. It is intended to provide an 
all-of-nation approach for building and sustaining a cycle of 
preparedness activities over time. 

[18] In accordance with the Homeland Security Act and in response to 
HSPD-7, DHS issued, in June 2006, the first National Infrastructure 
Protection Plan, which provides the overarching approach for 
integrating the nation's critical infrastructure and key resource 
protection initiatives into a single effort. DHS issued a revised Plan 
in January 2009. The Plan sets forth a risk management framework and 
details the roles and responsibilities of DHS, sector-specific 
agencies, and other federal, state, regional, local, tribal, 
territorial, and private sector partners, including how they should 
use risk management principles to prioritize protection activities 
within and across sectors. 

[19] In September 2011, DHS issued the National Preparedness Goal as 
directed by PPD-8. According to DHS, the goal is "A secure and 
resilient Nation with the capabilities required across the whole 
community to prevent, protect against, mitigate, respond to, and 
recover from the threats and hazards that pose the greatest risk." 
Thirty-two "core capabilities," such as "planning" and "threats and 
hazard identification," are listed and defined under each of the five 
broader mission areas named in the goal ("prevent," "protect against," 
etc.). These capabilities will be the foundation for measuring overall 
national preparedness and allocating resources to fill preparedness 
gaps. Additionally, in November 2011, DHS released its description of 
the National Preparedness System that summarizes the components of the 
National Preparedness System, which include: identifying and assessing 
risk, estimating the level of capabilities needed to address those 
risks, building or sustaining the required levels of capability, 
developing and implementing plans to deliver those capabilities, 
validating and monitoring progress, and reviewing and updating efforts 
to promote continuous improvement. 

[20] 6 U.S.C. § 605(e); 6 U.S.C. § 604. 

[21] [hyperlink, http://www.gao.gov/products/GAO-11-318SP]. 

[22] 6 U.S.C. §§ 604, 605. 

[23] 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. 

[24] Pub. L. No. 110-329, 122 Stat. 3574, 3671 (2008). 

[25] The regional working groups choose projects for the highest risk 
Tier 1 regions. The remaining transit regions'--Tier 2 regions--
projects are fully competitive. 

[26] The Captain of the Port (COTP) is a Coast Guard officer 
responsible for enforcing port safety, security and marine 
environmental regulations within a given port area. The COTP also 
leads the local field-level review of PSGP projects, although the 
COTP's actual level of involvement in the selection process may vary 
from port to port depending on local conditions. 

[27] Programs of the Maritime Administration promote the development 
and maintenance of an adequate, well-balanced United States merchant 
marine capable of service as a naval and military auxiliary in time of 
war or national emergency. The Maritime Administration also seeks to 
ensure that the United States maintains adequate shipbuilding and 
repair services, efficient ports, effective intermodal water and land 
transportation systems, and reserve shipping capacity for use in time 
of national emergency. 

[28] For more detailed information on PSGP program requirements and 
processes see [hyperlink, http://www.gao.gov/products/GAO-12-47]. 

[29] FEMA directs each UASI region to create its own regional working 
group, which FEMA's grant guidance refers to as an urban area working 
group. Grant guidance requires the working group to determine 
representation from the jurisdictions and response disciplines that 
comprise the UASI region. Beginning in fiscal year 2008, UASI grant 
guidance recommended to urban areas that they consider for UASI 
working group membership those counties within which the cities 
included in the UASI region reside, contiguous jurisdictions, and 
jurisdictions within the region's Metropolitan Statistical Area (MSA). 
An MSA is a geographic entity defined by the Office of Management and 
Budget that contains an urban core population of 50,000 or more. 

[30] [hyperlink, http://www.gao.gov/products/GAO-11-318SP]. 

[31] Regarding FEMA's data limitations, FEMA is currently using a 
grants management system "on-loan" from the Department of Justice. 
This involves a number of disparate systems and spreadsheets. FEMA is 
in the process of transitioning to a new system called ND (non 
disaster) Grants. ND Grants is slated to be a one-stop shop for 
programmatic and financial information on DHS grants, as well as 
monitoring and payment. ND Grants was introduced in 2011 but is still 
several years away from having full functionality, according to FEMA. 

