Thread by @DavidBegnaud

NEWLY RELEASED: @FEMA mismanaged the distribution of commodities in response to Hurricanes Irma and Maria in Puerto Rico,” according to a report just released by the Inspector General. The findings are shocking. See thread below. oig.dhs.gov/sites/default/…

“FEMA lost visibility of about 38% of its commodity shipments to Puerto Rico, worth an estimated $257 million. Commodities successfully delivered to Puerto Rico took an average of 69 days to reach their final destinations.”

“Inadequate FEMA contractor oversight contributed to the lost visibility and delayed commodity shipments. FEMA did not use its Global Positioning System transponders to track commodity shipments, allowed the contractor to break inventory seals, &..”

‘...did not ensure documented proof of commodity deliveries. Given the lost visibility & delayed shipments, FEMA cannot ensure it provided commodities to Puerto Rico disaster survivors as needed to sustain life & alleviate suffering as part of its response and recovery mission.”

“In addition, FEMA’s mismanagement of transportation contracts included multiple contracting violations and policy contraventions. These violations occurred because of poor acquisition planning that did not address requirements for transoceanic shipments.”

The inspector general wrote: “While we understand FEMA’s priority on expediting commodity shipments to disaster survivors, it overrode the importance of following sound inventory management practices, significantly increasing the potential for fraud, waste, and abuse.”

“Contract costs grew without FEMA having proof that services were performed as required and ultimately led to contract overruns of about $179 million and at least $50 million in questioned costs.”

“...Specifically, it took FEMA an average of 13 days to ship the commodities from various contractor sites located within CONUS to Puerto Rico. Once on the island, commodities sat in FEMA’s custody at various locations on the island approximately 48 days...”

“... The final transfer of the commodities from FEMA’s custody to their end destinations took about 7.5 additional days.”

“... Water and food, two of the most important life-sustaining commodities, experienced average shipping delays of 71 and 59 days, respectively...”

“ Of the approximately 97 million liters of water FEMA shipped to Puerto Rico between September 2017 and April 2018, 36 million liters (approximately 37 percent) reached the RSAs or PODs for distribution.”

“...Likewise, during the same period, of the 53 million meals FEMA shipped to Puerto Rico, 24 million (approximately 45%) reached the RSAs or PODs for distribution. The remaining commodity shipments for both water and meals that arrived in the Commonwealth either remained in..”

“...FEMA’s custody, were in contractor facilities, or had unknown destinations...According to our survey results, it took FEMA an average of 10 days immediately after the hurricanes to deliver the first food and water to the disaster survivors.”

“Furthermore, only 27 percent (8 of 30) of the municipalities received sufficient amounts of water and only 20 percent (6 of 30) received sufficient amounts of food in the first commodity delivery.”

“Although commodity distribution improved over the first 2 months after Hurricane Maria, approximately 24 percent (6 of 25) of municipalities did not receive sufficient food and water to support their disaster survivors.”

“Furthermore, 40 percent (12 out of 30) of municipalities said they experienced significant problems with receiving expired food.”

“Moreover, the food that was delivered was nutritionally deficient. In an effort to quickly ship commodities to survivors, FEMA provided various food types such as meals ready-to-eat (MRE), snack boxes, and shelf-stable food that it deemed as meals.”

“However, these meals varied widely in food type, and some meal types contained questionable nutritional value. For example, FEMA sent “meal” boxes that included junk food such as Oreos, candy, cereal bars, and other similar items that lacked sufficient nutritional value.”

“FEMA sent these snack boxes because it was unable to order additional meals ready-to-eat due to the demand from concurrent disasters. Advance contract vendors were at capacity in providing nutritional meals following Hurricane Harvey and could not produce any more to support...”

“... the effort in Puerto Rico. As a result, Puerto Rico increased the number of snack boxes distributed per survivor to account for the nutritional deficiencies of the food items. Puerto Rico officials reported one meal for approximately every 12 snack boxes distributed to a...”

“... survivor. This created challenges for FEMA when it attempted to reconcile Puerto Rico’s meal distribution records with its LSCMS records as the meal figures did not match FEMA’s distribution figures...”

