FEMA Needs to Improve
Management of Its
Flood Mapping Programs
September 27, 2017
OIG-17-110
DHS OIG HIGHLIGHTS
FEMA Needs to Improve Management of Its
Flood Mapping Programs
September 27, 2017
Why We Did
This Audit
Flood hazard identification
and mapping is an integral
part of the National Flood
Insurance Program (NFIP) as it
creates the foundation for
floodplain management, flood
insurance, and mitigation. We
sought to determine whether
the Federal Emergency
Management Agency’s (FEMA)
Risk Mapping, Assessment
and Planning Program (Risk
MAP) resulted in the
production of timely and
accurate flood maps in
accordance with NFIP
requirements.
What We
Recommend
We made four
recommendations designed to
improve FEMA’s management
and oversight of its flood
mapping programs.
For Further Information:
Contact our Office of Public Affairs at
(202) 254-4100, or email us at
What We Found
FEMA is unable to assess flood hazard miles to meet its
program goal and is not ensuring mapping partner quality
reviews are completed in accordance with applicable
guidance. FEMA needs to improve its management and
oversight of flood mapping projects to achieve or reassess
its program goals and ensure the production of accurate
and timely flood maps. Specifically, FEMA –
x needs to improve its financial management of flood
map projects to achieve or to reassess its
program goal of 80 percent New, Valid, or Updated
Engineering program miles;
x has not updated its Risk MAP life cycle cost estimate
to inform critical decision making;
x lacks uniform, centralized policies and procedures
for projects placed on hold; and
x is not performing adequate oversight to ensure
mapping partner quality reviews comply with
requirements set forth in applicable guidance.
Without accurate floodplain identification and mapping
processes, management, and oversight, FEMA cannot
provide members of the public with a reliable rendering of
their true flood vulnerability or ensure that NFIP rates
reflect the real risk of flooding.
FEMA’s Response
FEMA noted that it has made significant progress
developing and implementing several flood-related policy
and program changes since the Office of Inspector General
began this audit. FEMA remains strongly committed to
providing credible risk information to communities so that
they can make informed flood risk management decisions.
The report contained four recommendations with which
FEMA concurs.
www.oig.dhs.gov OIG-17-110
OFFICE
OF
INSPECTOR GENERAL
Department
of
Homeland
Security
Washington,
DC
20528
/
www.oig.dhs.gov
September 27, 2017
MEMORANDUM FOR:
Angela
Gladwell
Risk
Management
Deputy
Assistan
t
Administrator
Federal
Insurance
and
Mitigation
Administration
Federal
Emergency
Management
Agency
FROM:
John
V.
Kelly
_...,
Deputy
Inspector
General
SUBJECT:
FEMA
Needs
to Improve
Management
of
its
Flood
Mapping Programs
Attached
for
your
action
is
our
final
report,
FEMA
Needs
to Improve
Management
of
its
Flood Mapping Programs. We
incorporated
the
formal
comments
provided
by
your
office.
The
report
contains
four
recommendations
aimed
at
improving
FEMA's
management
and
oversight
of
its
flood
mapping
programs.
Your
office
concurred
with
all
four
recommendations.
Based
on
the
information
provided
in
your
response
to
the
draft
report,
we
consider
recommendations
1
and
2
open
and
resolved.
Once
your
office
has
fully
implemented
the
recommendations,
please
submit
a
formal
closeout
letter
to
us
within
30
days
so
that
we
may
close
the
recommendations.
The
memorandum
should
be
accompanied
by
evidence
of
completion
of
agreed
upon
corrective
actions
and
the
disposition
of
monetary
amounts.
We
consider
recommendations
3
and
4
open
and
unresolved.
As
prescribed
by
the
Department
of
Homeland
Security
Directive
077-01,
Follow-Up
and
Resolutions
for
the
Office
of
Inspector
General
Report
Recommendations,
within
90
days
of
the
date
of
this
memorandum,
please
provide
our
office
with
a
written
response
that
includes
your
target
completion
date
for
each
recommendation.
Please
send
your
response
or
closure
request
to
OIGAudi
t
sFo
ll
owup@oig
.
dhs.gov
.
Consistent
with
our
responsibility
under
the
Inspector
General Act,
we
will
provide
copies
of
our
report
to
appropriate
congressional
committees
with
oversight
and
appropriation
responsibility
over
the
Department
of
Homeland
Security.
