From fiscal years 2002 through 2011, the federal government appropriated over $37 billion to a variety of Department of Homeland Security (DHS) homeland security preparedness grant programs. Of this amount, the DHSs Federal Emergency Management Agency (FEMA) allocated about $20.3 billion to grant recipients through four programs: the State Homeland Security Program, the Urban Areas Security Initiative, the Port Security Grant Program, and the Transit Security Grant Program. Through these grant programs, DHS has sought to enhance the capacity of states, localities, and other entitiessuch as ports or transit agenciesto prevent, respond to, and recover from a terrorism incident.
As GAO reported in March 2011, DHS could benefit from examining its 17 preparedness grant programs and coordinating their application processes; developing measurable capability requirements and evaluation criteria; and eliminating redundant reporting requirements. GAO also reported in February 2012 on 4 of these 17 grant programs the State Homeland Security Program, the Urban Areas Security Initiative, the Port Security Grant Program, and the Transit Security Grant Programand found that multiple factors contributed to the risk of FEMA funding unnecessarily duplicative projects. These factors include overlap among grant recipients, goals, and geographic locations, combined with the limited project information that FEMA had available regarding grant funding levels, grant recipients, and grant purposes.
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).
GAO has previously reported that overlap among government programs or activities can be harbingers of unnecessary duplication. The four DHS grant programs that GAO reported on in February 2012the State Homeland Security Program, the Urban Areas Security Initiative, the Port Security Grant Program, and the Transit Security Grant Programhave multiple areas of overlap. The grant programs have similar goals and fund similar activities, such as equipment and training, in overlapping jurisdictions. For instance, each state and eligible territory receives a legislatively mandated minimum amount of State Homeland Security Program funding to help ensure that all geographic areas develop a basic level of preparedness, while the Urban Areas Security Initiative grants explicitly target urban areas most at risk of terrorist attack. However, many jurisdictions within designated Urban Areas Security Initiative regions also apply for and receive State Homeland Security Program funding. Similarly, port stakeholders in urban areas could receive funding for equipment such as patrol boats through both the Port Security Grant Program and the Urban Areas Security Initiative, and a transit agency could purchase surveillance equipment with Transit Security Grant Program or Urban Areas Security Initiative funding.
Further, depending on the program, other federal stakeholders in addition to FEMA are involved in the administration or coordination of some, but not all, of the four programs. The table below illustrates overlap in the purposes and types of projects funded by the four grant programs.
Federal Agencies, Purpose, and Project Type Involved in Select Homeland Security Grants
State Homeland Security Grant Program
Urban Areas Security Initiative
Port Security Grant Program
Transit Security Grant Program
Primary federal agencies involved
Federal Emergency Management Agency
Federal Emergency Management Agency
Federal Emergency Management Agency/ U.S. Coast Guard
Federal Emergency Management Agency/ Transportation Security Administration
Purpose of the grant program
The State Homeland Security Programprovides funding to support state and local efforts to prevent, protect against, respond to, and recover from acts of terrorism and other catastrophic events.
The Urban Areas Security Initiativeprovides funding to high-risk urban areas to build and sustain regional capabilities to prevent, protect, respond to, and recover from acts of terrorism.
The Port Security Grant Programprovides funding to port stakeholders to mitigate against risks associated with potential terrorist attacks by enhancing capabilities to detect, prevent, respond to and recover from terrorist attacks.
The Transit Security Grant Programprovides funds to public transit agencies 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
Source: Federal Emergency Management Agency grant guidance.
As GAO reported in February 2012, FEMA made award decisions for all four programs with differing levels of information which contributes to the risk of funding unnecessarily duplicative projects. While GAO understands that some overlap may be desirable to provide multiple sources of funding, a lack of visibility over grant award details around these programs increases the risk of unintended and unnecessary duplication. Some of the factors that contributed to the differences in the information available include different administrative processes and information requirements. With respect to administrative differences, FEMA delegates some administrative duties to stakeholders for the State Homeland Security Program, the Urban Areas Security Initiative and the Port Security Grant Program, thereby reducing its administrative burden according to FEMA officials. However, this delegation also contributes to FEMA having less visibility over some grant applications, and in particular those funded by the State Homeland Security Program and the Urban Areas Security Initiative. These two programs are administered by state administrative agencies; however, some administrative functions are further delegated to subrecipients such as local governments or other entities. In contrast, Transit Security Grant Program awards are made directly to the final grant recipients and this more direct award structure, among other factors, allows FEMA to better track these grant awards. In delegating significant grants administration duties to the state administrative agencies for the larger State Homeland Security Program and Urban Areas Security Initiative programs, FEMA officials recognize the trade-off between decreased visibility over grant funding, subrecipients, and specific project-level data in exchange for their reduced administrative burden.
