Background On September 6, 2017, the eye of Hurricane Irma traveled about 50 nautical miles to the north of the northern shore of Puerto Rico as a category 5 hurricane. Less than two weeks later, Hurricane Maria made landfall as a category 4 hurricane on the main island of Puerto Rico on the morning of September 20, 2017 with wind speeds up to 155 miles per hour. The center of the hurricane moved through southeastern Puerto Rico to the northwest part of the island, as shown in figure 1 below. In response to the request of the Governor of Puerto Rico, the President declared a major disaster the day after each hurricane impacted Puerto Rico. Major disaster declarations can trigger a variety of federal response and recovery programs for government and nongovernmental entities, households, and individuals, including assistance through the Public Assistance program. Under the National Response Framework, DHS is the federal department with primary responsibility for coordinating disaster response, and within DHS, FEMA has lead responsibility. The Administrator of FEMA serves as the principal adviser to the President and the Secretary of Homeland Security regarding emergency management. FEMA’s Public Assistance Program FEMA’s Public Assistance program provides funding to state, territorial, local, and tribal governments to assist them in responding to and recovering from major disasters or emergencies. As shown in figure 2, Public Assistance program funds are categorized broadly as either “emergency work” or “permanent work.” Within those two broad categories are separate sub-categories. In addition to the emergency work and permanent work categories, FEMA’s Public Assistance program includes category Z, which represents indirect costs, administrative expenses, and other expenses a recipient or subrecipient incurs in administering and managing projects. Puerto Rico’s agencies, such as the Department of Housing; public corporations, such the Puerto Rico Electric Power Authority and the Puerto Rico Aqueduct and Sewer Authority; and Puerto Rico’s 78 municipalities are eligible to apply for the Public Assistance program. FEMA’s Public Assistance program also provides funding for cost- effective hazard mitigation measures to reduce or eliminate the long-term risk to people and property from future natural and man-made disasters and their effects. Specifically, FEMA provides funding for hazard mitigation measures in conjunction with the repair of disaster-damaged facilities to enhance their resilience during future disasters. For example, a community that had a fire station damaged by a disaster could use Public Assistance funding to repair the facility and incorporate additional measures such as installing hurricane shutters over the windows to mitigate the potential for future damage. In Puerto Rico, the Public Assistance program is administered through a partnership between FEMA and the recipient (Puerto Rico), which provides funding to eligible subrecipients (local or territory-level entities). Under the standard Public Assistance program process, once the President has declared a disaster, Public Assistance staff work with the recipient or subrecipients to help them document damages, identify eligible costs and work, and prepare requests for Public Assistance grant funds by developing project proposals. Officials then review and obtain approval of projects prior to FEMA obligating funds to reimburse recipients or subrecipients for eligible work. The Use of Alternative Procedures for Public Assistance Projects in Puerto Rico The Sandy Recovery Improvement Act of 2013 authorized the use of alternative procedures in administering the Public Assistance program, thereby providing new flexibilities to FEMA, states, territories, and local governments for debris removal, infrastructure repair, and rebuilding projects using funds from this program. The stated goals of the alternative procedures are to reduce the costs to the federal government, increase flexibility in the administration of the Public Assistance program, expedite the provision of assistance under the program, and provide financial incentives for recipients of the program for the timely and cost- effective completion of projects. Unlike the standard Public Assistance program where FEMA will fund the actual cost of a project, the Public Assistance alternative procedures allow awards for permanent work projects to be made on the basis of fixed cost estimates to provide financial incentives for the timely and cost- effective completion of work. Under these procedures, if the actual cost of the project exceeds the fixed cost estimate agreed upon by FEMA and the recipient, the recipient or subrecipient is responsible for the additional costs. However, if the actual cost of completing eligible work for a project is below the estimate, the recipient or subrecipient may use the remaining funds for other eligible purposes, such as for additional cost-effective hazard mitigation measures to increase the resiliency of public infrastructure. These funds may also be used for activities that improve the recipient’s or subrecipient’s future Public Assistance operations or planning. Although FEMA had approved alternative procedure grants in 30 states as of April, 2018, in these cases, alternative procedures were used on a project-by-project basis. Puerto Rico’s recovery from the 2017 hurricanes is the first recovery to use alternative procedures for all large permanent work projects. On October 30, 2017, Puerto Rico requested to use the alternative procedures process for all large-project funding for Public Assistance permanent work, categories C through G. According to FEMA guidance, as part of the alternative procedures process in Puerto Rico, FEMA and Puerto Rico must agree on a group of personnel with cost estimation expertise who will serve as part of a center of excellence. This center of excellence will assist FEMA and Puerto Rico in developing cost estimating methodologies to be used for determining fixed cost estimates for Public Assistance permanent work projects. FEMA officials stated that they are in the process of conducting inspections for Public Assistance projects for permanent work and, as of August 2018, had a total list of 10,000 site inspections to complete. FEMA officials stated that October 2019 is their target date for completing all alternative procedures fixed cost estimates for Public Assistance permanent work. However, pursuant to 428 guidance published in April 2018, this time frame may be adjusted on a project-by-project basis, based on extenuating circumstances. Puerto Rico’s Central Recovery Office Oversees Federal Recovery Spending Amendment 5 to the President’s disaster declaration imposed a number of grant conditions, including that Puerto Rico establish an oversight authority supported by third-party experts. This authority is to act as the grant recipient for all Public Assistance and hazard mitigation funding to ensure sound project management and enhanced, centralized oversight over FEMA grant distributions. In October 2017, the Governor of Puerto Rico established COR3, a Puerto Rico government office, to plan, guide, and oversee recovery efforts, including administering and overseeing the Public Assistance program. According to FEMA and COR3 officials, COR3 will fulfill the oversight requirements outlined in Amendment 5. According to COR 3 officials, COR3 was also established to ensure coordination with FEMA. The Executive Director of COR3 will act as the Governor’s Authorized Representative, which is the designated individual responsible for administering federal disaster assistance programs on behalf of Puerto Rico. Among other things, COR3 will: Identify, procure, and administer all federal, territorial, and private resources available to Puerto Rico related to recovery; Provide oversight of subrecipients using risk-based monitoring; and Provide technical assistance and advise Puerto Rico’s governmental agencies and municipalities regarding any matter related to recovery. According to COR3 officials, they will also implement internal controls, policies, and procedures to appropriately manage recovery funds. COR3 has also launched an online transparency portal intended to provide a breakdown of FEMA Public Assistance and other federal funding made available for disaster recovery in Puerto Rico. Bipartisan Budget Act of 2018 Requirements for Puerto Rico and Congressional Oversight of Recovery Efforts The Bipartisan Budget Act of 2018 (Bipartisan Budget Act) required that Puerto Rico submit an economic and disaster recovery plan to Congress by August 9, 2018, that defines the priorities, goals, and expected outcomes of Puerto Rico’s recovery related to a number of sectors, including, among other things, infrastructure, housing, electric power systems and grid restoration. The Bipartisan Budget Act also directs the Governor of Puerto Rico to develop the disaster recovery plan in coordination with FEMA, with support and contributions from other federal agencies having designated responsibilities in the National Disaster Recovery Framework. As of June 2015, Puerto Rico had roughly $66.9 billion in outstanding debt. According to the recovery plan, economic contraction in the years prior to the hurricanes contributed to a severe fiscal crisis and Puerto Rico’s credit rating dropped below investment grade in early 2014, followed by a series of defaults on debt payments. In response to Puerto Rico’s financial crisis, Congress passed and the President signed the Puerto Rico Oversight, Management, and Economic Stability Act in June 2016, which established the FOMB with broad budgetary and financial control over Puerto Rico. The Bipartisan Budget Act also permits the FOMB to review any federal funds over $10 million that are designated for Puerto Rico’s response to or recovery from Hurricanes Irma or Maria. FEMA Obligated Almost $4 Billion in Public Assistance Funding, and Puerto Rico and FEMA Have Taken Actions to Provide Oversight of Federal Recovery Funds FEMA obligated nearly $4 billion in Public Assistance funds for Puerto Rico’s emergency work projects, as well as the repair and restoration of its public infrastructure, among other things. In order to provide financial oversight of these funds, Puerto Rico is developing an internal controls plan as well as management policies and procedures that will, in part, help provide financial monitoring. In the interim, FEMA has instituted a manual reimbursement process to mitigate risk and ensure fiscal accountability. FEMA Obligated Almost $4 Billion, and Puerto Rico Expended Almost $1.7 Billion in Public Assistance Funding as of September 2018 As shown in figure 3, FEMA has obligated $3.63 billion (93 percent) for emergency work (categories A and B), and $151 million (4 percent) for permanent work (categories C through G) in Puerto Rico as of September 30, 2018. An additional $136 million (3 percent) was obligated for management and administrative costs. As of the end of fiscal year 2018, Puerto Rico expended about $1.7 billion (about 43 percent) of the almost $4 billion Public Assistance funds obligated by FEMA. Ninety-eight percent of this amount went toward emergency work projects in categories A and B. For example, the Puerto Rico Aqueduct and Sewer Authority expended almost $91 million to cover the costs of generator usage. Aside from generators, one category B project by the Puerto Rico Emergency Management Agency repaired the emergency warning system for about $9.4 million. A third