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Federal Emergency Management Agency: Crisis Counseling Grants Awarded to the State of New York after the September 11 Terrorist Attacks

GAO-05-514 Published: May 31, 2005. Publicly Released: Jun 30, 2005.
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Highlights

To help alleviate the psychological distress caused by the September 11, 2001, attacks the Federal Emergency Management Agency (FEMA) awarded the state of New York two grants totaling $154.9 million to provide crisis counseling and public education. Because of questions about whether the program, called Project Liberty, had spent all the funds it received from the federal government, GAO was asked to determine (1) the extent to which the program expended the funds awarded from the federal government, (2) whether the federal government had an effective process in place to determine the amount of funds to provide the program, (3) whether the federal government had adequate financial oversight of the program, and (4) steps taken by the federal government and New York State to assess the program's effectiveness.

For the period September 11, 2001, through September 30, 2004, Project Liberty reported that it had expended approximately $121 million, or three-quarters of the $154.9 million in grants awarded by FEMA, leaving a remaining balance of $33.9 million. The majority of the remaining balance, approximately $32 million, related to unresolved issues involving the adequacy of supporting documentation for the New York City Department of Education's (NYC DOEd) expense claims. As of March 31, 2005, city and state officials told GAO they had accepted alternative forms of supporting evidence related to $5.2 million in NYC DOEd expenses; however, this alternative evidence provides only limited assurance of the propriety of the claimed amounts. It is unclear whether similar alternative sources of evidence will be accepted for the remaining $26.8 million in NYC DOEd expense claims. FEMA assisted state officials in developing estimated funding needs for Project Liberty immediately after the terrorist attacks. By necessity, these initial budgets were developed using estimates established during the initial stages of the disaster. However, FEMA never required Project Liberty to prepare adjusted budgets to reflect new information or subsequent changes to the program. As a result, FEMA did not have realistic budget information to assess how city and state officials were planning to spend Project Liberty grant funds. FEMA assigned primary responsibility for oversight and monitoring to the Substance Abuse and Mental Health Services Administration (SAMHSA) through an interagency agreement. Although SAMHSA had procedures in place to monitor Project Liberty's delivery of services, it performed only limited monitoring of financial information reported by Project Liberty about the cost of those services. For example, while SAMHSA received periodic financial reports from Project Liberty, it did not perform basic analyses of expenditures in order to obtain a specific understanding of how the grant funds were being used and, as noted above, did not have updated budget information to gauge how actual spending compared to budgets. As a result, SAMHSA was not in a position to exercise a reasonable level of oversight to ensure that funds were being used efficiently and effectively in addressing the needs of those affected by the September 11 attacks. Both the state of New York and the federal government have taken steps to assess how Project Liberty delivered services. These assessments were ongoing as of March 2005. FEMA plans to consider lessons learned from Project Liberty when conducting its own internal review of the crisis counseling program.