[32] 6 U.S.C. §§ 604, 605. 

[33] FEMA, Redundancy Elimination and Enhanced Performance for 
Preparedness Grants Act: Initial Report to Congress (Washington, D.C.: 
May 23, 2011). In August 2009, FEMA established the Reporting 
Requirements Working Group to compile a list of select grant reporting 
activities, collect grant stakeholder feedback, and make 
recommendations on future data collection policies. The May 2011 
Initial Report to Congress is based on the Working Group's research 
and outlines recommendations and implementation actions related to 
grant application criteria and data integration, among other things. 

[34] BSIRs are submitted electronically by SAAs to FEMA for the life 
of the award to account for the use of grant funding. All funds 
provided to the SAA must be accounted for and linked to one or more 
projects in the BSIR. 

[35] Port and transit projects are not included in the BSIR, thus 
information was obtained from spreadsheets which contain IJ data. 
According to a FEMA section chief, the BSIR system was designed for 
state-level reporting as opposed to reporting from the variety of 
different subrecipients that receive PSGP and TSGP funds more 
directly. TSGP projects were listed in the BSIR prior to fiscal year 
2009 when they were administered by state SAAs. 

[36] DHS, Efficacy of DHS Grant Programs, OIG-10-69 (Washington, D.C.: 
Mar. 22, 2010). 

[37] 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. 

[38] As noted above, FEMA would collect more specific BSIR data at the 
application stage of the grants cycle instead of higher level 
"investment" descriptions. This more specific project-level data could 
include more detailed data elements related to funding; target 
capabilities addressed; and proposed solution categories, such as 
planning, organization, training, exercises, equipment, and management 
and administration. 

[39] Threat and Hazard Identification Risk Assessments (THIRA) 
establish a foundation to justify and guide preparedness activities 
and investments. THIRAs should include the range of threats and 
hazards faced by an applicant. The assessment should be based on 
analysis of the relative consequences of the various threats and 
hazards with consideration of empirical data to the maximum degree 
possible. An effective THIRA will allow the applicant to compare and 
prioritize risks, even if they are dissimilar, by identifying possible 
threats and hazards faced with respective probability estimates of 
their occurrence. THIRA findings should be incorporated into each 
applicant's preparedness strategy, planning, Investment Justification, 
and assessment documentation and address capability gaps identified 
during the THIRA process. 

[40] DHS-OIG, The State of New Jersey's Management of State Homeland 
Security Program and Urban Areas Security Initiative Grants Awarded 
During Fiscal Years 2007 through 2009, OIG-11-112 (Sept. 26, 2011). 

[41] OIG-10-69. 

[42] Since 2001, all 50 states and some local governments have 
established fusion centers to address gaps in terrorism-related 
information sharing that the federal government cannot address alone 
and to provide a mechanism for information sharing within the state. 
For more information on fusion centers, see GAO, Information Sharing: 
Federal Agencies Are Helping Fusion Centers Build and Sustain 
Capabilities and Protect Privacy, but Could Measure Results, 
[hyperlink, http://www.gao.gov/products/GAO-10-972] (Washington, D.C.: 
Sept. 29, 2010). 

[43] The federal government is working with state, local, and tribal 
government agencies to implement the Nationwide Suspicious Activity 
Reporting initiative. This effort is intended to establish a 
nationwide capability to gather and share information about suspicious 
incidents to enable rapid identification and mitigation of potential 
terrorist threats. 

[44] GAO, DHS Improved its Risk-Based Grant Programs' Allocation and 
Management Methods, But Measuring Programs' Impact on National 
Capabilities Remains a Challenge, [hyperlink, 
http://www.gao.gov/products/GAO-08-488T] (Washington D.C.: Mar. 11, 
2008). 

[45] [hyperlink, http://www.gao.gov/products/GAO-08-488T]. 

[46] According to FEMA, the Performance Measure Implementation Plan is 
an internal plan that provides the agency's general approach to 
performance measurement as well as a key list of milestones for 
implementing the agency's new performance measures and refining its 
existing measures related to preparedness grants. 

[47] The National Preparedness Assessment Division (NPAD) is 
responsible for evaluation and assessment of preparedness grant 
programs, among other things. 

[End of section] 

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