project put a temporary roof on a Puerto Rico Institute of Culture facility in Vieques for $4,000. As shown in table 1, the majority of FEMA’s obligations in Puerto Rico as of September 30, 2018, have been for emergency work categories because these projects began soon after the disasters struck and focused on removing debris and providing assistance to address immediate threats to life and property. In contrast, permanent work projects take time to identify, develop, and ultimately complete as they represent the longer-term repair and restoration of public infrastructure. Funds expended by Puerto Rico for permanent work have been mostly limited to roads and bridges (category C) because impassable roads like the one shown in figure 4 below impede the provision of critical services to citizens. They can also get in the way of other disaster recovery efforts. Expenditures for roads and bridges (category C) amount to approximately $32 million, while expenditures for other permanent work categories (D- G) total approximately $1 million. According to FEMA officials, Public Assistance projects in categories D-G are still pending prioritization and formulation. For example, figure 5 below shows a recreational public space along the edge of a river in Maricao. The dashed line indicates where the iron railing and concrete paving used to continue, overlooking the river, before Hurricane Maria. As of September 2018, the municipality was awaiting FEMA assistance to begin restoration FEMA categorizes Puerto Rico’s subrecipients as commonwealth public corporations, commonwealth agencies, municipalities, and all other entities. As shown in table 2 below, 89 percent of obligations, as of the end of September 2018, for Puerto Rico were awarded to commonwealth public corporations and commonwealth agencies, with 47 percent awarded to the Puerto Rico Electric Power Authority. Overall, about 43 percent of obligated funds have been expended. Puerto Rico is Developing an Internal Controls Plan and Recovery Management Policies and Procedures to Provide Oversight of Federal Recovery Funds As previously discussed, Puerto Rico designated COR3 to administer and manage the Public Assistance program in coordination with FEMA. As part of COR3’s recovery oversight role, COR3 officials stated that they are developing an internal controls plan and recovery management policies and procedures with FEMA. According to COR3, these oversight documents will provide detailed guidance on grant application, procurement, payment and cash management, and financial monitoring and reporting, among other things. According to COR3 officials, they have held numerous meetings to coordinate with FEMA and have submitted drafts of the internal controls plan as well as management policies and procedures for FEMA’s consideration. In addition, according to COR3 officials, COR3 plans to provide direct technical assistance related to federal grants management to Puerto Rico’s cabinet-level agencies, public corporations, municipalities and other eligible subrecipients. As part of COR3’s advisory role, COR3 is expected to help Puerto Rico’s agencies, public corporations, municipalities, and some nonprofit entities formulate projects, draft cost estimates, and make funding requests, among other things. FEMA Has Instituted an Interim Manual Reimbursement Process to Mitigate Risk Federal grant award regulations allow FEMA to impose additional specific grant award conditions in specific circumstances, such as to mitigate risk and ensure fiscal accountability of the recipient or subrecipient. According to FEMA, once FEMA obligates funds, the recipient is able to expend funds as necessary. However, in November 2017, according to FEMA officials, the agency instituted a manual reimbursement process for subrecipients in Puerto Rico for federal funds, including Public Assistance funds, to mitigate fiduciary risk and decrease the risk of misuse of funds. Specifically, FEMA officials stated that they decided to institute this process because the government of Puerto Rico had expended funds prior to submitting complete documentation of work performed. According to FEMA officials, they also decided to institute the manual reimbursement process due to Puerto Rico’s financial situation, weaknesses in internal controls, and the large amount of recovery funds, among other things. This manual reimbursement process requires that COR3 fill out the Office of Management and Budget’s Standard Form 270 and submit supporting documentation before obligated funds can be withdrawn by Puerto Rico through COR3 and reimbursed to subrecipients. Subsequently, FEMA must review the submitted Standard Form 270 and all project documentation for completeness, compliance, and accuracy before disbursing funds to the recipient. In cases where FEMA requires additional documentation to process a Standard Form 270 request, FEMA will submit requests for information asking COR3 to supply the information needed for FEMA to complete the review. FEMA officials said that they aim to complete the entire process described above within ten calendar days, or 15-20 calendar days if FEMA needs to request additional information from COR3. Additionally, FEMA officials stated that the manual reimbursement process is intended as a temporary measure. They will cease the process once FEMA has reviewed the operational effectiveness of COR3’s internal controls and approved the final internal controls plan, which are under review. FEMA, COR3, and Subrecipients Report Initial Challenges with the Recovery Process FEMA, COR3, and Puerto Rico municipal government officials from ten municipalities we interviewed reported initial challenges with the recovery process, including with Public Assistance alternative procedures. These concerns included (1) workforce capacity constraints, (2) a need for additional guidance, (3) delays related to choosing cost estimators, and (4) reimbursement for emergency work. Workforce capacity constraints. FEMA and municipality officials cited concerns about FEMA staff turnover and lack of knowledge about how the Public Assistance alternative procedures are to be applied in Puerto Rico. While several municipal officials we spoke to remarked positively on consistent communication with FEMA officials, municipal officials in six municipalities we visited cited high levels of turnover among FEMA staff as a challenge. For example, officials in three municipalities said that discontinuity in FEMA personnel has caused them to have duplicative conversations with FEMA. An official from one municipality described the disruption that had been caused by repeated changes in FEMA personnel, especially when their point of contact at FEMA changed at least six times since the hurricanes. FEMA officials acknowledged that more personnel with expertise in the alternative procedures process are needed to administer the Public Assistance program and assist subrecipients. According to FEMA officials, FEMA has leveraged existing expertise from personnel in the Federal Coordinating Officer Advisory Group to train new employees to increase workforce capacity. FEMA personnel from this group are rotating experts assigned to recovery issues to increase institutional understanding of alternative procedures and train local hires. According to FEMA officials, these local hires can serve as FEMA staff for up to one year before they become reservists. In addition, FEMA officials stated that they have identified contractors with previous experience regarding alternative procedures to provide additional assistance to subrecipients. Need for additional guidance. Municipal officials cited concerns about a lack of comprehensive guidance for the alternative procedures process. Specifically, officials in eight municipalities we interviewed cited problems with missing, incomplete, or conflicting guidance from FEMA. In addition, officials in four municipalities stated that they are waiting on additional written instructions to establish more clear and consistent guidance. Officials from one municipality told us that the lack of written guidance has meant that the municipality has had to re-submit documents to FEMA multiple times to respond to changing guidance that they have received verbally. Additionally, four municipalities cited missing, incomplete, or conflicting guidance from COR3 as a challenge. However, one municipality noted that the quality of communication with COR3 has improved over time as COR3 has become more established. According to FEMA officials, they are drafting supplemental guidance for the alternative procedures process with the goal of incorporating lessons learned from prior iterations of the alternative procedures. Similarly, according to COR3 officials, COR3 is currently developing additional guidance and standard operating procedures to help subrecipients, including municipalities and Puerto Rico government agencies, better understand FEMA Public Assistance grant requirements. Delays related to choosing cost estimators for Puerto Rico. As mentioned previously, FEMA’s guidance for alternative procedures requires that FEMA and Puerto Rico, through COR3, choose personnel with expertise in cost estimation to serve as a center of excellence, which will develop a cost estimating methodology. FEMA has chosen personnel to staff the center of excellence. However, in August 2018, FEMA officials told us that COR3 had not yet finalized their choice of personnel, which had delayed the cost estimation process. Subsequently, COR3 officials told us that personnel have been identified to serve on the center of excellence and the final contracting process for these personnel is now in progress. Reimbursement for emergency work. Officials in nine municipalities we spoke to said that they had not been fully reimbursed for emergency work they completed. Further, officials in five municipalities we interviewed stated that the lack of full reimbursement has caused financial hardships. For example, officials in three municipalities said that the lack of full reimbursement has meant that the municipalities have had to pause or delay recovery work due to lack of financial resources. A mayor in one municipality stated that they have scaled back some essential services, such as the frequency of garbage pick-up, while waiting for full reimbursement. According to FEMA officials, delays in providing reimbursement were due to several factors including a loss in FEMA personnel to process reimbursement requests and a significant increase in the volume of reimbursement requests submitted by COR3 to FEMA. FEMA officials also stated an increasing need to make requests for information to COR3 due to a lack of documentation submitted at the time of the reimbursement request. In response to these factors, FEMA officials told us that they have undertaken new procedures with COR3. For example, according to FEMA officials, COR3 adopted procedures to review the completeness of documentation prior to submitting a reimbursement request to FEMA. FEMA officials stated that the agency is also holding weekly meetings with COR3 to increase coordination, and that FEMA increased the number of personnel devoted to reimbursement reviews. According to officials from FEMA and COR3, these steps have contributed to reduced delays. Puerto Rico Developed an Economic and Disaster Recovery Plan in Response to the Bipartisan Budget Act of 2018 That Addresses Long- and Short-Term Needs In response to the Bipartisan Budget Act, Puerto Rico submitted an economic and disaster