Lack of performance targets contributed to weak local preparedness system
Weakness in demonstrating improvement and measurable accomplishments of homeland security funded projects — as well as weakness in preparing and prioritizing investment justifications — are two contributing factors to American Samoa’s inability to integrate the National Preparedness System components into an efficient and effective system, a federal performance audit report says.
The audit report was prepared by the U.S. Department of Homeland Security’s Office of Inspector General on American Samoa Department of Homeland Security (ASDHS) management of the USDHS’ State Homeland Security Program (SHSP) grants for fiscal years 2009 thru 2011.
The audit identified three reasons for the local department’s failure to put together an efficient and effective local preparedness system based on the national components with the third reason — a weakness of the territory in utilizing governing bodies — reported on in last Friday’s edition.
NO MEASURABLE TARGET LEVELS OF PERFORMANCE
According to the report, reviews and updates of the Territory’s State strategies for FYs 2009 through 2011 were ineffective because the strategies did not include appropriate goals, objectives, and implementation steps; or did not address the Territory’s needs for basic emergency response capabilities.
The report went on to say that “monitoring and reporting program performance” is required of the grantee to ensure compliance with applicable federal requirements and to ensure that performance goals were being achieved.
“However, ASDHS could not demonstrate specific improvements and measurable accomplishments of SHSP funded projects because it did not monitor grant implementation,” it says.
“As a result, ASDHS did not have a basis for measuring improvements in its preparedness and response capabilities,” it pointed out.
The report cites ASDHS officials saying they measured improvements in preparedness every time the Emergency Operations Center (EOC) was activated; however, OIG says activating the EOC may be a means to validate capabilities, but only if a measurable target level of performance has been established.
ASDHS officials were further cited in the report saying that progress towards increasing their level of preparedness was reported to USDHS annually with their submission of the State Preparedness Report (SPR) and the Threat and Hazard Identification Risk Assessment (THIRA)
However, the auditors say the “FY 2011 SPR did not report improvements in capabilities; did not identify risks, vulnerabilities, or needs; did not crosswalk to the goals and objectives in the State strategies; and did not contain any performance measures.”
LACK OF INVESTMENT JUSTIFICATIONS
According to the performance audit report, FEMA guidance for preparing Investment Justifications grant applications for FYs 2009 to 2011, required States and U.S. Territories to describe how terrorism and natural hazards influenced the development of the investments (projects), identify State strategy goals, objectives, and milestones associated with each project; and describe each project, including funding for each solution area.
“ASDHS did not adequately describe the spectrum of terrorism and natural hazard risks that the Territory faced or explain how this understanding influenced development of the grant applications,” it says.
The report cites ASDHS officials saying that in its FYs 2009 and 2010 SPRs, the freeze in USDHS/FEMA funding, limited progress being made toward specific target capabilities.
(Samoa News should point out that this freeze in funding, stemmed from a 2007 financial audit, which found several problems with administrating homeland security grants.)
Departments and agencies did submit their needs in the form of Investment Justifications for projects, but the identified needs were not based on formal risk assessments, the report noted.
“While expected outcomes were identified by ASDHS, there was no specificity in project documentation to indicate how these outcomes would be achieved,” the auditors said, and noted that new projects were proposed, but older projects were never started or remained incomplete with needed capabilities unmet. Citing examples, the report notes several projects as “vague and incomplete”.
“According to FEMA officials, advance planning and grant oversight were systemic problems with the Territory,” it says.
The report cited the following from the FYs 2010 and 2011 State strategies, “The reality for isolated territories with weak economies such as American Samoa is that we remain deficient in most aspects of basic emergency response services.
“It is critical that recognition of American Samoa’s unique status directs attention to these deficits and acknowledges the need to replace antiquated basic emergency response equipment and update training in order to benefit from technological advances in emergency response, lessons learned, and documented best practices,” it stated.
USDHS-OIG’s recommendation is to stabilize the ASDHS organization by defining the roles and responsibilities of ASDHS staff in relation to the responsibilities of ASDHS.
FEMA concurred and will require ASDHS to develop a staffing plan that encompasses authorized staff positions with approved job descriptions that can support its unique homeland security organizational activities.
In response, ASDHS says its leadership has introduced a new organizational chart which has been reviewed by Department of Human Resources and Office of Budget and Planning.
In addition, position descriptions further defining the roles and responsibilities of ASDHS personnel in relation to the mission and mandated functions of the Department have been submitted.
Another recommendation is for ASDHS to design and implement an integrated preparedness system that demonstrates to FEMA that the leadership activities of ASDHS align with the priorities and goals of the American Samoa Government and address the components of the National Preparedness System.
FEMA concurred and stated that the integrated preparedness system has its basis in the strategic plan and planning process, part of which is designed to help the Territory establish measurable goals and objectives and systematically measure improvements in first responder capabilities and Territory-wide preparedness.
ASDHS said it is willing to revisit its preparedness system process to ensure that the leadership activities of ASDHS align with the priorities and goals of the Territory.
The local homeland security department also says it will ensure performance measures are documented and Investment Justifications and other reports are sufficiently monitored with a view toward achieving goals and objectives.
More on the audit report later this week.