We will
post
the
report
on
our
website
for
public
dissemination.
Please
call
me
with
any
questions,
or
your
staff
may
contact
Maureen
Duddy,
Deputy
Assistant
Inspector
General
for
Audits,
at
(617)
565-8723.
Attachment
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Table of Contents
Background .................................................................................................... 1
Results of Audit .............................................................................................. 3
Management of Flood Mapping Projects Needs Improvement .................. 3
FEMA Should Enhance Its Oversight of
Mapping Partner Quality Reviews .......................................................... 7
Conclusion .......................................................................................... 10
Recommendations ......................................................................................... 11
Appendixes
Appendix A: Objective, Scope, and Methodology ................................. 14
Appendix B: FEMA Comments to the Draft Report ............................... 17
Appendix C: Report Distribution .......................................................... 21
Abbreviations
ECD estimated completion date
FEMA Federal Emergency Management Agency
FIRM or flood map Flood Insurance Rate Map
LCCE life cycle cost estimate
MIP Mapping Information Platform
Needs Database Coordinated Needs Management Strategy
Database
NFIP National Flood Insurance Program
NVUE New, Valid, or Updated Engineering
OIG Office of Inspector General
QR quality review
Risk MAP
Risk Mapping, Assessment and Planning Program
RMD Risk Management Directorate
verification check Database Verification Tool
www.oig.dhs.gov OIG-17-110
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Background
Flooding has been, and continues to be, a serious risk in the United States. To
reduce this risk, Congress established the National Flood Insurance Program
(NFIP) with the passage of the National Flood Insurance Act of 1968. Although
originally intended to be funded with policyholder premiums, NFIP, in part due
to natural disasters in 2005 and 2012, has proven to be actuarially unsound.
For example, as of March 2016, the Federal Emergency Management Agency
(FEMA) owed the U.S. Treasury $23 billion, up from $20 billion in November
2012, to pay flood claims.
FEMA administers NFIP through the Federal Insurance and Mitigation
Administration. NFIP’s three-fold mission is to –
x make federally backed flood insurance available to home and business
owners and renters;
x minimize the economic impact of flood events through floodplain
management, which incorporates mitigation efforts and community-
adopted floodplain ordinances; and
x identify and map community areas subject to flooding.
Flood hazard identification and mapping is an integral part of NFIP as it creates
the foundation for floodplain management, flood insurance, and mitigation.A
Flood Insurance Rate Map (FIRM or flood map) includes statistical information
such as data for river flow, storm tides, hydrologic and hydraulic analyses, and
rainfall and topographic surveys.
Flood maps provide risk information and enable communities to make
informed decisions, e.g., to adopt and enforce minimum floodplain
management regulations that reduce the loss of life and property.
Flood studies are conducted to assess the following conditions:
x riverine flooding of rivers, streams, or other waterways;
x flooding of lakes and ponds;
x coastal flooding caused by hurricanes or severe storms; and
x shallow flooding, ponding, and sheet flow.
FEMA manages its mapping needs through the Coordinated Needs
Management Strategy Database (Needs Database), a resource that includes
processes and data for tracking flood hazard studies. FEMA uses the Needs
Database assessment process to report the percentage of updated and valid
flood maps. FEMA expresses this metric as the New, Valid, or Updated
Engineering (NVUE) percent attained.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
The NVUE percent attained is a ratio of all NVUE study miles divided by the
total miles in FEMA’s mapped inventory. NVUE metrics distinguish between
engineering studies that adequately identify the level of flood risk (known as
Valid) from those that are in need of restudy (known as Unverified). Changes in
topography, hydrology, and/or land development are evaluated as part of this
validation process. When a floodplain needs to be studied or is being studied, it
is labeled as Unverified in the Need Database. Unverified miles can only
become NVUE compliant through a new flood study.
According to the National Flood Insurance Reform Act of 1994, FEMA must
assess the need to revise and update all floodplain areas and flood risk zones
identified once during each 5-year period. Thus, valid miles will expire every
five years if not assessed. Failure to assess an NVUE compliant mile within the
5-year window will result in the mile being re-categorized as “Unknown” in the
Needs Database. Unknown miles have not been subjected to the validation
process to determine whether they reflect the current flood risk or are in need
of restudy.In 2009, FEMA set a goal to attain 80 percent NVUE by the end of
fiscal year 2014.