recovery plan (recovery plan) to Congress on August 8, 2018. The recovery plan defines the priorities, goals, and expected outcomes of Puerto Rico’s recovery related to building government capacity for the recovery and strengthening of Puerto Rico’s infrastructure, among other things. The recovery plan estimates infrastructure repair and recovery costs of $132 billion and total recovery costs of $139 billion for a time period starting in 2018 and ending in 2028. According to the recovery plan, COR3 will guide recovery investment and policy in the months and years ahead and is intended to serve as a focal point for strategic thought and management of Puerto Rico’s recovery. The recovery plan is generally responsive to the directives outlined in the Bipartisan Budget Act. For example, Puerto Rico submitted the plan to Congress within 180 days of enactment of the Bipartisan Budget Act. The recovery plan defines priorities, goals, and expected outcomes for Puerto Rico’s recovery effort based on damage assessments conducted by sector. As mentioned earlier, Puerto Rico developed the recovery plan in coordination with FEMA and with support of the U.S. Department of Energy, the U.S. Department of Health and Human Services, and other federal agencies with responsibilities outlined in the National Disaster Recovery Framework. Additionally, the FOMB of Puerto Rico certified the recovery plan on August 28, 2018, as directed in the Bipartisan Budget Act, but provided two caveats to its certification. First, FOMB expressed concern that the recovery plan lacks sufficient detail of funding sources and estimates a much greater amount of federal funding than the certified fiscal plan for Puerto Rico projects. The recovery plan states that at the time of its release, Puerto Rico had not undergone eligibility reviews in various federal funding programs, and therefore the ability to identify accurate funding sources was limited. COR3 officials confirmed that full recovery funding needs will not be known until all damage assessments are complete, and they will continue to identify and leverage all funding resources as they are made available. Second, FOMB indicated that the recovery plan does not address oversight of federal funds and the recovery process. While the Bipartisan Budget Act does not require specific mechanisms for oversight of federal funding as part of the recovery plan, according to COR3 officials, they plan to implement internal controls, policies, and procedures to provide oversight. Puerto Rico’s recovery plan outlines 276 “courses of action” (actions)— defined by the plan as “a collection of potential activities, policies, and other actions that could contribute to recovery”—selected by Puerto Rico to align with its future recovery vision. As shown in table 3 below, the actions reflect Puerto Rico’s short-term and long-term recovery vision, organized into three areas. First, the recovery plan proposes “precursor” actions—those that serve as a foundation for all future actions—that will be prioritized for implementation. For example, the recovery plan includes actions to build capacity of municipalities to secure and manage recovery funds, and to improve the quality and volume of public data available to decision makers. Second, the recovery plan proposes a set of actions that aim to build the infrastructure and systems that support Puerto Rico’s economy, society, and disaster resiliency, such as addressing vulnerabilities in Puerto Rico’s electric grid. Finally, the recovery plan proposes a set of actions that address Puerto Rico’s long-term recovery goals, such as developing and enhancing Puerto Rico’s visitor economy. Most individual actions in the recovery plan include initial and recurring cost estimates for the time period from 2018 through 2028. The recovery plan describes all cost estimates as preliminary, and says that more specific cost estimates require completion of damage assessments and more details about the implementation of actions. To develop Puerto Rico’s disaster recovery plan, FEMA assisted COR3 in retaining the Homeland Security Operational Analysis Center (HSOAC), a federally-funded research and development center operated by the RAND Corporation under contract with DHS. According to FEMA officials, FEMA provided funding and technical assistance, through contractor support, for Puerto Rico to develop the recovery plan, but COR3 and Puerto Rico will be responsible for its implementation. These officials also stated that Puerto Rico received input and technical assistance from other federal departments, such as those in the Recovery Support Function Leadership Group led by FEMA. HSOAC developed the recovery plan in consultation with Puerto Rico by developing a preliminary sector-by-sector assessment of damages and needs caused by Hurricanes Irma and Maria across Puerto Rico. In conjunction with Puerto Rico’s stated vision for the recovery process, HSOAC’s damage assessment report provided the baseline needed to define, compare, and prioritize actions. HSOAC worked in teams of sector-specific experts to develop and refine the actions by reviewing reports, proposals, best practices, and other literature. For example, in June 2018, the U.S. Department of Energy released a report on energy resilience for Puerto Rico’s electric grid, containing recommendations for Puerto Rico to consider when developing the Recovery Plan. HSOAC sought feedback from various subject matter experts and stakeholders while developing the recovery plan. According to FEMA officials, FEMA’s joint recovery office delivered interim drafts of the recovery plan to federal agency partners and Puerto Rico for feedback. HSOAC also sought input from local-level stakeholders, including Puerto Rico’s municipal governments. For example, HSOAC commissioned a survey of officials from municipalities to gauge the challenges they faced in the aftermath of the 2017 hurricanes. According to FEMA and HSOAC officials, the survey, along with other input provided by mayors led to the development of actions focused on building the capacity of municipal governments to support recovery efforts. HSOAC officials noted that while the final recovery plan was submitted to Congress, they will continue to produce products that will assist Puerto Rico and their stakeholders in recovery implementation. HSOAC intends to release updated versions of the recovery plan, including updated damage and needs assessments. Other expected products include detailed descriptions and cost estimates for each action and a lessons learned report. The Bipartisan Budget Act also directs Puerto Rico to develop a public report on the progress made in achieving the recovery plan’s goals every 180 days after submission. FEMA officials explained that the recovery plan serves as a strategic, direction-setting plan for recovery, and does not provide step-by-step or site-by-site guidance on the recovery process. FEMA officials also acknowledged that there may be some overlap between some of the actions in the recovery plan and some of the permanent work funded through FEMA’s Public Assistance program, but that it is COR3’s responsibility to merge and coordinate such recovery efforts. Agency Comments and Our Evaluation We provided a draft of this report to DHS and the government of Puerto Rico for review and comment. In its comments, reproduced in appendix I, DHS summarized the amount of Public Assistance funding provided to Puerto Rico through fiscal year 2018. DHS also described FEMA’s temporary manual reimbursement process instituted to mitigate risk and ensure fiscal accountability of taxpayer dollars, and stated that FEMA is committed to supporting Puerto Rico as it finalizes internal controls, management policies and procedures to oversee disaster recovery funds. DHS also provided technical comments, which we incorporated as appropriate. The government of Puerto Rico provided comments that we reproduced in appendix II. In its comments, the government of Puerto Rico stated that in addition to what was discussed in this report, COR3 achieved progress and faced additional challenges. This report is a part of an ongoing review of disaster recovery efforts in Puerto Rico. The remainder of our ongoing work will continue to examine Puerto Rico’s recovery process, including implementation of the Public Assistance alternative procedures process and efforts by FEMA and Puerto Rico to oversee disaster recovery funds, including the manual reimbursement process. If you and your staff have any questions, please contact me at (404) 679- 1875 or curriec@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. GAO staff who made key contributions to this report are listed in appendix II. Appendix I: Comments from the Department of Homeland Security Appendix II: Comments from the Government of Puerto Rico Appendix III: GAO Contact and Staff Acknowledgments GAO Contact Chris Currie, (404) 679-1875 or CurrieC@gao.gov. Staff Acknowledgments In addition to the contact named above, Joel Aldape (Assistant Director), Pedro Almoguera, Aditi Archer, Michelle Bacon, Sylvia Bascope, Lilia Chaidez, Taylor Hadfield, Danielle Pakdaman, Lorraine Ettaro, Eric Hauswirth, Heidi Nielson, and Kevin Reeves made key contributions to this report.


Background On September 6, 2017, the eye of Hurricane Irma traveled about 50 nautical miles to the north of the northern shore of Puerto Rico as a category 5 hurricane. Less than two weeks later, Hurricane Maria made landfall as a category 4 hurricane on the main island of Puerto Rico on the morning of September 20, 2017, with wind speeds up to 155 miles per hour. The center of the hurricane moved through southeastern Puerto Rico to the northwest part of the island, as shown in figure 1 below. In response to the request of the governor of Puerto Rico, the president declared a major disaster the day after each hurricane impacted Puerto Rico. Major disaster declarations can trigger a variety of federal response and recovery programs, including assistance through FEMA’s Public Assistance program. Under the National Response Framework, DHS is the federal department with primary responsibility for coordinating disaster response, and within DHS, FEMA has lead responsibility. FEMA’s Public Assistance Program FEMA’s Public Assistance program provides grant funding to state, territorial, local, and tribal governments, as well as certain types of private nonprofit organizations, to assist them in responding to and recovering from major disasters or emergencies. As shown in figure 2, Public Assistance program funds are categorized broadly as either “emergency work” or “permanent work.” Within those two broad categories are separate sub-categories. In addition to the emergency work and permanent work categories, FEMA’s Public Assistance program includes Category Z, which represents any indirect costs, any direct administrative costs, and any other administrative expense associated with a specific project. Entities Involved in Puerto Rico’s Recovery Given the immense scale and scope of devastation, disaster recovery in Puerto Rico is a complex and dynamic process involving a large number of entities. As shown in figure 3, implementing the Public Assistance program involves recovery partners from the federal government; the Commonwealth of Puerto Rico; and Puerto Rico government agencies, public corporations, municipalities, and eligible nonprofits in Puerto Rico. These recovery partners play a role in implementing the Public Assistance program by developing projects and