“... Approximately 4 months into the disaster response, FEMA & Puerto Rico came to an agreement on the meal conversion factors for reporting purposes, which significantly reduced the number of meals FEMA reported for certain meal types...”

“FEMA did not fully utilize its GPS technology to monitor commodity movements for over 75 percent of its shipments to Puerto Rico, and over 96 percent of its shipments within Puerto Rico...”

“... To illustrate, FEMA did not ensure GPS transponders worked properly or record GPS numbers in LSCMS. Additionally, FEMA had challenges using its GPS for commodity shipments to PR because the vertical stacking of containers on barges and at staging yards caused signal...”

“...loss that prohibited the transmission of geographic data. Given inadequate use of the GPS technology, FEMA had GPS data recorded for only 3.4% of the commodity shipments transported within PR. FEMA consequently had limited knowledge about the location of commodity shipments.”

Click to read the report oig.dhs.gov/sites/default/…

“FEMA Allowed the Contractor to Break Container Seals & Redistribute Commodities in Different Containers... due to inadequate FEMA oversight, Crowley Maritime Corporation (Crowley), FEMA’s transportation contractor, broke the FEMA inventory seals & repackaged commodities at a...”

“... second cross-docking location20 in Jacksonville, FL.... Disregarding the original packing slips and cargo manifests provided by FEMA, Crowley created generic cargo manifests labeled “relief supplies” that negatively impacted subsequent commodity shipment operations.”

“Cargo manifests are critical as they provide details such as descriptions of the goods and their respective quantities, and relevant consignor and consignee information. According to FEMA personnel, the accuracy of Crowley’s manifests was questionable.”

“Crowley did not know the contents of all containers shipped due to its generic cargo manifests. Consequently, our data analysis indicates about 1,000 containers may have never left the Jacksonville port.”

“FEMA personnel in Jacksonville indicated that over 1,500 containers that FEMA packed — most of them early in the disaster — may have never made it to Puerto Rico.”

“The contractor reported that it broke the seals to cross-dock and maximize shipping space to balance commercial and FEMA requirements. This contributed to delays in providing commodities to disaster survivors...”

“... For example, of the 7,942 commodity shipments sent from the CONUS to Puerto Rico, 41 percent took longer than 14 days to arrive on the island.”

“Not only did the practice of breaking seals to cross-dock delay shipments leaving CONUS, it also delayed shipments traveling within PR...data shows 538 shipments departed Crowley Bayamon Yard in PR...each of these shipments was subject to an additional delay of about 9 days.”

“The Puerto Rico government lacked a formal records management system to track commodities received from FEMA and distributed to the municipalities. Instead, Puerto Rico government personnel maintained manual records that were not filed in an organized manner in a designated...”

“... location where they could be easily retrieved. For example, we requested supporting documentation to verify commodity distribution numbers in the Puerto Rico government’s summary reports provided to FEMA...”

“... Puerto Rico government officials could not provide the supporting commodity distribution records because they were dispersed throughout various locations on the island, including a personal residence.”

“FEMA’s mismanagement of its transportation contracts with Crowley and Estes Express Lines (Estes) resulted in multiple violations of Federal regulations. Specifically, we noted the following:...”

“FEMA’s advanced transportation contracts did not include adequate transportation services necessary for disaster response;
FEMA awarded an unauthorized sole source contract with no reasonable price determination;
did not practice sound funds mgmt...”

“...& improperly validated & approved payment on contractor
invoices..Further, management’s priority on disaster response, which overrode adherence to sound business practices, contributed to the violations...”

“... As a result, FEMA allowed transportation contractors to exceed their contract ceilings by a combined $179 million. These actions also resulted in significant risk for fraud, waste, and abuse, including questioned costs of approximately $50 million.”

Here was the conclusion from the Inspector General: “FEMA faced tremendous challenges meeting mission requirements because of the catastrophic nature of Hurricane Maria and multiple, concurrent, nationwide disasters...”

Here was the conclusion from the Inspector General: “FEMA faced tremendous challenges meeting mission requirements because of the catastrophic nature of Hurricane Maria and multiple, concurrent, nationwide disasters...”