FEMA Headquarters and regions select flood mapping projects based on the
highest risk, need, and available funding. FEMA relies on mapping partners
such as production and technical services contractors, which are private
engineering firms, as well as state and local governments or regional agencies
participating in FEMA’s Cooperating Technical Partners program for riverine,
levee, and coastal flood studies.
FEMA uses the Mapping Information Platform (MIP) as the system of record to
manage the production of flood maps. MIP integrates program and project
management, data storage and retrieval, standardized quality control reviews,
and tracking of flood map production into one web-based application.
This review focuses on riverine flooding, which occurs in waterways subject to
overbank flooding, flash floods, and urban drainage system flooding.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Results of Audit
FEMA is unable to assess flood hazard miles to meet its program goal and is
not ensuring mapping partner quality reviews are completed in accordance
with applicable guidance. FEMA needs to improve its management and
oversight of flood mapping projects to achieve or reassess its program goals
and ensure the production of timely and accurate flood maps. Specifically,
FEMA –
x needs to improve its financial management of flood map projects to
achieve or to reassess its program goal of 80 percent NVUE program
miles;
x has not updated its
Risk Mapping, Assessment and Planning Program
(Risk MAP)
life cycle cost estimate (LCCE) to inform critical decision
making;
x lacks uniform, centralized policies and procedures for projects placed on
hold; and
x lacks oversight to ensure mapping partner quality reviews (QR) comply
with requirements set forth in FEMA’s quality review guidance.
Without accurate floodplain identification and mapping processes,
management, and oversight, FEMA cannot provide members of the public with
a reliable rendering of their true flood vulnerability or ensure that NFIP rates
reflect the real risk of flooding.
Management of Flood Mapping Projects Needs Improvement
FEMA is not meeting its program goal to ensure flood hazards are current with
NVUE miles. In 2009, FEMA set a performance goal to attain 80 percent NVUE
by the end of FY 2014. However, in February 2014, FEMA notified the
Department of its anticipated breach of that goal and set an approved revised
baseline of 64 percent NVUE. Despite adjusting its performance goal, FEMA
only attained 49 percent NVUE at the end of FY 2014 (see figure 1). As of
December 2016, FEMA’s NVUE was at 42 percent, meaning more than half of
the Needs Database inventory of miles either required a re-study or have not
yet been assessed through the validation process.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Figure 1: National NVUE Attained through FY17 Quarter 1
% NVUE
Attained
60.0%
40.0%
20.0%
0.0%
40.2%
41.8%
45.0%
45.7%
46.7%
48.0%
49.2%
49.3%
42.0%
40.9%
42.4% 42.4%
32.5%
Source: FEMA
This was caused in part because FEMA (1) does not have an appropriate
system for tracking obligations and expenditures for regions at the task order
level; (2) has not updated its Risk MAP life cycle cost estimate to inform critical
decision making; and (3) did not always effectively oversee the progress and
completion of flood map projects. FEMA needs to improve its management of
flood map projects to achieve or to reassess its 80 percent NVUE program miles
goal.
Financial Management Oversight to Achieve Program Goal
FEMA needs to improve its financial management of flood map projects to
achieve or to reassess its program goal of 80 percent NVUE. FEMA attributed
the reduction in NVUE compliance to a decrease in program funding. FEMA’s
funding for FYs 2010 to 2014 was expected to total $1.47 billion, but FEMA
received just $1.23 billion during this period. We identified $194 million
unexpended funds from FYs 2010 to 2014 that could have been used for
additional projects.
FEMA officials stated that they were unable to spend the $194 million due to
mapping projects lasting long periods or projects that were not closed.
Although we identified two regions with an in-house mechanism to track and
trace commitments, we were unable to reconcile these unexpended funds to
mapping studies because FEMA does not have a financial system that enables
them to track obligations and expenditures for regions at the task order level.
Tracking obligations and expenditures would enable FEMA to better manage its
resources and give them a means for monitoring and assessing the validity of
its program goal.
The Risk MAP Life Cycle Cost Estimate
FEMA has not updated its Risk MAP life cycle cost estimate (LCCE) to inform
critical decision making. FEMA created the original Risk MAP LCCE in 2010
and updated it in 2012 to project costs through 2014. Following NVUE
performance goal breach and the award of two major production and technical
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OFFICE OF INSPECTOR GENERAL
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service contracts in 2014, FEMA drafted an LCCE to estimate the total cost of
Risk MAP over the life of the program (FY2010 through FY2020). This
document was in draft form at the conclusion of our review. According to one
FEMA Program Specialist, the LCCE remains in draft because of their
impending new governance structure and uncertainty regarding future
congressional appropriations.