providing or receiving grants and sub-grants (subawards). FEMA. FEMA administers the Public Assistance program in partnership with Puerto Rico and makes Public Assistance grant funding available to Puerto Rico. Puerto Rico Central Office of Recovery, Reconstruction and Resilience. Puerto Rico was required, as a condition to receiving Public Assistance grant funding, to establish an oversight authority supported by third-party experts and provide centralized oversight over recovery funds. In October 2017, the governor of Puerto Rico established the Central Office of Recovery, Reconstruction, and Resilience (central recovery office) to be the recipient for all Public Assistance funding consistent with the conditions provided in Amendment 5 to the President’s disaster declaration. The central recovery office is a non-federal entity that provides a subaward to an applicant to carry out part of the federal program. As a recipient of federal funds, the central recovery office must oversee subrecipients to ensure that they are aware of and comply with federal regulations. According to central recovery office officials, the office was also established to ensure coordination with FEMA across the numerous partners in recovery. Commonwealth agencies, local entities, and private non-profits. Puerto Rico’s agencies, such as the Department of Housing, and public corporations, such as the Puerto Rico Electric Power Authority, act as subrecipients. Specifically, they work with FEMA and the central recovery office to identify, develop, and implement Public Assistance projects. Local entities, including Puerto Rico’s 78 municipalities and eligible private non-profits that provide critical services, are also subrecipients of FEMA Public Assistance funding. As subrecipients, these entities receive subawards from the central recovery office to carry out work under the Public Assistance program. Alternative Procedures for Public Assistance Funds According to a November 2017 amendment to Puerto Rico’s major disaster declaration, FEMA must obligate all large project funding for Public Assistance permanent work through alternative procedures due to the extraordinary level of infrastructure damage caused by Hurricane Maria, as well as Puerto Rico’s difficult financial position. To develop projects under the Public Assistance program, FEMA and Puerto Rico officials are to collaborate to identify and document the damage caused by a disaster to a particular facility. These officials are to then use the damage description to formulate the scope of work—or activities required to fix the identified damage—as well as the estimated cost of these activities. Under the standard Public Assistance program, FEMA will fund the actual cost of a large project, and will increase or reduce the amount of funding based on the cost of completed eligible work. In contrast, in Puerto Rico, the alternative procedures require that the central recovery office and subrecipients work collaboratively with FEMA to develop a fixed cost estimate. According to FEMA officials, once this fixed cost estimate is agreed to and obligated, subrecipients have flexibility within that fixed cost estimate to rebuild in the manner that they find most appropriate. Subrecipients could do the actual work used to develop the fixed cost estimate, or they could put funds towards another FEMA approved project. Unlike the standard Public Assistance program, the subrecipient is responsible for actual costs that exceed the fixed cost estimate. If actual costs are less than the fixed cost estimate, the subrecipient may use all or part of excess funds for other eligible purposes, such as for additional cost-effective hazard mitigation measures to increase the resiliency of public infrastructure, as detailed in figure 4 below. The Bipartisan Budget Act of 2018 Section 20601 of the Bipartisan Budget Act of 2018 authorized FEMA, when using the alternative procedures, to provide assistance to fund the replacement or restoration of disaster-damaged infrastructure that provides critical services—such as medical and educational facilities—to an industry standard without regard to pre-disaster condition. It also allows for restoration of components not damaged by the disaster when necessary to fully effectuate restoration of the disaster-damaged components to restore the function of the facility or system to industry standards. For example, through the Act, FEMA may fund the restoration of a disaster-damaged school building—which provides a critical service—to accepted industry standards applicable to the construction of education facilities. Therefore, according to FEMA policy, if the school building was not up to industry standards, or in poor condition prior to the 2017 hurricanes, the Act allows FEMA to fund the restoration of this building to a better condition than it was in prior to the storms. Further, the Additional Supplemental Appropriations for Disaster Relief Act of 2019 (Supplemental Relief Act), which was signed into law on June 6, 2019, provides additional direction to FEMA in the implementation of section 20601. Following the Supplemental Relief Act, FEMA issued additional guidance in September 2019 that includes information on eligibility and applicable industry standards. FEMA Obligated Nearly $6 Billion for Public Assistance in Puerto Rico as of September 2019, but FEMA and Puerto Rico Face Significant Challenges in Developing Projects Status of FEMA Public Assistance Funding in Puerto Rico Since the 2017 hurricanes, FEMA has obligated nearly $6 billion in Public Assistance program funding for 1,558 projects across Puerto Rico, according to our analysis of FEMA’s data as of September 30, 2019 (see fig. 5). Specifically, FEMA had obligated approximately $5.1 billion for emergency work projects (categories A and B), $487 million for permanent work projects (categories C through G), and $315 million for management costs (Category Z). Of the nearly $6 billion FEMA has obligated, Puerto Rico has expended approximately $3.9 billion as of September 30, 2019—about 65 percent of total Public Assistance program obligations to Puerto Rico—to reimburse subrecipients for completed work. As shown in table 1, Puerto Rico has expended about $3.7 billion for emergency work projects, $39 million for permanent work projects, and $104 million for management costs. The majority of FEMA’s obligations and the funding Puerto Rico expended as of September 30, 2019, are for emergency work because these projects began soon after the disasters struck and focused on debris removal and providing assistance to address immediate threats to life and property. In contrast, permanent work projects take time to identify, develop, and ultimately complete as they represent the longer- term repair and restoration of public infrastructure, such as a sports center in Caguas, Puerto Rico, as shown in figure 6 below. FEMA and Puerto Rico Face Significant Challenges in Developing Public Assistance Projects FEMA and Puerto Rico officials identified challenges in developing Public Assistance projects in Puerto Rico. Specifically, they cited: (1) delays in establishing a cost estimating guidance for projects in Puerto Rico, (2) the large number of damaged sites that require finalized fixed cost estimates, and (3) challenges with the implementation of the flexibilities authorized by section 20601 of the Bipartisan Budget Act. Delays in establishing cost estimating guidance. Given the importance of reaching mutual agreement on fixed cost estimates for alternative procedures projects, FEMA and Puerto Rico have taken a deliberative approach to establishing the data and procedures that will be used to develop these fixed cost estimates. This includes, among other things, adapting the way FEMA estimates costs to the specific post- disaster economic conditions in the territory, including developing exceptions to FEMA’s cost estimating guidance. According to FEMA, these exceptions were developed to account for risk, including higher anticipated costs due to increased demand for labor, equipment, and materials in Puerto Rico’s post-disaster economy. To develop these exceptions, FEMA and the central recovery office established a Center of Excellence staffed with mutually agreed upon representatives. FEMA used cost estimators from RAND Corporation (RAND) as their chosen representatives, while the central recovery office hired separate contractors as their representatives. According to FEMA officials, the Center of Excellence was established, among other things, to involve Puerto Rico in developing cost estimating guidance and to ensure that the exceptions made to FEMA’s Cost Estimating Format were agreeable to both parties. However, this approach has been beset by delays. For example, it took nearly one year for Puerto Rico to hire its chosen representatives to the Center of Excellence. According to FEMA, the central recovery office did not select members for the Center of Excellence until February 2019, which delayed progress on the development of finalized fixed cost estimates for permanent work. In July 2019, FEMA leadership signed an agreement establishing the exceptions to FEMA’s cost estimating guidance based on an assessment conducted by a panel of FEMA engineers. These exceptions are intended to address certain costs specific to post-disaster conditions in Puerto Rico, for example adjustments to account for increased labor and material costs. Large number of damaged sites requiring a fixed cost estimate. In addition, FEMA and Puerto Rico officials have cited the large number of sites requiring damage assessments, project development, and mutually agreed-upon fixed cost estimates as a challenge. As of September 30, 2019, FEMA identified a total of 9,344 damaged sites in various stages of development. According to FEMA, 6,304 sites (67.5 percent of total sites identified) have completed damage assessments; 3,021 sites (32.3 percent of total sites identified) are pending the completion of damage assessments to begin project development; and 19 projects (0.2 percent of total sites identified) have finalized fixed cost estimates. According to FEMA guidance, October 11, 2019, was the deadline for completing fixed cost estimates for Public Assistance alternative procedures projects. However, on October 8, 2019, officials from the central recovery office requested an extension to the deadline, which FEMA granted. FEMA officials acknowledged that significant work remains on the part of Puerto Rico, subrecipients, and FEMA towards developing fixed cost estimates for all Public Assistance alternative procedures projects in Puerto Rico. According to FEMA officials, as of October 2019, FEMA and Puerto Rico are working together to establish specific time frames for the completion of fixed cost estimates. Implementation challenges with Section 20601 of the Bipartisan Budget Act of 2018. Puerto Rican government and FEMA officials identified challenges with the implementation of the flexibilities authorized by section 20601 of the Bipartisan Budget Act. As previously discussed, this section of the Act allows for the provision of assistance under the Public Assistance alternative procedures to restore disaster-damaged facilities or systems that provide critical services—such as medical and educational facilities to an industry standard without regard to pre-disaster condition. Officials from Puerto Rico’s central government stated that they disagreed with FEMA’s interpretation of the types of damages covered by section 20601 of the