Differences in information requirements also affect the level of information that FEMA has available for making grant award decisions. For example, for the State Homeland Security Program and Urban Areas Security Initiative, states and eligible urban areas submit investment justifications for each program with up to 15 distinct investment descriptions that describe general proposals in wide-ranging areas such as critical infrastructure protection. Each investment justification encompasses multiple specific projects to different jurisdictions or entities, but project-level information, such as a detailed listing of subrecipients or equipment costs, is not required by FEMA. In contrast, Port Security Grant Program and Transit Security Grant Program applications require specific information on individual projects such as detailed budget summaries. As a result, FEMA has a much clearer understanding of what is being requested and what is being funded by these programs.
FEMA has studied the potential utilization of more specific project-level data for making grant award decisions, especially for the State Homeland Security Program and Urban Areas Security Initiative. Specifically, a May 2011 FEMA report recommended that the agency modify the investment justification format for the Urban Areas Security Initiative and the State Homeland Security Program applications to include a detailed project list. This project list would contain information that is currently collected later in the grant cycle in the post-award phase. However, while GAO's analysis of selected grant projects determined that this additional information was sufficient for identifying potentially unnecessary duplication for nearly all of the projects it reviewed, the information did not always provide the FEMA with sufficient detail to identify and prevent the risk of unnecessary duplication.
Specifically, GAO reviewed the type of information that FEMA would have available at the applications stage if it implemented the May 2011 report recommendation. GAOs analysis of 1,957 projects, using post-award information as recommended in the report, determined that over 1,800 of the projects representing about 90 percent of the overall funding had the detail needed to determine whether they were unnecessarily duplicative. However, 140 projects, or 9.2 percent of the overall funding associated with the 1,957 projectsabout $183 millionlacked sufficient detail to determine whether they were unnecessarily duplicative or had involved coordination during the states planning or selection processes to prevent any unnecessary duplication. For example, in one instance GAO identified overlap in the descriptions of the project types and titles of State Homeland Security Program, Urban Areas Security Initiative, and Port Security Grant Program grants that funded critical infrastructure improvements in a single port area. This overlap suggested that duplication could be occurring among the grant programs, and warranted further analysis.
After gathering additional information from state and local grant recipients, however, GAO determined that none of the projects it reviewed were duplicative. While implementing the May 2011 report recommendation to better utilize more specific project-level data would be a step in the right direction, the Director of FEMAs Grants Preparedness Division reported in September 2011 that FEMA had not yet determined the specifics of future data requirements related to the reports recommendation. GAO was able to ascertain that over 90 percent of the projects it reviewed had sufficient detail to determine that the projects were not likely duplicative. However, GAO believes that more detailed project information could be of value to FEMA in its grant review process since the information that would be gathered and considered, if the reports recommendation were implemented, would not always allow for the necessary differentiation between projects funded by the four grant programs. Moreover, DHSs Office of Inspector General has also concluded in recent years that FEMA should utilize more specific project-level data in making grant award decisions, especially for the State Homeland Security Program and Urban Areas Security Initiative, in order to identify and mitigate potential duplication.
Another effort that FEMA has initiated to improve its grant information is the phase-in of a new consolidated grants management systemthe Non-Disaster Grants system. Agency officials stated that this system, once completed, will help FEMA manage all of its preparedness grants, and has an explicit goal of enhancing project-level data collection. In addition, FEMA anticipates that the Non-Disaster Grants system will consolidate data from multiple systems and facilitate greater utilization and sharing of information. However, according to FEMA documentation, the agency has not yet determined all of its specific data needs for the system. As FEMA continues to develop the Non-Disaster Grants system, it will be important to ensure that it collects the level of data needed, as appropriate, to compare projects across grant programs to mitigate the risk of funding unnecessarily duplicative projects. GAO recognizes that collecting more detailed project information through the new system could involve additional costs. However, collecting additional information with this level of detail could help better position FEMA to ensure that it is using its resources effectively.
GAO also reported in February 2012 that FEMA lacks a process to coordinate application reviews across the four grant programs. FEMAs Grants Program Directorate has divided the administration of the grant programs into two separate branches: The Urban Areas Security Initiative and State Homeland Security Program are administered by a Homeland Security Grant Program branch, while the Port Security Grant Program and Transit Security Grant Program are administered by a Transportation Infrastructure Security branch. The result of this structure is that grant applications are reviewed separately by program and are not compared across each other to determine where possible unnecessary duplication may occur. Similar findings were also reported by the DHS Inspector General in March 2010.
As noted earlier, each grant program GAO reviewed has similar goals, allowable costs, and geographic proximity. As a result, these four programs share applicants as state and local entities seek to maximize grant dollars for their projects; however, FEMA does not compare applications, including the investment justifications, for these overlapping grant programs. As a result, neither FEMA nor an independent third party is positioned to determine where unnecessary duplication may occur.