We believe that finalizing the Risk MAP LCCE would help FEMA estimate the
likely cost of flood hazard studies and contribute to establishing a baseline for
NVUE compliance over the next 5 years.
Projects Placed on Hold
FEMA did not always effectively oversee the progress and completion of flood
map projects. A FEMA region may place a flood map project on hold to
temporarily suspend its assessment of schedule and cost performance (earned
value calculation) when it cannot progress due to uncontrollable
circumstances. Schedule and cost performance is calculated by earned value at
the project level. Earned value calculations of time, budget, and performance
better enable FEMA to manage and assess the health of a flood map project.
FEMA may place a project on hold pending the receipt of data from an external
source or when progress cannot be made until critical information such as new
levee guidance has been received.
Although the intent of placing projects on hold is supposed to be temporary to
suspend earned value calculations, FEMA lacks centralized policies and
procedures for expediting removal of projects from on hold status. Specifically,
65 of the 88 projects we tested were on hold for more than a year. When flood
map projects are placed on hold for long periods, FEMA cannot provide
members of the public with a timely understanding of their true flood
vulnerability or ensure that NFIP rates reflect the real risk of flooding.
We identified 240 of 1,947 (12 percent) active flood map projects that were on
hold during of our review. We focused our review on 88 of the 240 on hold
projects that were riverine flood map projects. Of the 88 riverine projects
tested:
x 28 (or 32 percent) were on hold for an average of 2.9 years because they
were impacted by new levee accreditation guidance;
x 21 (or 24 percent) were on hold for an average of 2.6 years because their
period of performance for the mapping contract expired. These projects
could remain on hold indefinitely as FEMA may or may not fund to
continue the project in the subsequent years; and
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x
OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
13 (or 15 percent) were on hold for an average of 2.9 years because the
project was in the post or revised preliminary mapping process. When a
project needs significant modification, it may be necessary to issue a
revised set of preliminary maps. The revised preliminary process usually
requires a contract modification in order to change the project scope,
period of performance, and funding.
See figure 2 for the range of reasons FEMA placed 88 projects on hold.
Figure 2: Duration and Reason Risk MAP Projects Placed on Hold
for Regions Combined
Reason #
1 2 3 4
Levee Analysis and Mapping Procedures 28
Expired Period of Performance 21
Revised Preliminary Phase 11
Completed; Future Work Anticipated 9
Awaiting Completion of Countywide Project 3
No Additional Funding 3
Awaiting LiDAR Data 2
Post Preliminary Phase 2
Change Request 1
Other* 8
88
2.4
1.9
2.9
0.8
3.4
1.3
Duration in Years (Average)
2.9
2.6
2.8
1.1
Source: Office of Inspector General (OIG) analysis of FEMA data
*Other: Projects that have been combined with other flood mapping projects or are placeholders in the
MIP.
The Regional Project Management Lead or the Regional Project Manager is
responsible for tracking the status of projects and placing them on hold with
FEMA Headquarters approval. FEMA region officials reported that they would
like more input or guidance from Headquarters on how they should complete
or prioritize on hold projects. For example, while one FEMA region prioritizes
the funding of on hold projects during their annual planning phase, another
region pools projects regardless of their status. Also, while one FEMA region
plans and sets aside funding to cover expenses associated with community
appeals, another does not.
Because FEMA allows its 10 regions to independently manage and oversee
their flood mapping projects, at a minimum, FEMA should set a standard or
benchmark for the completion of on hold projects and improve communication
and coordination among Regional Project Managers to develop and share best
practices.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
FEMA Should Improve Its Oversight of Mapping Partner Quality
Reviews
FEMA lacks oversight to ensure that mapping partner QRs comply with
applicable guidance. Specifically, FEMA did not ensure that mapping partners
completed and uploaded required checklists and self-certifications into MIP.
FEMA also did not always verify that flood map project data passed all required
Database Verification Tool checks (verification check) prior to issuing a map or
ensure that documentation was kept on file to support bypassing failed
verification checks.