Bipartisan Budget Act of 2018. In response, FEMA officials in Puerto Rico stated they held several briefings with Puerto Rico’s central recovery office to explain FEMA’s interpretation of the section, and released new guidance in September of 2019. It is too soon to assess the impact this guidance may have on current and future projects, but we will continue to examine this in future work. We will continue to monitor the status of FEMA’s cost estimating process, the development of the remaining fixed cost estimates for permanent work and the impact of FEMA’s new guidance on the implementation of section 20601 of the Bipartisan Budget Act. FEMA Has Adapted Cost Estimating Guidance to Specific Conditions in Puerto Rico, but Could Take Further Action to Fully Align the Guidance with Best Practices FEMA Has Adapted Its Guidance to Estimate Public Assistance Costs to Address Post-Disaster Conditions in Puerto Rico As Puerto Rico is responsible for any costs that exceed fixed cost estimates for large infrastructure projects under the alternative procedures, FEMA has adapted its guidance for estimating costs to ensure that these estimates accurately reflect the total costs of Public Assistance projects. As previously mentioned, FEMA and Puerto Rico established a Center of Excellence to develop proposed exceptions to adapt FEMA’s Cost Estimating Format—the agency’s standard guidance used for Public Assistance cost estimating nationwide—to more accurately estimate costs in Puerto Rico. After consideration of these proposals, FEMA approved two exceptions: (1) a cost factor to account for local labor, equipment, and material costs in Puerto Rico, and (2) a future price factor and price curve to account for anticipated rises in construction costs over time due to the massive influx of disaster recovery funds, coupled with limited material and labor resources in Puerto Rico. Cost Factor: According to FEMA officials, during the development of a cost factor by the Center of Excellence, FEMA learned that Gordian, a company that provides local cost indices called RSMeans which FEMA uses as part of their standard Cost Estimating Format, was developing four localized cost indices to apply to San Juan, urban areas, rural areas, and remote island (the islands of Vieques and Culebra) areas of Puerto Rico. FEMA officials told us that these cost indices compile location-specific construction costs for each of the four areas. In 2019, a panel of FEMA engineers assessed the methodologies proposed by RAND, the Center of Excellence, and the RSMeans localized indices for Puerto Rico. On July 12, 2019, in agreement with the panel’s assessment, FEMA decided to use RSMeans’s localized cost indices to act as the cost factor for fixed cost estimates in Puerto Rico beginning on September 27, 2019. For fixed cost estimates developed before this date, FEMA used a different cost index that RSMeans had previously developed for San Juan. According to FEMA, cost estimates signed before September 27, 2019 using RSMeans’s San Juan cost index as the cost factor are considered final. Future Price Factor and Curve: According to FEMA officials, FEMA began using a future price factor—an economic model based on expected construction conditions to estimate construction costs across ten years—in July 2019 to estimate costs in Puerto Rico. FEMA is using this future price factor along with the cost factor. FEMA has also asked RAND to develop a future price curve, an analysis that will adjust as time goes on to account for changing economic conditions, to eventually replace the future price factor. FEMA estimates that RAND will take until November 2019 to develop the future price curve, and that the future price factor is being used in the meantime. FEMA officials stated that cost estimates produced using the future price factor are considered final and will not be eligible for revisions in the future once FEMA implements the future price curve. According to FEMA officials, the use of the cost factor combined with the future price factor and curve are intended to adapt FEMA’s cost estimating guidance to the specific post-disaster economic conditions in Puerto Rico. FEMA Cost Estimating Guidance Met Most Cost Estimating Best Practices, but FEMA Could Take Further Action to Fully Align with Best Practices FEMA’s cost estimating guidance for Public Assistance fully or substantially met nine of the 12 steps from GAO’s Cost Estimating and Assessment Guide (GAO Cost Guide). However, the guidance partially met two and minimally met one of the remaining cost estimating steps, as shown in figure 7 below. The GAO Cost Guide outlines best practices for cost estimating and presents 12 steps that, when incorporated into an agency’s cost estimating guidance, should result in reliable and valid cost estimates that management can use to make informed decisions. A reliable cost estimate is critical to the success of any construction program. Such an estimate provides the basis for informed decision making, realistic budget formulation and program resourcing, and accountability for results. For example, FEMA, Puerto Rico and subrecipients rely on cost estimates to help ensure that funding is sufficient for the costs of the Public Assistance projects carried out under the fixed cost estimate. Accurate and reliable cost estimating is especially important in Puerto Rico where all large permanent Public Assistance projects are being developed under the alternative procedures, which require a fixed cost estimate that cannot be revised once the award is made. Given Puerto Rico’s financial situation, accurate cost estimates are necessary so that Puerto Rico has adequate funds to complete Public Assistance projects. For example, on the basis of our analysis, we determined that FEMA’s guidance fully met the step to “define the estimate’s purpose” because it describes the estimate’s purpose, level of detail required, and overall scope. In addition, the guidance provides a time frame for which the estimates must be developed and reach agreement. FEMA’s guidance substantially met another step, “identify the ground rules and assumptions”, because it provides measures to ensure assumptions are not arbitrary, are founded on expert judgments, and are documented. However, we rated this step as substantially met instead of fully met because FEMA’s guidance does not address all of GAO’s best practices for ground rules and assumptions. For example, it does not discuss the risk of an assumption being incorrect and the resultant effect on the cost estimate. Additionally, FEMA guidance substantially met the step to “document the estimate” because it contains, among other things, basic information about the project and the estimate; a description of the scope of work; the basis for the estimate; and supporting backup information. However, we assessed this step as substantially met instead of fully met because FEMA policy does not require documentation to include a discussion of high risk areas. Further, we found that FEMA’s guidance for cost estimating does not fully or substantially meet three steps: (1) conduct a sensitivity analysis; (2) obtain the data; and (3) conduct a risk and uncertainty analysis. Sensitivity analysis (Minimally met): We found that FEMA’s cost estimating guidance only minimally met the best practice regarding sensitivity analysis. A sensitivity analysis addresses some of the uncertainty in a cost estimate by testing assumptions and other factors that could change cost. By examining each assumption or factor independently, while holding all others constant, the cost estimator can evaluate the results to discover which assumptions or factors most influence the estimate. A sensitivity analysis also requires estimating the high and low uncertainty ranges for significant cost driver input factors. According to the GAO Cost Guide, when an agency does not identify the effect of uncertainties associated with different assumptions, this increases the chance that decisions will be made without a clear understanding of these impacts on costs. According to FEMA officials, FEMA’s cost estimating guidance accounts for construction, cost, and market risks over time which allows FEMA to plan and estimate costs for unknown or unforeseen circumstances such as cost escalation or overhead. In addition, FEMA officials stated that their use of RSMeans unit costs, a benchmark industry standard based on ongoing iterative analysis of construction costs nationwide, allows FEMA to account for fluctuations and uncertainties in the market. However, we rated this step as minimally met because FEMA guidance does not indicate that cost estimators are to conduct a sensitivity analysis as part of FEMA’s cost estimating process. Specifically, the guidance does not require that an estimator examine the effect of changing assumptions and the effect these changes could have on a cost estimate. Since the guidance does not direct estimators to conduct a sensitivity analysis, estimators may not fully understand which variable most affects the cost estimate and FEMA risks making decisions without a clear understanding of the impact of costs. Obtaining the data (Partially met): We found that FEMA’s cost estimating guidance only partially met the best practice for obtaining data—assembling information to serve as the foundation of a cost estimate. The quality of the data obtained affects a cost estimate’s overall credibility. Depending on the data quality, an estimate can range from a mere guess to a highly defensive cost position. We found that FEMA did not meet some of the best practices for obtaining data. Specifically, FEMA’s guidance did not outline procedures for making sure data was validated using historical data as a benchmark for reasonableness. In addition, FEMA’s guidance did not stipulate that data be normalized to remove the effects of inflation or analyzed with a scatter plot to determine trends and outliers. As mentioned previously, FEMA used a city cost index based on San Juan as an interim measure to estimate costs throughout Puerto Rico until September, 2019 when FEMA began using additional cost indices to target costs in particular regions of Puerto Rico. Similarly, FEMA has been using a static future price factor as an interim measure until a more dynamic and iterative future price curve is finalized. FEMA does not plan to adjust cost estimates developed using these interim measures. Without adjusting these costs when better data becomes available consistent with the obtaining the data step, FEMA risks creating estimates that may not be based on accurate data. According to FEMA, estimates are developed based on historical costs or nationally available industry standard data. In addition, FEMA officials stated that FEMA does not revisit cost estimates to reflect updated market conditions or newly available cost information because FEMA uses an industry standard cost database that is updated quarterly. FEMA officials stated that the interim measures used to estimate costs are intended to enable work to continue and cost estimates to be developed while the future cost curve is being developed. However, we rated the step relating to obtaining data as partially met because without finalizing the future cost curve, and updating estimates to reflect this information, estimates may not be based on accurate data. Additionally, while the use of industry standard cost estimating resources addresses some best practices for this step such as data normalization and data validation, industry data is only one