“... Although we understand FEMA’s priority on expediting commodity shipments to disaster survivors, the extent of the deviations from established operating procedures significantly increased the risk for fraud, waste, and abuse...”

“... Some flexibility and adaptation of normal processes is expected during disaster responses, but controls necessary to safeguard commodities cannot be altogether ignored...”

“..FEMA’s emphasis on delivering commodities to disaster survivors overrode the importance of following sound inventory mgmt practices. When combined with poor acquisition planning prior to the hurricanes, FEMAs mgmt of the commodity distribution process didn’t function properly”

The Inspector General made these recommendations: First, “ Develop a comprehensive strategy and implementation plans for improving asset tracking and in-transit visibility across all modes of transportation...”

“...These plans should also include specific goals & corrective actions to address the agency’s commodity distribution challenges in managing the end-to-end distribution process, ensure the accuracy of underlying data, strengthen & integrate distribution policies & governance...”

“Recommendation 2: Develop and improve management reporting & data gathering business processes to address the data reporting challenges, resulting in more accurate and near-real-time information that enables quality decision making in assessing disaster survivor support needs.”

“... Recommendation 3: Establish robust transportation, supply chain, and general logistics contingency contracts to provide more timely and effective delivery of disaster support.”

“Recommendation 4: Develop internal controls over contract administration from initiation to closeout. These controls should: 1) ensure all contract requirements are met in accordance with the Federal Acquisition Regulation & corresponding DHS & FEMA policies and procedures;...”

“Recommendation 4: Develop internal controls over contract administration from initiation to closeout. These controls should: 1) ensure all contract requirements are met in accordance with the Federal Acquisition Regulation & corresponding DHS & FEMA policies and procedures;...”

“... 2) ensure training needs are met by procurement personnel and appropriate approvals are obtained prior to the award or modification of contracts;...”

“...and 3) ensure contract oversight officials adequately review invoices, including verifying costs, to the extent possible, based on source documentation to ensure billed costs are supported and allowed.”

“... Recommendation 5: Investigate FEMA’s transportation contracts in response to the Puerto Rico disaster for potential Anti-Deficiency Act violations and appropriately report the results of the review.”

The IG went on to write: “Although FEMA concurred with four of the five recommendations, it disagreed with our conclusions concerning commodity distribution. According to FEMA, its reconciliation resulted in accounting for all but 19 of 9,775 containers shipped to Puerto Rico...”

“... It took FEMA several months to locate these containers throughout the island, and it acknowledged some were empty or were filled with different products than expected. Finding lost containers does not mean FEMA found the commodities in the containers...”

“... The amount of commodities that FEMA lost because of its mismanagement of the distribution process is undeterminable.”

“We consider recommendations 1 through 4 resolved and open. Recommendation 5 is resolved and closed. A copy of FEMA’s response in its entirety is included in Appendix B. FEMA also provided technical comments and suggested revisions to our report in a separate document...”

“... We reviewed the technical comments and made changes to the report where appropriate. A summary of FEMA’s response and our analysis follows.”

“FEMA’s Comments to Recommendation 1: Concur. FEMA’s strategy in response to this recommendation is to address the multi-modal components of asset tracking along with in-transit visibility of FEMA’s systems, processes, training, and personnel...”

“... FEMA has...deployed the Transportation Procurement module & is implementing other LSCMS system improvements, publishing guidance like: Transportation Management Guide, & procuring solar satellite transponders to replace legacy transponders. Estimated Completion Date: 7/30/21

“OIG Analysis of FEMA’s Comments: FEMA’s corrective actions are responsive to the recommendation. However, the recommendation will remain open and resolved until we receive and evaluate a comprehensive supply chain strategy and corresponding initiatives, in conjunction...”

“... with implementation plans that include estimated completion dates, for all critical aspects of supply chain management and distribution. At a minimum, the strategy and implementation plans should address the use of technology for evaluating supply and demand and tracking...”