In 2013, FEMA revised its QR requirements that mapping partners must
comply with during the course of developing flood maps. FEMA’s guidance
requires that mapping partners use FEMA’s three mandatory standardized
checklists during the course of developing a flood map. These checklists
document whether project data complies with FEMA’s standards. Once the
mapping partner makes any necessary corrections and completes the checklist,
the mapping partner uploads them into MIP and self-certifies the flood map’s
compliance with FEMA’s standards.
Additionally, data used to develop a flood map must pass automated
verification checks in order for the project to advance to the next step in the
development of the flood map. Verification checks determine whether project
data used in developing a flood map complies with FEMA’s Flood Map
Database standards. Mapping partners upload data into MIP and use the
verification checks to test the quality of draft, preliminary, and final flood map
database submittals. If the MIP verification check fails, the data is returned to
the mapping partner for correction. In some instances, the mapping partner
can request a verification check bypass and explain the reason. All quality
compliance check issues noted during the QR process must be fully addressed,
documented, resolved, and included in MIP.
However, FEMA’s guidance does not assign responsibilities to FEMA personnel
to ensure that mapping partners –
x complete and upload the required checklists and self-certifications into
MIP;
x validate that flood map project data passes all verification check prior to
issuance of a flood map; and
x upload documentation of verification check bypasses in the MIP.
FEMA regions reported a general lack of understanding as to who should
oversee QRs performed by mapping partners. According to one FEMA Program
Specialist, FEMA has not provided any training to Regional Program Managers
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Department of Homeland Security
regarding the QR process. Additionally, this specialist was unaware of any
FEMA region that confirms the uploading of required checklists into MIP. We
held discussions with five Regional Program Managers and they offered the
following feedback about oversight uncertainty. Different managers indicated
that they –
x did not know who was responsible for overseeing the quality review
process;
x were not required to upload quality review checklists to the MIP prior to
2015;
x did not have access to all MIP files;
x believed the QR process was not mandatory;
x stated the regions and Headquarters shared responsibility for overseeing
QRs;
x did not always know whether mapping partners completed and uploaded
QR checklists to MIP (based on the manager’s tendency not to use MIP);
and
x did not know where QRs are housed in MIP.
During the course of our review, we also learned that a Regional Program
Manager may be responsible for up to 50 ongoing flood mapping projects in
addition to first responder duties for disaster-related events.
We judgmentally selected nine flood map projects completed between May 2014
and July 2016 to substantiate the lack of internal controls identified during the
course of our review. None of nine flood map projects selected for our review
complied with FEMA’s QR guidance. Specifically, all nine projects either did not
have FEMA’s mandatory checklists or the required self-certification uploaded in
MIP.
1
Eight of the nine projects had a failed verification check for a draft,
preliminary, final, or test after final flood map submittal. The results of our
analysis follow.
Quality Review Checks
FEMA is not supervising contractor performance to ensure that required QR
checklists and self-certifications are completed and uploaded into MIP. All nine
projects selected for our review either did not have FEMA’s mandatory QR
checklists or the required self-certification uploaded in MIP. Specifically, 19 out
of 27 QR checklists (70 percent) and 8 out of 9 self-certifications (89 percent)
were not in MIP at the time of our review. See table 1 for the results of our
review by region.
1
We selected one project from each of FEMA’s 10 Regions except Region 8, where we could not
find any flood map projects completed during our test period.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Table 1: Total Number of Quality Review Checklists and Self -
Certifications Missing in the MIP by Region
Region Case #
Required Quality Review Checklists in MIP?
Self –
certifications
in MIP?
Quality
Review 3
Quality
Review 7
Quality
Review 8
1 11-01-0889S Yes Yes Yes No
2 13-02-0708S No No Yes No
3 10-03-0355S No No No No
4 09-04-8601S No No Yes No
5 11-05-1556S No No No No
6 10-06-1115S No No No No
7 11-07-2747S No No No No
9 11-09-0920S No No Yes No
10 10-10-0993S Yes No Yes Yes
Total
7 of 9 8 of 9 4 of 9
8 of 9
19 of 27
Source: OIG Analysis of MIP data
For QR checklists not included in MIP, we contacted FEMA to verify whether
mapping partners had in fact completed them. FEMA subsequently received
from mapping partners 9 of the 19 missing checklists and 3 of the 8 missing
self-certifications.