of many sources referenced in FEMA’s guidance. For other data sources identified, FEMA guidance does not describe a process to analyze the data for cost drivers or to adequately document the data. Risk and uncertainty analysis (Partially met): We found that FEMA’s cost estimating guidance does not include best practices consistent with performing a statistical analysis of risk to determine a range of possible costs and the level of confidence in achieving the estimate. By conducting a risk and uncertainty analysis, a cost estimator can model the effect of schedules slipping and missions changing, allowing for a known range of potential costs. Having a range of costs around a point estimate is useful to decision makers because it conveys the level of confidence in achieving the most likely cost and informs estimators about potential risks. We found that FEMA’s cost estimating guidance does not require a statistical analysis of risks to be performed to determine a range of possible costs. While contingencies are accounted for within the guidance, they are not derived from a statistical analysis, nor do they reflect a level of confidence in the estimate. According to FEMA, risks associated with changing costs and conditions over the life of a Public Assistance alternative procedures construction project is not a risk that the federal government takes on. Rather, the risk is transferred to the recipient and subrecipients responsible for executing work using Public Assistance alternative procedures funding. In addition, FEMA officials told us that alternative procedures funding is not always used to restore facilities to pre-disaster condition, and therefore may not represent the final cost of work completed. In addition, the procedures are designed to incentivize subrecipients to manage grants and use excess funds for eligible work, as described earlier. However, GAO’s Cost Guide states that point estimates alone are insufficient for good decision- making. For management to make good decisions, the program estimate must reflect the degree of uncertainty, so that a level of confidence can be given about the estimate regardless of the entity holding the risk. In the case of alternative procedures projects in Puerto Rico, where actual costs that exceed the estimate are borne by the recipient or subrecipient, estimates that accurately reflect the degree of uncertainty are important in establishing a level of confidence about the estimate. While FEMA fully or substantially met nine of the 12 steps in the GAO Cost Guide, FEMA could improve its cost estimating guidance to ensure that all best practices in the 12 steps in the GAO Cost Guide are fully met. In doing so, FEMA could further enhance the reliability of its cost estimating guidance. FEMA Has Developed Public Assistance Program Policies and Guidance over Time for Puerto Rico, but Recovery Partners Reported Challenges FEMA Public Assistance Program Policies and Guidance for Puerto Rico In response to the complexity of the recovery, as well as the nature of change in a recovery environment, FEMA has developed and issued guidance that is specific to the implementation of the Public Assistance program in Puerto Rico. As previously discussed, disaster recovery in Puerto Rico is a complex and dynamic process that requires the coordination of many entities, including FEMA, the government of Puerto Rico, and numerous subrecipients. Recovery in Puerto Rico also involves the use of Public Assistance structures including alternative procedures and new flexibilities afforded to FEMA under the Bipartisan Budget Act of 2018. FEMA officials told us that many elements of the Public Assistance process in Puerto Rico are the same as in other declared disasters across the United States. Therefore, according to FEMA officials, the standard guidance for the Public Assistance program, Public Assistance Policy and Procedures Guide (Policies and Procedures Guide), generally applies in Puerto Rico. FEMA has also developed policies and guidance to address the specific recovery circumstances in Puerto Rico. For example, in April of 2018 and September of 2019, FEMA published the Public Assistance Alternative Procedures Guide for Permanent Work to clarify how FEMA would implement the program in Puerto Rico. This guidance describes the scope and limitations of the alternative procedures; highlights changes to aspects of the Public Assistance program to which these procedures apply; identifies responsibilities for certain activities; and documents timelines for key actions and decisions. FEMA also issued a policy on the agency’s implementation of section 20601 of the Bipartisan Budget Act as it applies in Puerto Rico in September of 2018, detailing the applicability of the section to specific critical services and outlining eligible industry standards for purposes of authorized projects, among other things. Following the Supplemental Relief Act, FEMA issued guidance in September 2019 that includes additional information on eligibility and applicable industry standards. According to FEMA officials, FEMA has also developed and implemented training specific to recovery in Puerto Rico. This training has included presentations to the central recovery office and subrecipients on the flexibilities of the Bipartisan Budget Act and alternative procedures, among other things. Recovery Partners in Puerto Rico Identified Challenges with the Accessibility of FEMA Public Assistance Policies and Guidance FEMA has iteratively developed, refined, and clarified Public Assistance guidance in Puerto Rico to respond and adapt to changing recovery conditions since the 2017 hurricanes. While iterative and responsive guidance is necessary in a complex and changing recovery, the pace of change necessitates that all involved recovery entities have real-time accessibility to current applicable FEMA guidance. Officials from the central recovery office and four Puerto Rico government agencies we spoke with stated that they did not consistently have the guidance they needed to implement the Public Assistance program. For example, an official from one Puerto Rico agency said that they delayed starting on any large Public Assistance projects through alternative procedures because they were waiting for FEMA to issue additional guidance. Similarly, we reported in March 2019 that four municipal officials stated that they were waiting on additional instruction from FEMA to establish more clear and consistent guidance to begin projects in Puerto Rico. According to FEMA officials, the agency works with Puerto Rico government officials and subrecipients to provide relevant guidance and technical assistance throughout the Public Assistance project development process. However, we found that pertinent guidance may not be shared with key recovery partners. For example, FEMA officials told us that the Standard Operating Procedure for Alternative Procedures (SOP) was available as of March 2019, but remains in draft form as of October 2019, pending finalized information about cost estimating procedures. This SOP provides instruction on specific procedures to implement the Public Assistance alternative procedures guide. In April 2019, FEMA officials described the SOP as a “living document”; they also stated that the draft SOP is in effect and has been sent to the central recovery office for further dissemination to subrecipients. While the SOP document is still in draft, according to FEMA officials, it is operative guidance that FEMA expects the central recovery office to disseminate to subrecipients. However, in June 2019, central recovery office personnel told us they did not view the SOP as being in effect as it was still in draft form. As such, central recovery office officials stated they had not distributed the SOP to subrecipients. FEMA officials stated that they rely on the central recovery office to disseminate at least some FEMA guidance and policy to subrecipients in Puerto Rico, including municipalities and government agencies. As the recipient for all Public Assistance funding in Puerto Rico, the central recovery office is responsible for monitoring and providing technical assistance to subrecipients to ensure that federal funding is used in accordance with federal statutes, regulations, and the requirements of the grant. FEMA officials also stated that subrecipients have an assigned FEMA point of contact to assist them through the project development process, including communicating policy information and updates. However, municipal and Puerto Rico agency officials we spoke to said that confusion persisted in part due to changing points of contact. FEMA’s reliance on the central recovery office or individual FEMA staff to deliver and distribute FEMA guidance poses a risk that the guidance is not made accessible to all partners involved in recovery, including subrecipients. While FEMA officials told us that FEMA assigns a point of contact to subrecipients to provide guidance and other necessary information throughout the project development process, Puerto Rico officials described a significant amount of “back and forth” with FEMA regarding requests for clarification, guidance, or instruction. FEMA officials acknowledge that FEMA has faced difficulties in disseminating information in Puerto Rico. According to FEMA officials, FEMA does not maintain a repository of Public Assistance policies and guidance available to all relevant recovery partners. The accessibility of FEMA guidance is especially important because FEMA releases iterative guidance to respond and adapt to changing recovery circumstances, such as updated legislation, among other things. Misunderstandings across recovery partners about guidance applicability raise concerns that subrecipients do not understand which guidance is currently in effect or how they should proceed in accordance with FEMA policy. Without real-time access to the totality of FEMA’s current applicable guidance, recovery partners risk using guidance that has been revised or replaced. According to FEMA’s National Disaster Recovery Framework, the federal government has the role of ensuring that information is distributed in an accessible manner such that all partners are informed of and aware of the recovery process. Developing a repository of current applicable policy and guidance and making it available to all relevant recovery partners in Puerto Rico, including subrecipients, would improve the accessibility of the information and provide greater assurance that recovery partners are aware of current applicable guidance. Puerto Rico and FEMA Have Structures in Place to Manage and Oversee Public Assistance Funding and FEMA Has Instituted Additional Controls to Mitigate Risk Puerto Rico Established an Office to Manage and Oversee Public Assistance Funding and Help Ensure Compliance with FEMA Policy Following the 2017 hurricanes, Puerto Rico took several steps to provide management and oversight of the Public Assistance program to ensure the program is implemented in compliance with applicable laws and regulations, as well as FEMA policies and guidance. Specifically, Puerto Rico (1) established a central recovery office to provide management and oversight of recovery funds; (2) developed an administrative plan, as required by FEMA policy; (3) developed an internal controls and recovery management plan; and (4) created a system to oversee and assess subrecipient risk. First, in accordance with Amendment 5 to the President’s disaster declaration, the central recovery office has been