Because the applications for the four grant programs are being reviewed by two separate divisions, yet have similar allowable costs, GAO and the DHS Inspector General concluded that coordinating the review of grant projects internally would give FEMA more complete information about applications across the four grant programs. This additional information could help FEMA identify and mitigate the risk of unnecessary duplication across grant applications. A FEMA Grants Program Directorate Section Chief 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 FEMAs lack of resources to coordinate the grant application review process. GAO recognizes the challenges associated with reviewing a large volume of grant applications, but to help reduce the risk of funding unnecessarily duplicative projects, FEMA could benefit from exploring opportunities to coordinate project reviews across grant programs while also taking into account the large volume of grant applications it must process.
In addition, from fiscal year 2010 to 2012, appropriations for DHSs preparedness grant programs declined from $3.02 billion to $1.35 billionor about 55 percent. Further, the consolidated appropriations act for fiscal year 2012 combined funding for DHSs preparedness grant programs into a single appropriation and provided the Secretary of Homeland Security with the discretion to distribute this funding amongst the suite of preparedness grant programs. Specifically, the appropriations for these four programs declined by about $487 millionor about 20 percentfrom fiscal year 2010 to 2011. However, the fiscal year 2012 funding levels for these four programs are unclear at this time because the Secretary of Homeland Security has not yet determined how to distribute available funding amongst the grant programs. Given the significant overlap in these grant programs and the risk of unnecessary duplication, requiring additional information on FEMAs efforts to identify and eliminate overlap may be helpful to the Congress as it makes future decisions regarding preparedness grant funding.
See 6 U.S.C. §§ 604, 605.
A designated state administrative agency is responsible for managing the State Homeland Security Program and Urban Areas Security Initiative 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.
Investment justifications are one component of the State Homeland Security Program, the Urban Areas Security Initiative, the Port Security Grant Program, and the Transit Security Grant Program 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 investment justifications must demonstrate how proposed investments address gaps and deficiencies in current capabilities, and also demonstrate adherence to program guidance.
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 regarding future data collection policies. FEMA utilized the working groups analysis and recommendations in a May 2011 Report to Congress.
See FEMA, Redundancy Elimination and Enhanced Performance for Preparedness Grants Act: Initial Report to Congress (Washington, D.C.: May 23, 2011) for their findings and recommendations.
We reviewed investment justification and Biannual Strategy Implementation Report informationThe Biannual Strategy Implementation Report is a reporting requirement submitted by states to FEMA regarding the progress of certain grantsfor 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.
Department of Homeland Security Office of Inspector General, Efficacy of DHS Grant Programs, OIG-1069 (Washington, D.C.: Mar. 22, 2010).
 This total is comprised of preparedness grant programs in FEMAs state and local programs account, which does not include firefighter assistance grants and emergency management performance grants.
See H.R. Rep. No. 112-331, at 175-77 (2011) (Conf. Rep.).
The State Homeland Security Program, Urban Areas Security Initiative, Port Security Grant Program, and Transit Security Grant Program have similar goals and fund similar activities in overlapping jurisdictions. In a constrained budget environment, it is important for FEMA to have the information it needs about projects funded through these programs and to coordinate their administration to maximize their impacts on improving homeland security and avoid the risk of any unnecessary duplication. Although reviewing a large volume of grant applications is challenging, these reviews are important to better ensure that FEMA is able to identify and prevent any potential unnecessary duplication, and that limited grant resources are used effectively.
GAO recommended in its February 2012 report that to help reduce the risk of unnecessary duplication by strengthening the administration and oversight of these programs, the FEMA Administrator should
In addition to these recommendations to DHS from GAOs February 2012 report, Congress may also want to consider
The information contained in this analysis is based on findings from the products listed in the related GAO products section. GAO took several actions to determine how FEMA awarded grant funds and how funds were distributed. GAO interviewed officials at DHS and FEMA and visited five urban areas that contained grant recipients for all four grant programs and were among the highest annual grant recipients in fiscal year 2010 due to their risk profile. In each of these locations, GAO interviewed officials responsible for administering the program (state and local officials for the State Homeland Security Program/Urban Areas Security Initiative; fiduciary agents for the Port Security Grant Program; and transit agency officials for Transit Security Grant Program). GAO also met with grant recipients and members of the local coordination or project selection groups (e.g., Urban Area Working Group for the Urban Areas Security Initiative). Additionally, GAO reviewed grant guidance, legislation and prior GAO and Department of Homeland Security Inspector General reports; analyzed grant awards; and reviewed state and national plans related to homeland security grant programs. See page 344 of the PDF version of this report (appendix III) for a list of the programs GAO identified that may have similar or overlapping objectives, provide similar services or be fragmented across government missions. Overlap and fragmentation may not necessarily lead to actual duplication, and some degree of overlap and duplication may be justified.
GAO requested comments on this report section from Justice. In technical comments, Justice stated that using funding from multiple grant programs may be necessary to fully implement law enforcement projects in light of limited local and federal resources. GAO acknowledges that there may be cases where funding in this manner is warranted, but without an assessment of the extent of overlap across Justice grant programs, combined with consistent and routine grant award coordination, there is an increased risk of unnecessary duplication in grant awards. Justice also provided additional technical comments, which GAO incorporated as appropriate.
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