Database Verification Tool Checks
FEMA is not supervising contractor performance to ensure flood map project
data passed all required verification checks. Additionally, FEMA did not ensure
documentation was kept on file to support bypassing failed verification checks.
Eight of the nine projects selected for our review had a failed verification check
for either a draft, preliminary, final, or test after final flood map submittal.
Specifically, 14 of 27 (55 percent) required verification checks failed and were
bypassed, but there was no evidence of a bypass explanation in MIP. See table
2 for the results of our review by Region.
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Department of Homeland Security
Table 2: Number of Database Verification Tool Bypasses Not on MIP
Region Case #
Number of Database
Verification Tool Bypasses
Not on MIP
Type of Submittal
1 11-01-0889S 1 Final
2 13-02-0708S 1 Final*
3 10-03-0355S 2 Draft* and Preliminary*
4 09-04-8601S 2 Draft and Final
5 11-05-1556S 0
6 10-06-1115S 2 Draft and Preliminary
7 11-07-2747S 2 Draft and Preliminary
9 11-09-0920S 3 Draft, Preliminary, and Final
10 10-10-0993S 1 Final
Total 14
Source: OIG analysis of MIP data
*Provided by mapping partner
To determine whether mapping partners completed bypass explanations, we
contacted FEMA personnel who coordinated with mapping partners for bypass
documentation. Mapping partners could not provide documentation for 11 of
the 14 bypasses.
We also found four instances where a verification check failed but the project
advanced to the next phase without a bypass request and the map was issued.
A FEMA official was unable to explain the reason FEMA advanced three of the
four projects, and did not provide documentation to support map issuance.
Without adequate oversight to ensure that mapping partner QRs comply with
applicable guidance, FEMA cannot provide the public with a reliable rendering
of their true flood vulnerability or ensure that NFIP rates reflect the real risk of
flooding.
Conclusion
FEMA needs to improve its management and oversight of flood mapping
projects to achieve program goals and ensure the production of accurate and
timely flood maps. Flood hazard identification and mapping is an integral part
of NFIP. It creates the foundation for floodplain management, flood insurance,
and mitigation. Flood maps provide risk information and enable communities
to make informed decisions such as adopting and enforcing minimum
floodplain management regulations that reduce the loss of life and property.
FEMA lacks uniform, centralized policies and procedures for projects placed on
hold and is not adequately overseeing mapping partner quality reviews.
Without accurate floodplain identification and mapping processes,
management, and oversight, FEMA cannot provide members of the public with
a reliable rendering of their true flood vulnerability or ensure that NFIP rates
reflect the real risk of flooding.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Recommendations
We recommend that the Federal Insurance and Mitigation Administration, Risk
Management Deputy Assistant Administrator, Federal Emergency Management
Agency:
Recommendation 1: Implement a system of tracking regional cost allocations
for flood map projects including studies and other investments, as well as the
status of funds (expended and unexpended) and where they are in their
lifecycle.
Recommendation 2: Coordinate with the FEMA Chief Acquisition Executive
Office to finalize and approve the Risk MAP LCCE.
Recommendation 3: Develop an effective oversight strategy and
implementation plan including necessary policies and procedures to enable
mapping projects to move forward on a timely and consistent basis.
Recommendation 4: Revise policies and procedures to require Regional
Project Managers to –
x ensure QR checklists and self-certifications are completed and uploaded
into MIP;
x verify project data passes all Data Verification Tool checks prior to
issuance of a flood map; and
x ensure documentation of all Data Verification Tool bypasses is uploaded
in MIP.
FEMA Comments and OIG Analysis
FEMA concurs with all of the recommendations. In its comments, FEMA noted
that it has made significant progress developing and implementing several
flood-related policy and program changes since OIG began this audit. These
changes include: (1) development and finalization of a Risk Mapping
Assessment and Planning (Risk MAP) Program Lifecycle Cost Estimate (LCCE);
(2) development and implementation of the Risk Management Directorate
(RMD) Centric Budget Matrix Tool; and (3) updating the Risk MAP Quality
Assurance Management Plan.
We have included a copy of the management comments in their entirety in
appendix B. A summary of FEMA’s response and our analysis follows.