supported by third-party experts to help it establish its structure and carry out its management and oversight mission. Specifically, the central recovery office has hired contractors to help perform the following functions: Design a management guide and assess subrecipient risk. According to central recovery office officials, the office hired contractors to develop management protocols and guidance to ensure compliance with federal and state law, regulation, and guidance. The office also tasked these contractors with developing a system to oversee subrecipients using risk-based oversight. Provide technical assistance. Central recovery office officials also hired contractors to provide technical assistance and advise Puerto Rico’s government agencies and municipalities regarding recovery processes. This includes helping subrecipients define the scope of damages, and providing technical assistance to develop Public Assistance projects, among other things. The recovery office also tasked these contractors with overseeing grant accounting and reviewing reimbursement requests from subrecipients for eligible Public Assistance work performed. Develop data systems to track the central recovery office’s work. The central recovery office launched an online transparency portal, with the assistance of contractors, that is intended to provide a breakdown of FEMA Public Assistance and other federal funding made available for disaster recovery in Puerto Rico. According to central recovery office officials, in addition to the development of the online transparency portal, contractor personnel also developed systems to track internal recovery data. Second, to meet FEMA reporting requirements, the central recovery office developed an administrative plan—or FEMA State Agreement—in 2019 for the Public Assistance program following the 2017 hurricanes. This plan outlines the central recovery office’s management and oversight activities as well as the procedures that Puerto Rico must follow in implementing the programs. Puerto Rico is responsible, as required in the FEMA State Agreement, to ensure that subrecipients are in compliance with the conditions of the disaster grant award. For example, the plan emphasizes FEMA’s requirement that Puerto Rico submit quarterly progress and financial reports on the status of projects. Further, the plan describes Puerto Rico’s specific roles and responsibilities for managing and overseeing the program. For example, according to the Puerto Rico 2019 Public Assistance Administrative Plan, the central recovery office is responsible for, among other things, processing requests for time extensions to complete projects and conducting quarterly reviews, site inspections, and audits to ensure program compliance. Third, in addition to the administrative plan, in March 2019, the central recovery office released the Disaster Recovery Federal Funds Management Guide (management guide) that includes an internal controls plan and other policies and procedures for managing recovery funds. The management guide’s 14 chapters outline roles, responsibilities, policies and procedures on various recovery functions including procurement, payment and cash management, and subrecipient management and oversight, among other things. FEMA officials told us that they reviewed portions of the management guide, including sections on the central recovery office’s payment and cash management plan and subrecipient oversight. Further, FEMA worked with the central recovery office to make revisions to the plan, which included, adding clarifying information and correcting instances of duplication in the guidance, among other things. In addition, the central recovery office, with the help of contractors, is taking steps to assist subrecipients in meeting compliance requirements and supplementing their management capacity. FEMA and Puerto Rico government agency officials cited varying levels of capacity to manage federal grant funds, including Public Assistance funding. For example, agency officials at one government agency we spoke with stated that they were performing their own federal grants management and had prior experience managing large federal funds. Other Puerto Rico government officials we interviewed reported that central recovery office contractors have helped augment capacity to oversee federal funds. For example, officials from one subrecipient, a Puerto Rico public corporation, said that their agency did not have prior experience managing federal funds on such a large scale. The official told us that in order to bolster the capacity of the agency to oversee these grant funds, central recovery office contractors work closely with the agency to help them manage Public Assistance funding. Similarly, officials at one Puerto Rico government agency stated that the central recovery office offered help on uploading and validating grant data. Fourth, as detailed in its management guide, the central recovery office has also developed criteria to evaluate subrecipients’ risk of noncompliance with federal laws and regulations, as well as FEMA policy. According to the procedures outlined in the central recovery office’s management guide, each subrecipient is to be assessed annually to determine whether they are at a low, moderate, or high risk for noncompliance. The central recovery office is to place additional award conditions on subrecipients with risk factors identified through the risk assessment process. These may include additional oversight and more frequent on-site visits from the central recovery office. Additionally, central recovery office guidance states that corrective actions are to be taken in cases when deficiencies are found during audits. FEMA Has Instituted Additional Controls to Protect the Federal Investment in Puerto Rico’s Recovery In March 2019, we reported that FEMA instituted a manual reimbursement process in November 2017 for subrecipients in Puerto Rico for federal funds, including Public Assistance funds, to mitigate fiduciary risk and decrease the risk of misuse of funds. Specifically, FEMA officials stated that they decided to institute this process because the government of Puerto Rico had expended funds prior to submitting complete documentation of work performed. According to FEMA officials, they also decided to institute the manual reimbursement process due to Puerto Rico’s financial situation, weaknesses in internal controls, and the large amount of recovery funds, among other things. The manual reimbursement process required that FEMA review each reimbursement request before providing Public Assistance funds to mitigate risk and help ensure financial accountability. In Puerto Rico, the manual reimbursement process requires that the central recovery office fill out the Office of Management and Budget’s Standard Form 270 and submit supporting documentation to FEMA before obligated funds can be withdrawn by Puerto Rico through the central recovery office and reimbursed to subrecipients. Subsequently, FEMA must review the submitted Standard Form 270 and all project documentation for completeness, compliance, and accuracy before disbursing funds to the recipient. In cases where FEMA requires additional documentation to process a Standard Form 270 request, FEMA will submit requests for information asking the central recovery office to supply the information needed for FEMA to complete the review. On March 25, 2019, FEMA and the government of Puerto Rico, through the central recovery office, signed an agreement allowing the central recovery office to directly access federal grant funds and reimburse subrecipients for Public Assistance work they perform. During FEMA’s review of the central recovery office’s management guide, FEMA asked for revisions to sections, including chapters related to payment and cash management and subrecipient management and monitoring. According to the March 2019 agreement, these policies and procedures were developed in collaboration with FEMA, and comments and concerns provided by FEMA were addressed. FEMA officials also told us that they sampled Public Assistance grant documentation for completeness to ensure that the reimbursement requested was eligible for payment. According to FEMA officials, FEMA communicated minor discrepancies with the central recovery office for resolution, but said that they did not find any significant discrepancies during their completeness review. On April 1, 2019, FEMA removed the manual reimbursement process and began a transition to allow the central recovery office to make direct payments to subrecipients. In July 2019, FEMA announced that it would reinstate the manual reimbursement process due to, “ongoing leadership changes within the Puerto Rican government, combined with continued concern over Puerto Rico’s history of fiscal irregularities and mismanagement.” FEMA said that these additional steps are being taken in order to protect the federal investment in Puerto Rico’s recovery. We previously reported that FEMA and central recovery office officials told us that the manual reimbursement process caused delays in reimbursements, but once FEMA increased the number of personnel devoted to reimbursement reviews, delays decreased. In September 2019, FEMA once again lifted the manual reimbursement process following a meeting between FEMA and Governor Vásquez’s senior leadership. According to FEMA, the agreement to remove the manual reimbursement process is contingent on Puerto Rico’s continued ability to implement the mutually-acceptable internal controls plan. FEMA officials also stated that they are selecting samples from fiscal year 2019 to test Puerto Rico’s internal controls, and plan to move to a quarterly testing routine after testing for fiscal year 2019 is complete. As part of our ongoing review, we will continue to monitor the central recovery office’s management and oversight of Public Assistance funding, as well as of FEMA’s oversight of the federal investment in Puerto Rico’s recovery. Conclusions After the devastation of the catastrophic 2017 hurricane season, FEMA and Puerto Rico face a recovery of enormous scope. Puerto Rico estimates that $132 billion in funding will be needed to repair and reconstruct the infrastructure damaged by the hurricanes through 2028, and FEMA has identified nearly ten thousand damaged sites in need of Public Assistance funding. FEMA has taken steps to adapt its guidance to estimate costs to post-disaster conditions in Puerto Rico, but strengthening its cost estimating guidance could help FEMA provide greater assurance that its cost estimating guidance for Public Assistance projects is reliable. In addition, given the large number of individuals and entities involved in Puerto Rico’s complex recovery, ensuring that all recovery partners have easy access to the most current applicable policy and guidance could help clarify which FEMA guidance and policies are in effect. Recommendations for Executive Action We are making the following two recommendations to FEMA: The FEMA administrator should revise FEMA’s cost-estimating guidance for Public Assistance projects to fully align with all 12 steps in the GAO Cost Estimating and Assessment Guide. (Recommendation 1) The FEMA administrator should develop a repository for all current applicable Public Assistance policies and guidance for Puerto Rico and make it available to all recovery partners, including subrecipients. (Recommendation 2) Agency Comments and Our Evaluation We provided a draft of this product to FEMA, DHS and Puerto Rico’s Central