Weaknesses Exist in FEMA’s Oversight of Data Quality, but Corrected FEMA Data Showed Fluctuations in Appeal Inventory and Delays in Processing

Our review of FEMA data that track first- and second-level appeals  showed weaknesses in the agency’s data quality practices that affect  program oversight. FEMA Regional Offices Do Not Track Appeals Information Consistently or Update First- Level Appeal Information Regularly

Our review of first-level appeals data showed that, between January 2014  and July 2017, regional offices did not consistently report first-level  appeal information for a number of the key data fields in the PAAB first- level appeal tracking spreadsheet. Further, as shown in figure 6, only a small percentage of decided first-and  second-level appeals (9 and 11 percent, respectively) were processed  within the 90-day statutory time frame. FEMA also took steps to increase its staffing levels. However, FEMA has not developed a workforce staffing plan to identify  hiring, training, and retention needs of appeals staff across PAAB and the  regional offices. In the absence of a workforce  plan for the PA appeals staff, FEMA will likely continue to experience  workforce challenges including vacancies in key appeals analyst  positions, appeals staff turnover, training delays, and understaffing due to  disaster deployment. These challenges will likely continue to contribute to  delays in FEMA’s processing and issuing first- and second-level PA  appeals decisions. FEMA Established Goals and Measures to Assess Second- Level Appeal Processing, but Did Not Do So for First- Level Appeals

FEMA officials have acknowledged the importance of establishing goals  and measures to assess the performance of the PA appeals program. According to  FEMA officials, while the Recovery Directorate established goals and  measures for second-level appeals, it is not responsible for developing  goals and measures to assess performance within the regional offices. Without consistent performance measures across FEMA  regional offices to help assess progress and identify deficiencies in  appeals processing, DHS and its subcomponent agencies like FEMA may  have difficulty providing accurate reporting on the effectiveness of current  efforts to process first-level appeals and on the factors that contribute to  ongoing appeal processing delays. Conclusions

Although FEMA has made efforts to improve its management of the PA  appeals process, these efforts have been hampered by a number of  issues including weaknesses in FEMA’s appeals tracking data and its  ability to ensure the quality of this data. As a result, these weaknesses will persist. FEMA also faces a variety of workforce challenges that have contributed  to appeals processing delays. In its comments, DHS  concurred with our recommendations and described actions planned to  address them. The objectives of this review were to determine: (1) the extent to  which FEMA ensures quality in its data on appeals and what FEMA data  show about its appeals inventory and timeliness for appeals decisions; (2)  what steps FEMA has taken to improve its management of the appeals  process and what challenges, if any, remain; and (3) the extent to which  FEMA has developed goals and measures to assess the appeal  program’s performance. Developed by PAAB and provided to FEMA management on a  quarterly basis, these reports included aggregate information on PA  appeals inventory, such as the number of first- and second-level pending  appeals, the number of appeals processed within statutory timeframes,  the number of pending appeals that are beyond the statutory timeframe,  and common appeal issues based on keywords entered by analysts  responsible for processing appeals. For all three objectives, we reviewed relevant legislation and FEMA  standard operating procedures that govern both FEMA headquarters and  regional offices. We also interviewed officials in PAAB and FEMA’s  Recovery Directorate.
Why GAO Did This Study

In both 2016 and 2017, 15 separate U.S. disasters resulted in losses exceeding $1 billion each. FEMA provides PA grants to state and local governments to help communities recover from such disasters. If applicants disagree with FEMA's decision on their PA grant application, they have two chances to appeal: a first-level appeal to be decided by the relevant FEMA regional office and, if denied, a second-level appeal to be decided within FEMA's Recovery Directorate. Each is subject to a 90-day statutory processing timeframe.
GAO was asked to review FEMA's appeals process. This report examines: (1) the extent to which FEMA ensures the quality of its appeals data and what these data show about PA appeals inventory and timeliness; (2) what steps FEMA has taken to improve its management of the appeals process and what challenges, if any, remain; and (3) the extent to which FEMA developed goals and measures to assess program performance. GAO analyzed FEMA policies, procedures, and data on appeals and interviewed officials from headquarters and from regional offices with the highest number of pending appeals. GAO also spoke to state officials from the two states within each of the three regions with the highest number of pending appeals.

What GAO Found

Weaknesses in the quality of Federal Emergency Management Agency's (FEMA) Public Assistance (PA) appeals data limit its ability to oversee the appeals process. For example, FEMA's data are inaccurate and incomplete because regional offices do not consistently track first-level appeals and FEMA does not have processes to ensure data quality. When GAO discussed these weaknesses with FEMA officials, they acknowledged them and provided GAO with corrected data for January 2014 through July 2017. GAO's analyses of the corrected data show fluctuations in the appeal inventory from year to year depending on the number of disasters declared and delays in processing. For example, as shown in the figure, only 9 percent of first-level and 11 percent of second-level appeals were processed within the 90-day statutory timeframe.
FEMA has taken steps to improve its management of the appeals process—including issues that GAO and the Department of Homeland Security's Office of Inspector General identified in 2008 and 2011. For example, FEMA increased its appeal staffing levels and developed standard operating procedures. Despite these efforts, FEMA continued to face a number of workforce challenges that contributed to processing delays, such as staff vacancies, staff turnover, and delays in training. FEMA has not developed a workforce staffing plan to identify hiring, training, and retention needs across its headquarters and regional offices, though FEMA officials acknowledge the potential benefits of having such a plan and stated that they are focused on filling vacancies. In the absence of a workforce plan, FEMA will continue to experience workforce challenges that could further contribute to delays in processing appeals.
FEMA has not established goals and measures for assessing first-level appeals processing performance, but has done so for second-level appeals. FEMA views establishing these first-level goals and measures as the responsibility of its regional offices. Without goals and measures, FEMA is limited in its ability to assess the efficiency and effectiveness of its overall appeals process and identify and address weaknesses that may lead to delays in making appeal decisions.

What GAO Recommends

GAO is making four recommendations, including that FEMA implement a consistent approach for tracking appeals and ensuring data quality, develop a workforce plan, and develop measurable goals for processing first-level appeals. FEMA concurred with all four recommendations.