Response to Recommendation #1: Concur. FEMA’s RMD is developing
budget tracking procedures with action steps for regional program components
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and staff. These steps include: (1) aligning cost tracking to production
milestones, 2) working with regional staff to develop cost tracking guidance,
and 3) implementing a review of the cost tracking procedures as part of the
quarterly occurring joint performance reviews with the Regions to assess
operations during FY 2018. Estimated completion date (ECD): September 30,
2018.
OIG Analysis: FEMA’s corrective action is responsive to the recommendation.
The recommendation will remain open and resolved until FEMA provides
evidence to support that corrective actions are completed.
Response to Recommendation #2: Concur. FEMA’s RMD initiated an update
of the Risk MAP LCCE, led by the Risk MAP Program Manager, during the audit
period. The LCCE is now in final routing for approval by FEMA Office of the
Chief Financial Officer, Office of the Chief Information Officer, and the Chief
Acquisition Executive. ECD: October 31, 2017.
OIG Analysis: FEMA’s corrective action is responsive to the recommendation.
The recommendation will remain open and resolved until FEMA provides
evidence of the final approved version of the LCCE.
Response to Recommendation #3: Concur. FEMA is developing a strategy to
monitor the status of projects currently on hold. The strategy will include
quarterly joint performance review meetings that will introduce performance
metrics to ensure regions continue to maintain progress in moving projects
forward to completion. Monthly cost and schedule performance reports will be
reviewed during these meetings and corrective action will be provided as
needed. FEMA will also develop a national implementation plan to categorize all
on hold projects and will provide regions with guidance to move these projects
forward in a consistent manner. ECD: to be determined.
OIG Analysis: FEMA’s corrective action is responsive to the recommendation
but will remain open and unresolved pending receipt of ECD and evidence of its
strategy and implementation plan to ensure mapping projects currently placed
on hold move forward in a timely manner.
Response to Recommendation #4: Concur. FEMA‘s Quality Working Group
finalized the Quality Assurance Management Plan requiring regions verify their
project data passes all Data Verification Tool checks prior to issuance of a
flood map. FEMA also update the Mapping Information Platform system to
include quality review (QR) tasks and validation tasks. The QR task will be the
repository for the upload of the QR checklists, Production and Technical
Services self-certification documentation, and Data Verification Tool check
information, to include results and bypasses, should they exist. The validations
tasks will allow the Regions to validate that correct information is uploaded for
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the QR tasks and the project has met the quality requirements. A report of the
data validation tasks and documentation checks will be developed and
provided to all study managers on a quarterly basis to provide an additional
level of visibility on the process and data collection. ECD: to be determined.
OIG Analysis: FEMA’s corrective action is responsive to the recommendation
but will remain open and unresolved pending receipt of ECD and until we have
reviewed FEMA’s Quality Assurance Management Plan.
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Department of Homeland Security
Appendix A
Objective, Scope, and Methodology
The Department of Homeland Security (DHS) Office of Inspector General (OIG)
was established by the Homeland Security Act of 2002 (Public Law 107ï296) by
amendment to the Inspector General Act of 1978.
We conducted this audit to determine whether Federal Emergency Management
Agency’s (FEMA) Risk Mapping, Assessment and Planning Program (Risk MAP)
assessed and updated flood maps timely and accurately in accordance with
National Flood Insurance Program (NFIP) requirements. Specifically, we
reviewed whether FEMA is meeting its program goal to ensure that 80 percent
of flood hazard miles are current with New, Valid, or Updated Engineering
(NVUE); oversaw the progress and completion of riverine flood map projects
placed on hold; and ensured mapping partner quality reviews comply with
requirements set forth in FEMA’s quality review guidance.
To accomplish our objective, we obtained and reviewed pertinent Federal and
FEMA specific regulations, policies, procedures, and guidance relevant to flood
mapping. We interviewed FEMA officials and staff responsible for the
management and oversight of flood mapping projects.
To determine whether FEMA met its program goal of 80 percent NVUE miles,
we obtained FEMA’s report titled Overview of Risk MAP Coordination Needs
Management Strategy and NVUE Status issued to Congress on September 18,
2015. We compared the data in this report to reports from FEMA’s
Coordination Needs Management Strategy to verify accuracy. We obtained
additional fiscal year data from the Coordination Needs Management Strategy
system to present the current year NVUE attained percentage presented in
figure 2 of this report. For the purpose of this report we determined that the
data was sufficiently reliable.
