The Office of Inspector General (OIG) says the Federal Emergency Management Agency (FEMA) must improve its oversight of the Emergency Food and Shelter Program (EFSP). Since the program’s inception, there have been 38 program phases through fiscal year 2020, and four special appropriations, including the Coronavirus Aid, Relief, and Economic Security Act3 (CARES Act).
An OIG audit has found that from fiscal years 2017 through 2020, the National Board did not spend about $58 million of the $560 million (10.4 percent) in appropriated grant funds for the EFSP. The unspent funds fell into two groups: unclaimed – the Board allocated $37.0 million to State Set-Aside Committees (SSAs) and Local Boards (LBs), but the SSAs and LBs did not submit a board plan to claim the funds; and unpaid – the Board awarded $21.2 million to Local Recipient Organizations (LROs), but an EFSP official told auditors that the LROs did not receive payment due to, among other reasons, unresolved compliance issues related to previous awards.
OIG also found that FEMA’s EFSP program office was unable to identify areas in which the program achieved its goals or needed improvement. Although FEMA and the Board collected some program data, FEMA did not analyze the collected data to help improve EFSP. In particular, for all four phases in OIG’s audit scope, FEMA required reporting on the total number of provided meals, sheltered nights, rent or mortgage payments, and utility payments. However, FEMA did not develop or ensure the Board developed performance goals and adequate performance measures to provide insight into EFSP’s progress and help make informed programmatic decisions. The watchdog adds that the Board and its fiscal agent did not have written policies and procedures for certain key areas, such as establishing an agreement or contract for the fiscal agent’s duties, periodically reviewing the formula used to allocate grant funds, and assessing risk. OIG found that the Board did not enforce established guidance, and that this negatively affected how it administered the program.
The CARES Act requires EFSP supplemental funds (CARES Act funds) be used specifically to prevent, prepare for, and respond to COVID-19. According to FEMA’s grant management manual, “Appropriated funds may only be used for the purpose for which Congress made the appropriation.” However, OIG found that FEMA did not specifically measure how $200 million in CARES Act funds helped those affected by COVID-19.
The audit determined that these failings occurred because FEMA’s oversight and the Board’s administration of EFSP have remained static during the past several decades. A FEMA official told OIG that the program office is made up of one full-time FEMA employee who handles the day-to-day oversight of the entire EFSP, with two officials who help, as needed. One FEMA official said that FEMA employees learned their roles from predecessors and on-the-job training and did not have program-specific job aids, written standard operating procedures, or desk manuals. FEMA and Board officials did not believe the program’s success was measurable due to the emergency nature of the program and said their main goal was to get the funds disbursed quickly.
OIG is calling for FEMA and the Board to adequately document and implement policies and procedures to ensure the program more effectively and efficiently assists those in need. To this end, the watchdog has made ten recommendations to FEMA:
- Collaborate with the National Board to reallocate all unclaimed and unpaid funds for all phases with closed spending periods to the earliest possible phase.
- Collaborate with the National Board to develop a more proactive approach to determine, as early in the process as possible, whether LBs and SSAs are willing to accept funds, so that funds can be reallocated from jurisdictions unwilling or unable to participate in EFSP.
- Collaborate with the National Board to ensure FEMA’s fiscal agent (United Way Worldwide) performs a periodic analysis of LBs and SSAs that have routinely not accepted funds and determine whether LBs and SSAs can be reestablished.
- Collaborate with the National Board to ensure United Way Worldwide develops and implements policies and guidance to LBs to follow when LROs with outstanding compliance issues apply for EFSP funding.
- Develop and implement written policies on FEMA’s roles, responsibilities, and procedures for operating EFSP.
- Collaborate with the National Board to increase analysis of EFSP performance and ability to deliver funds and assess program participation during each phase.
- Ensure the National Board includes performance goals and measures in its guidance or grant recipient documentation for verifying the acceptance of funds, as well as performance goals and measures for addressing any unique requirements, such as those in the CARES Act for COVID-19, in future supplemental appropriations. FEMA should also work with the National Board to track and analyze these performance goals and measures.
- Collaborate with the National Board to establish a contract, memorandum of understanding, or other written agreement mechanism with EFSP’s fiscal agent and secretariat to establish requirements and expectations.
- Collaborate with the National Board to establish a formal board charter and develop and implement written policies and procedures including, but not limited to, periodically reviewing the direct allocation formula and a risk assessment of LBs and LROs for the compliance review process.
- Collaborate with the National Board to implement a plan to enforce already established guidance including LBs’ deadlines for board plan submission and the disbursement of funds to LROs within the McKinneyVento Homeless Assistance Act’s three-month required timeframe.
FEMA concurred with recommendations three through nine and will work to complete the actions needed by June 30, 2023. Officials stressed however that FEMA has one of seven votes on the National Board and cannot unilaterally guarantee changes in how EFSP is implemented. FEMA did not agree with OIG’s first, second and tenth recommendations. OIG disagreed with FEMA’s assertions or required supporting documentation and has therefore kept the recommendations open.