ASDHS has "fragmented approach" to preparedness


An independent “performance audit” of a federal grant program awarded to the American Samoa Department of Homeland Security (ASDHS) found many problems, such as failure to identify and assess the territory’s risks and vulnerabilities, as well as non compliance with required training and exercise activities.
The audit was conducted between January and June of last year by the Washington D.C based certified public accountant firm of Foxx & Company. The performance audit centered on American Samoa’s management of the U.S. Department of Homeland Security’s (USDHS) State Homeland Security Program (SHSP) grants for fiscal years 2009 thru 2011.
“Although the audit report comments on costs claimed by American Samoa, we did not perform a financial audit,” Martin W. O’Neill, a partner in the firm, wrote in a Nov. 14, 2013 cover letter to Anne L. Richards, the assistant inspector general for auditors of the USDHS Office of Inspector General. The letter included results of the audit.
Results of the performance audit and 17 recommendations — aimed at improving the overall effectiveness of American Samoa’s management of SHSP grants—was incorporated in the USDHS-OIG report to Brian E. Kamoie, assistant administrator of grant programs directorate of the Federal Emergency Management Agency, a bureau of USDHS.
According to OIG, the audit was to determine whether the Territory spent SHSP grant funds effectively and efficiently, and in compliance with applicable Federal laws and regulations. It also addressed the extent to which grant funds enhanced American Samoa’s “ability to prevent, prepare for, protect against, and respond to natural disasters, acts of terrorism, and other manmade disasters.”
During FYs 2009 to 2011, FEMA awarded the territory $4.1 million in SHSP grants, but only a “small portion” of the grants for these fiscal years had been obligated and expended, resulting in the review of personnel charges against the FY 2008 grant.
As of Jan. 25, 2013, only $204,000 of the grant awards had been obligated and expended, the audit says.
It also noted the territory “did not aggressively manage [SHSP] grant funds, did not adequately identify and assess its risks and vulnerabilities, and did not measure its progress in achieving needed capabilities.”
Additionally, the territory also did not comply with federal requirements regarding training and exercise activities, property management, and accounting for personnel time charges. “As a result, the territory’s preparedness was not in compliance with the FEMA requirements in the areas of emergency response equipment, training, and exercises,” the audit report says.
“We questioned costs totaling $52,292 that resulted from charging fiscal year 2012 management and administration costs against the fiscal year 2008 grant.”
It also says that the 17 recommendations in the report call on FEMA to initiate improvements, which, if implemented, should strengthen grant program management, performance, and oversight.
FEMA and the Territory concurred with all 17 recommendations it says, and included in the 65-page report written comments from both FEMA and ASG that are incorporated into the OIG report.
(Samoa News should point out that the current Lolo Administration took office in January last year, while the fiscal years covered in the performance audit covered the previous administration, which helped address several issues surrounding questionable spending in a USDHS-OIG financial audit of several programs.)
One of the findings in the audit deals with the territory’s Preparedness System, and the audit says ASDHS did not approach preparedness based on the components of the National Preparedness System (NPS), which states that implementation of the system will result in integration of the following components into an efficient and effective system: identifying and assessing risk; estimating capability requirements; building and sustaining capabilities; planning to deliver capabilities; validating capabilities; and reviewing and updating.
Instead, the audit says, the territory used a fragmented approach in its efforts to enhance preparedness capabilities. For example, the territory’s preparedness system consisted primarily of ASDHS taking the actions required to secure grant funding — e.g. periodic review and update of State Homeland Security Strategies, submission of State Preparedness Reports (SPRs), and submission of grant applications.
As a result of the “fragmented approach”, the Territory did not adequately identify and assess risks and vulnerabilities, accurately estimate capability requirements, or build, sustain, or plan to deliver capabilities, the report says.
Until the Territory designs and implements an integrated preparedness system based on the NPS, “lives and infrastructure could be at risk” because:
•            the risk to the Territory based on threats, vulnerabilities, and consequences will not be fully known.
•            core capability requirements will remain uncertain.
•            opportunities to enhance capabilities across the five mission areas of prevention, protection, mitigation, response, and recovery will be lost.
•            basic emergency response needs will remain unmet.
•            the ability to validate plans and capabilities through exercises will be minimal.
•            reviews of plans, resources, and capabilities will not provide the means to examine preparedness, determine priorities, direct preparedness actions, adjust goals and objectives, and monitor major programs that impact preparedness.
According to the report, three factors that contributed to the “Territory’s inability to integrate” the NPS components into an efficient and effective system are:
Weaknesses in utilizing governance bodies,
Demonstrating improvements and measurable accomplishments of SHSP funded projects, and,
Preparing and prioritizing investment justifications.
Samoa News will report tomorrow on the three factors lacking in a local preparedness system, including what the auditors had to say about ASDHS governance bodies that are charged with overseeing SHSP funding, but which were " ineffective” in their duties. There will also be a look at the recommendations and ASDHS response.
During the course of the audit, Foxx & Company auditors met with FEMA officials and conducted reviews and interviews at FEMA Headquarters and FEMA Region IX, whose officials provided important background information and key documentation concerning the Territory’s management and expenditure of the SHSP grants.
The auditors visited the territory and interviewed ASDHS and TEMCO officials, reviewed documentation supporting Territory management of the awarded grant funds (including expenditures for equipment, training, and exercises), and physically inspected some of the equipment procured with the grant funds.
Auditors also met with representatives of Treasury and Public Works departments as well as officials with the Office of Procurement. The territory did not award funds to any sub-grantees.


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