Recommendations

Recommendations for Executive Action

Agency Affected Recommendation Status
Directorate of Emergency Preparedness and Response In order to address the issues identified and to help ensure proper and timely expenditure of the remaining Project Liberty funds, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to determine whether an independent review of the propriety of the use of funds for payments to the NYC DOEd is needed.
Closed – Implemented
SAMHSA determined that audits of DoEd claims were necessary to establish their propriety. Audits of NYC Department of Education (DoEd) claims made for funds FEMA granted to New York State for a Regular Services Program (RSP) under its Crisis Counseling Assistance and Training Program (CCP) were completed in December 2005. The CCP is administered by FEMA and its federal partner, the Substance Abuse and Mental Health Services Administration (SAMHSA), an agency of the Department of Health and Human Services (HHS).
Directorate of Emergency Preparedness and Response In order to address the issues identified and to help ensure proper and timely expenditure of the remaining Project Liberty funds, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to provide assistance to New York City and State officials in appropriately resolving issues surrounding the NYC DOEd expense reimbursements.
Closed – Implemented
Audits of NYC Department of Education (DoEd) claims made for funds FEMA granted to New York State for a Regular Services Program (RSP) under its Crisis Counseling Assistance and Training Program (CCP) were completed in December 2005. The CCP is administered by FEMA and its federal partner, the Substance Abuse and Mental Health Services Administration (SAMHSA), an agency of the Department of Health and Human Services (HHS). SAMHSA determined that audits of DoEd claims were necessary to establish their propriety. These audits resolved all remaining DoEd claims, with final payment made to DoEd on March 20, 2006.
Directorate of Emergency Preparedness and Response In order to address the issues identified and to strengthen federal financial oversight of future Crisis Counseling Assistance and Training Program (CCP) grants, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to require the recipients of CCP grants to submit updated budgets to reflect approved changes to the program.
Closed – Implemented
On November 15, 2007, FEMA issued Crisis Counseling Assistance and Training Program Guidance. This guidance requires that any budget adjustments of 11 percent or more must be approved by either the SAMHSA Center for Mental Health Services or the SAMHSA grants management officer using a Request for Budget Adjustment letter.
Directorate of Emergency Preparedness and Response In order to address the issues identified and to strengthen federal financial oversight of future CCP grants, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to revise the current risk assessment process to comprehensively identify and assess risks associated with CCP grants.
Closed – Not Implemented
FEMA's Monitoring Plan, which provides a comprehensive and systematic approach to assessing risks associated with grants, applies only to Immediate Services Program (ISP) grants made under the Crisis Counseling Program (CCP), but not to Regular Services Program (RSP) grants. Importantly, FEMA did not provide GAO with adequate evidence that a risk assessment process sufficiently equivalent to its Monitoring Plan for ISP grants exists for the RSP, which is the larger and longer lasting of the two CCP grant programs. ISP grants are typically for services provided for the first 60 days following a disaster declared eligible for federal assistance by the President, whereas RSP grants are provided for services beyond 60 days. Further, according to FEMA officials we spoke to, ISP risk assessments (and levels and results of monitoring) performed by FEMA's Grants Program Directorate (GPD) are not shared with FEMA's CCP program managers and officials from the Substance Abuse and Mental Health Services Administration (SAMHSA) of HHS that FEMA relies on to provide programmatic oversight of RSP grants. Thus, GAO was unable to determine that the risk assessment process FEMA had in place at the time of our review had been adequately revised to comprehensively identify and assess risks associated with all CCP grants.
Directorate of Emergency Preparedness and Response In order to address the issues identified and to strengthen federal financial oversight of future CCP grants, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to establish a process to update the risk assessment for significant program changes.
Closed – Not Implemented
FEMA did not provide GAO with adequate evidence that a process exists for updating CCP grant risk assessments for significant program changes. Specifically, it is not clear that FEMA CCP managers and SAMHSA personnel are regularly determining whether changes to the program and other factors have an impact on how financial-related risks are assessed and should affect how grants and grantees should be monitored. CCP consists of Immediate Service Program (ISP) grants, whose risk is assessed and monitored by grants management specialists using a process developed by FEMA's Grants Program Directorate (GPD), and Regular Service Program (RSP) grants, whose risk is assessed and monitored by grants management specialists from HHS' Substance Abuse and Mental Health Services Administration (SAMHSA) using HHS's own risk assessment process. Risk assessments are not made at the CCP level, but at the ISP and RSP level for individual grants. So, since FEMA was unable to demonstrate that program changes and other factors are captured in either the FEMA or HHS risk assessment processes, GAO is unable to determine that an adequate process exists to update CCP risk assessments.
Directorate of Emergency Preparedness and Response In order to address the issues identified and to strengthen federal financial oversight of future CCP grants, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to consider developing formal requirements for consistent classifications of expense data.
Closed – Implemented
On November 15, 2007, FEMA issued Crisis Counseling Assistance and Training Program (CCP) Guidance that requires quarterly reports from the CCP grantees to include expenditure reporting consistent with the cost categories and budget line items listed in the approved budget.
Directorate of Emergency Preparedness and Response In order to address the issues identified and to strengthen federal financial oversight of future CCP grants, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to work with SAMHSA to develop formal procedures to perform more detailed analyses of financial reports, including comparing actual expenditures and budgets to identify variations and obtain an understanding of the reasons for any unusual variations.
Closed – Implemented
A Crisis Counseling Assistance and Training Program (CCP) interagency agreement was issued June 20, 2008 between FEMA and SAMHSA. The agreement requires that SAMHSA review quarterly reports containing budget and expenditure information submitted by grantees. The agreement also requires SAMHSA to summarize specific issues or concerns in writing. After the second quarterly report is received, the agreement requires SAMAHA to issue a summary focusing on issues and recommendations identified for corrective action based on a review of the quarterly reports and a site visit.
Directorate of Emergency Preparedness and Response In order to address the issues identified and to help ensure that the lessons learned from Project Liberty will be used to help improve future programs funded by CCP, the Secretary of Homeland Security should direct the Under Secretary of Emergency Preparedness and Response to direct FEMA to establish a clear time frame to complete its internal review of the CCP as expeditiously as possible.
Closed – Implemented
Although FEMA never established a time frame for completing the internal review of the CCP, FEMA and SAMHSA nonetheless did complete the review, thereby achieving GAO?s intention and stated view that completing the internal review would help ensure that the lessons learned from Project Liberty will be used to improve future programs funded by the CCP. FEMA explained that due to several leadership changes within FEMA's Recovery Directorate between 2009 and 2011, the "white paper" draft report issued in July 2009 was not formally reviewed at the Directorate level until January 2011. FEMA officials told GAO that at that time FEMA and SAMHSA representatives met and it was decided that, due to a change in leadership at FEMA's Recovery Directorate, the draft report would not be signed and issued as an official FEMA-SAMHSA document, but rather would be retained as an internal working document guiding the implementation of the recommendations. These recommendations included changes to program and services, such as individual and community interventions; collection and evaluation of data, such as data related to contacts with children; staffing of CCP teams and supervision and training of crisis counselors; and program policy and regulations. According to FEMA officials, actions on those recommendations FEMA agreed to have been completed or are part of an on-going effort by FEMA, SAMHSA, and interagency working groups. Consequently, this internal review of the CCP, which included consideration of lessons learned from Project Liberty, and those actions taken by FEMA and SAMHSA on the review's recommendations, will benefit counseling programs implemented following future crises.

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Disaster recoveryDisaster relief aidEmergency managementFederal aid to statesFederal fundsFederal grantsFinancial analysisFinancial managementFund auditsFunds managementGrants to statesInteragency relationsInternal controlsMental healthProgram evaluationTerrorismFederal and state relations