“... visibility; communication, collaboration, and accountability with third-party vendors; contracting; key performance metrics for timeliness and delivery based on severity of a disaster; and risk factors impacting the distribution process.”

“FEMA’s Comments to Recommendation 2: Concur. FEMA’s efforts to address this recommendation consist of planning, upgrading, and implementing aspects of information technology and data analysis...”

“... FEMA has undertaken LSCMS improvements and data collection tasks such as expanded Business Intelligence data models to improve ad-hoc, operational, and management reporting; moved LSCMS to the Cloud resulting in improvements to system agility;...”

“... and developed a multi-layered disaster logistics reporting and data gathering business tool. Estimated Completion Date: December 31, 2020”

“OIG Analysis of FEMA’s Comments: FEMA’s corrective actions are responsive to the recommendation. The recommendation will remain open and resolved until we have reviewed and analyzed documentation supporting actions taken to improve management reporting and data gathering.”

“FEMA’s Comments to Recommendation 3: Concur. FEMA Logistics has improved its logistics capabilities for response operations, including updates and expansions to high-priority, national-level commodity contracts...”

“... Improvements include replacement of a previous inter-island contract with a contract that has all-inclusive transportation and shipping services from a CONUS point of origin to Puerto Rico and the U.S. Virgin Islands...”

“... FEMA also awarded a National Cross Dock and Incident Support Base contract to aid in the movement control and management of disaster response resources.”

“also plans to award a multi-year contract vehicle to vendors, replacing a previous version, while also developing robust OCONUS transportation contracts for Hawaii, the Commonwealth of Northern Mariana Islands, & Alaska to provide transportation services for the movement of...”

“... resources during a disaster response. Estimated Completion Date: August 31, 2021”

“... OIG Analysis of FEMA’s Comments: FEMA’s corrective actions are responsive to the recommendation. The recommendation will remain open and resolved until we have reviewed contract documentation supporting these actions.”

“FEMA’s Comments to Recommendation 4: Non-Concur. FEMA’s Office of the Chief Procurement Officer has processes and procedures in place for internal controls addressing contract administration from initiation to closeout...”

“... FEMA contracting personnel receive updated policy guidance through the issuance of standard operating procedures and acquisition alerts throughout the fiscal year.”

“... FEMA OCPO continues to refine the internal control processes on an ongoing basis. Among other policies, FEMA issued the “Disaster Contracting Desk Guide,” which covers the entire disaster procurement process from submittal of a requisition through contract closeout...”

“... FEMA also created a draft FEMA Acquisition Manual that establishes the FEMA component-wide acquisition procedures that supplement the FAR and other requirements or policies.”

“OIG Analysis of FEMA Comments: Although FEMA did not concur with the recommendation, the agency’s actions to continuously refine internal control processes are responsive to this recommendation...”

“... The recommendation will remain open & resolved until we have received & reviewed the policies & procedures outlined in the response.”

“FEMA’s Comments to Recommendation 5: Concur. FEMA investigated the possibility of an Anti-Deficiency Act violation while assessing the unauthorized commitment in October 2018. During that assessment, FEMA OCPO analyzed the contract action and used cost and price analysts...”

“... to demonstrate fair and reasonable pricing. FEMA determined there was no violation as there was money in the Disaster Relief Fund account at the time of the procurement. These conclusions are supported in the ratification letter,...”

“... which was approved by the Office of General Counsel and the Head of the Contracting Activity. OIG Analysis of FEMA Comments: FEMA’s corrective actions are responsive to this recommendation, and we have reviewed the signed ratification letter along with documentation...”

“... supporting the cost assessment. The recommendation is considered resolved and closed.”

The Inspector General writes: “We conducted a survey of the 78 municipalities of Puerto Rico to assess and incorporate their perspectives into our analysis of the overall commodity distribution mission. The emailed survey consisted of 45 questions;...”

“... each question was designed and tested to ensure that responses could be used to further inform our analysis of this mission.”

“Lack of Coordination and Pre-positioned Commodities Hampered Initial Distribution Operations
Survey responses indicated that, in spite of widespread participation in various disaster response exercises and the existence of municipality-level commodities distribution plans,...”