To identify unexpended obligations, we obtained a listing of financial
transactions from FEMA’s Integrated Financial Management Information
System (IFMIS) for fiscal years 2009 through 2016. We subtracted the total
expenditures and adjustments from total obligations included in the listing of
IFMIS transactions. We were unable to test the data reliability of unexpended
funds because FEMA does not track obligations and expenditures at the task
order level for legacy contracts.
To assess the process of assuring the timely production of flood maps, we
identified the number of all active and on hold projects between April and
November 2016 (1,947 projects) from FEMA’s Mapping Information Platform
(MIP) and FEMA regions. We limited the scope of our review to riverine mapping
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projects that were categorized as “on-hold” in MIP as riverine projects are the
largest program cost within Risk MAP. In total we identified 240 “on-hold”
projects with expenditures totaling $41 million.
We developed and sent out a questionnaire to seven FEMA regions to
understand how each manages, tracks, and processes on-hold projects. Based
on responses received, we conducted interviews with seven regional officials
who manage flood map projects. We judgmentally selected these regions based
on criteria such as the number of on-hold projects at the time of our review
and type of responses given to our questionnaire to obtain a broad range of
view on how projects are managed.
To assess the reliability of the on-hold data, we compared the data generated
from MIP to each region’s responses and discussed the on-hold project data
with regional officials. We also “spot checked” for completeness and accuracy
by reviewing the information provided by the regions to MIP. We found
inconsistencies in some of the projects status during our interview with one
region and also found some data was missing because the case numbers were
not added to MIP. However, for the purpose of this report we determined that
the data was sufficiently reliable.
To determine whether quality reviews were conducted in accordance with
FEMA’s guidance, we verified whether (1) mandatory QR checklists and self-
certifications were completed and uploaded in MIP; (2) there was
documentation of a bypass request in MIP when project data failed a Data
Verification Tool check; and (3) projects passed all required Data Verification
Tool checks prior to FEMA issuing a flood map.
We judgmentally selected 9 of 1,894 coastal and riverine projects from FEMA’s
Risk MAP Progress website on July 7, 2016, that were prepared by production
and technical services mapping partners and completed between May 2014 and
July 2016. Production and technical services contractors and Cooperative
Technical Partners (CTP) completed a total of 1,894 projects. However, our
scope does not include projects completed by CTPs. The focus of our review
was on riverine flooding; however, we included one coastal project in our
sample as it was reviewed while developing our understanding of FEMA’s
quality review process during our survey phase
Ǥ We selected one project for
each of FEMA’s 10 regions except for Region 8, as we were unable to find in
that region a production and technical services project that was completed
during our test period. Additionally, we relied on the data provided in the
FEMA’s Risk MAP Progress website and did not conduct further reliability tests
of the information. We did not select more than nine projects because FEMA
personnel stated that they were not overseeing the quality review process
conducted by mapping partners.
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Department of Homeland Security
We conducted this performance audit between March and December 2016
pursuant to the Inspector General Act of 1978, as amended, and according to
generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based upon our
audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based upon our audit objectives.
The Office of Audits major contributors to this report are: Maureen Duddy,
Deputy Assistant Inspector General for Audits; Carolyn Hicks, Director; Paul
Exarchos, Audit Manager; Andrew Smith, Audit Manager; Jeff Mun, co-Auditor
in-charge; Roger Thoet, co-Auditor in-charge, Corneliu Buzesan, Program
Analyst; Steffanie Moore, Program Analyst; Aneet Marwaha, Program Analyst;
Ellen Gallagher, Communications Analyst; and Juan Santana, Independent
Referencer.
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Department of Homeland Security
Appendix C
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Policy
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Office of Management and Budget
Chief, Homeland Security Branch
DHS OIG Budget Examiner
Congress
Congressional Oversight and Appropriations Committees
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ADDITIONAL INFORMATION AND COPIES
To view this and any of our other reports, please visit our website at: www.oig.dhs.gov.
For further information or questions, please contact Office of Inspector General Public Affairs
at: DHS-OIG.OfficeP[email protected]. Follow us on Twitter at: @dhsoig.
OIG HOTLINE
To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click on the red
"Hotline" tab. If you cannot access our website, call our hotline at (800) 323-8603, fax our
hotline at (202) 254-4297, or write to us at:
Department of Homeland Security
Office of Inspector General, Mail Stop 0305
Attention: Hotline
245 Murray Drive, SW
Washington, DC 20528-0305