“... the responding municipalities were generally not adequately prepared to conduct the commodities distribution operation in the days immediately following Hurricanes Irma and Maria. The most relevant issues addressed in the survey occurred in the areas of planning and...”

“... coordination and commodity pre-positioning. The state-level planning document, “Plan de Distribucion de Suministros” (Emergency Commodities Distribution Plan), is a flawed, yet comprehensive, document that outlines roles, responsibilities, and expectations for...”

“...municipalities & other key stakeholders positioned throughout the distribution process. We found that 27% of responding municipalities claim to have had no familiarity with this document; only 23% of responding municipalities participated in the creation of this ... plan”

“In addition to the comprehensive plan just mentioned, most municipalities received additional guidance from state and Federal entities on their commodities distribution process. We determined that 73 percent of responding municipalities received such guidance; however,...”

“... 20% of responding municipalities neither received this guidance nor had familiarity with the Commodities Distribution Plan. This lack of coordinated guidance contributed to lapses in plan performance, further compounding the additional responsibilities that would,...”

“... at least partially, fall on FEMA.”
An additional component of preparedness cited in the survey is the pre- positioning, or pre-distribution, of commodities in advance of the Hurricanes of 2017. Current plans do not call for any commodities to be distributed to...”

“...municipalities in advance of an incident. In accordance with these plans, 90% of respondents reported they did not receive any commodities in preparation for Hurricane Maria. This result, while not surprising, further substantiates a lack of pre-positioned items on PR.”

“On average, municipalities received their first deliveries of food and water about 10 days after Hurricane Maria. The first deliveries of blue tarps, generators, and fuel were received after 22, 31, and 27 days, respectively...”

“... However, only 27% of responding municipalities received enough water in that first shipment while only 20 percent received enough food.”

“Over time the distribution process would become more effective at meeting the commodities needs of municipalities. Within the first week, less than 30 percent of responding municipalities stated they had received enough food to sustain survivors;...”

“... that proportion nearly doubled by the end of week two, and reached its peak of 76 percent within 4 weeks. The progress in distribution of tarps, generators, & fuel lagged behind — the 50 percent threshold was exceeded for tarps & fuel beyond 30 days, while the proportion...”

“... of responding municipalities that received enough generators never exceeded 33%. Specifically, the commodities distribution effort became markedly more responsive to municipality requests over time...”

“... Within the first 2 weeks, half of the responding municipalities reported they waited, on average, more than 3 days for requested commodities to be provided; 38 percent experienced average wait times of more than 7 days...”

“... However, in weeks three and four, more than 81 percent of municipalities stated that requested commodities were provided within 3 days; more than 40 percent received them within 24 hours. Responsiveness improved even further after the first month of operations...”

“... Figures 8, 9, & 10 illustrate the increasing responsiveness to commodities requests from municipalities over time. Within the first 2 weeks, half of the responding municipalities experienced wait times of longer than 3 days; that proportion shrank to 19 percent after week 2.

“Despite the marked increase in the amount of commodities received over time, municipalities faced issues with the commodities received. To illustrate, 27 percent of responding municipalities stated that they had “significant problems” with the packaging of water...”

“More concerning is the proportion of responding municipalities that had significant problems with food; the combination of expired or damaged meals, meals with damaged packaging, or other issues were a “significant problem” for a majority of municipalities...”

“... Only 40 percent of responding municipalities reported no “significant problems” with meals. Figure 11 shows an example of damaged meal packaging.”

“Even with the aforementioned issues pertaining to the quality of commodities received, the overall satisfaction of municipalities regarding the response increased dramatically over time...”

“...7% of responding municipalities stated Federal efforts were effective in meeting the needs of the municipality with the first 2 days following Hurricane Maria. This proportion increased to 81 after 2 weeks; 89% indicated Federal efforts were effective in meeting their needs.”

Read the report oig.dhs.gov/sites/default/…

My reflection: FEMA is not designed to be 911. They aid local govts, & they failed in many way. They had to assume near total responsibility for the response b/c of the devastation, & a lack of preparation that led to a collapse of the central govt which failed its people.