Office of Recovery, Reconstruction, and Resilience (central recovery office) for comment. In its comments, reproduced in appendix III, DHS concurred with our recommendations. FEMA also provided technical comments, which we incorporated as appropriate. DHS concurred with our first recommendation that FEMA revise its cost- estimating guidance for Public Assistance projects to fully align with all 12 steps in the GAO Cost Estimating and Assessment Guide. DHS stated that FEMA will create a quality assurance checklist as an addendum to FEMA’s Cost Estimating Format (CEF) to ensure that cost estimates reflect best practices from the GAO Cost Estimating and Assessment Guide. This action is a positive step to addressing our recommendation and we will monitor FEMA’s efforts to complete this work. In DHS’s concurrence to our second recommendation that FEMA develop a repository for all current applicable Public Assistance policies and guidance for Puerto Rico to be made available to all recovery partners, DHS requested that GAO consider this recommendation resolved and closed as implemented. DHS stated that FEMA maintains Public Assistance policy and guidance documents, including those specific to Puerto Rico, on the agency’s public web site, which FEMA stated it will continue to update. DHS also stated that FEMA maintains non-publicly available reference documents on the agency’s internal web site through the Grants Manager and Grants Portal systems. As we noted in our report, Puerto Rico’s recovery is a complex and dynamic process that requires the coordination of many recovery partners, including numerous municipalities and commonwealth agencies. For this reason, ensuring that information is distributed in an accessible manner would provide greater assurance that all recovery partners are aware of the most current and applicable Public Assistance policies and guidance. We will monitor FEMA’s public and internal web sites, including policy and guidance updates, to assess whether the actions outlined by FEMA meet the intent of our recommendation. COR3 also provided comments to our draft report, which we reproduced in appendix IV. In its comments, COR3 stated that it works with Public Assistance applicants to, among other things, provide technical assistance and training, and to monitor projects. COR3 also stated that it has established joint efforts with FEMA to improve COR3’s technical assistance, as well as compliance and monitoring efforts. We are sending copies of this report to the appropriate congressional committees, the Secretary of Homeland Security, the Administrator of FEMA, the Puerto Rico government, and other interested parties. In addition, the report is available at no charge on the GAO website at http://www.gao.gov. If you and your staff have any questions, please contact me at (404) 679- 1875 or curriec@gao.gov. GAO staff who made key contributions to this report are listed in appendix V. Appendix I: The Status of Public Assistance Program Funding in Puerto Rico Since September 2017, the Federal Emergency Management Agency (FEMA) obligated nearly $6 billion in Public Assistance grant funding for 1,558 projects across Puerto Rico as of September 30, 2019. Specifically, FEMA had obligated $5.13 billion for emergency work projects (categories A and B), about $487 million for permanent work projects (categories C through G), and $315 million for management costs, (category Z). As of that date, Puerto Rico expended nearly $3.9 billion—about 65 percent of total Public Assistance obligations to Puerto Rico—to reimburse subrecipients for completed work. Of this, Puerto Rico expended about $3.7 billion (96 percent of all expended funds) for emergency work projects, $38.6 million (1 percent) for permanent work projects, and $104 million (3 percent) for management costs. The majority of FEMA’s obligations and the funding Puerto Rico expended as of September 30, 2019 are for emergency work projects because these projects began soon after hurricanes Irma and Maria struck and focused on debris removal and providing assistance to address immediate threats to life and property. In contrast, permanent work projects take time to identify, develop, and ultimately complete as they represent the longer-term repair and restoration of public infrastructure. While the data in this appendix represent the status of Public Assistance funding as of September, 2019, the amount of grant funding FEMA obligates and Puerto Rico expends will likely increase over time as additional projects are finalized and approved. Emergency Work. As of September 30, 2019, FEMA obligated a total of $5.13 billion for approximately 1,200 emergency work projects across Puerto Rico. These projects focus on debris removal activities and providing assistance to address immediate threats to life and property. Category A: Debris Removal. FEMA obligated $637.0 million and Puerto Rico expended $427.1 million for 331 projects focused on debris removal activities in Puerto Rico under category A. Category B: Emergency Protective Measures. FEMA obligated nearly $4.5 billion for 871 projects under Category B. Of this, Puerto Rico has expended $3.29 billion. For example, FEMA has obligated more than $140 million to the Puerto Rico Aqueducts and Sewer Authority under category B to fund emergency protective measures, including using back-up generators to supply water to the island after Hurricane Maria, among other things. Permanent Work. As of September 30, 2019, FEMA has obligated about $487.3 million for 159 permanent work (Categories C through G) projects in Puerto Rico. These projects focus on the restoration of disaster- damaged infrastructure or systems. Category C: Roads and Bridges. FEMA obligated $140.5 million and Puerto Rico has expended $32.8 million for 20 projects focused on the permanent repair of roads and bridges in Puerto Rico, such as the damage illustrated in figure 8 below. Category D: Water Control Facilities. As of September 30, 2019, FEMA has obligated $435,493 for three projects, of which approximately $150,000 has been expended. This includes work on heavy water control infrastructure, such as berms or levees. Category E: Buildings and Equipment. FEMA obligated $43.5 million and Puerto Rico expended nearly $4 million for 87 projects focused on repairing and rebuilding damaged public buildings and equipment, such as the school shown in figure 9 below. Category F: Utilities. Of the $487 million FEMA obligated for permanent work projects, the largest share, $282 million was obligated for nine projects related to utilities, such as architectural and engineering design services for design work for electricity grid recovery projects. For example, in June 2019, FEMA obligated $111 million for architectural and engineering design services for design work for electricity grid recovery projects. Puerto Rico has expended just over $1 million of the funding obligated for projects related to repairing utilities. Category G: Parks, Recreational and Other Facilities. FEMA obligated approximately $20.9 million and Puerto Rico has expended just over $600,000 across 40 projects focused on repairing parks, playgrounds, and other facilities. Appendix II: Summary of GAO’s Assessment of the Federal Emergency Management Agency’s (FEMA) Cost Estimating Policies and Guidance GAO’s Cost Estimating and Assessment Guide (GAO Cost Guide) outlines best practices pertaining to cost estimating principles, presenting 12 steps to create high-quality estimates. These steps are generally applicable in a variety of circumstances and range from defining the purpose of the estimate to obtaining data to presenting the estimate to management for approval. Application of these principles should result in reliable and valid cost estimates that management can use to make informed decisions. To assess the extent to which FEMA’s cost estimating policy aligns with these best practices, we compared FEMA’s information to the GAO Cost Guide. Specifically, we reviewed FEMA documents containing cost estimating information pertinent to Public Assistance projects including FEMA’s Public Assistance Alternative Procedures Guide for Permanent Work FEMA-4339-DR-PR (Alternative Procedures Guide) and FEMA’s Cost Estimating Format (CEF) for Large Projects Instructional Guide V2.1 (dated September 2009). We compared FEMA’s guidance for developing cost estimates outlined in these documents against the 12 best practices described in the GAO Cost Guide. We assessed the extent to which these documents aligned with the best practices on a five point scale. Fully met. FEMA provided complete evidence that satisfies the elements of the step. Substantially met. FEMA provided evidence that satisfies a large portion of the elements of the step. Partially met. FEMA provided evidence that satisfies about half of the elements of the step. Minimally met. FEMA provided evidence that satisfies a small portion of the elements of the step. Not met. FEMA provided no evidence that satisfies any of the elements of the step. Taken together, FEMA’s documents provided cost estimating information that either substantially or fully meets nine of the 12 cost estimating steps. Furthermore, the information partially met two of the 12 steps, and minimally met one of the 12 steps. Table 1 summarizes GAO’s assessment of the extent to which FEMA’s information aligns with the 12 steps identified in the GAO cost guide. Appendix III: Comments from the Department of Homeland Security Appendix IV: Comments from the Commonwealth of Puerto Rico Appendix V: GAO Contact and Staff Acknowledgments GAO Contact Chris Currie, (404) 679-1875 or curriec@gao.gov. Staff Acknowledgments In addition to the contact named above, Joel Aldape (Assistant Director), Taylor Hadfield (Analyst in Charge), Michelle Bacon, Brian Bothwell, Lorraine Ettaro, Eric Hauswirth, Heidi Nielson, Danielle Pakdaman, Amanda Prichard, Kevin Reeves, and Mary Weiland made key contributions to this report. GAO Related Products U.S. Virgin Islands Recovery: Additional Actions Could Strengthen FEMA’s Key Disaster Recovery Efforts. GAO-20-54. Washington, D.C.: November 19, 2019. Disaster Resilience Framework: Principles for Analyzing Federal Efforts to Facilitate and Promote Resilience to Natural Disasters. GAO-20-100SP. Washington, D.C.: October 23, 2019. Disaster Recovery: Recent Disasters Highlight Progress and Challenges. GAO-20-183T. Washington, D.C.: October 22, 2019. Wildfire Disasters: FEMA Could Take Additional Actions to Address Unique Response and Recovery Challenges. GAO-20-5. Washington, D.C.: October 9, 2019. Puerto Rico Electricity Grid Recovery: Better Information and Enhanced Coordination Is Needed to Address Challenges. GAO-20-141. Washington, D.C.: October 8, 2019. Emergency Management: FEMA’s Disaster Recovery Efforts in Puerto Rico and the U.S. Virgin Islands. GAO-19-662T. Washington, D.C.: July 11, 2019. 2017 Disaster Relief Oversight: Strategy Needed to Ensure Agencies’ Internal Control Plans Provide Sufficient Information. GAO-19-479. Washington, D.C.: June 28, 2019. Emergency Management: FEMA Has Made Progress, but Challenges and Future Risks Highlight Imperative for Further Improvements. GAO-19-617T . Washington, D.C.: June 25, 2019. Emergency Management: FEMA Has Made Progress, but Challenges and Future Risks Highlight the Imperative for Further Improvements. GAO-19-594T. Washington, D.C.: June 12, 2019. Disaster Assistance: FEMA Action Needed to Better Support Individuals Who Are Older or Have Disabilities. GAO-19-318. Washington, D.C.: May 14, 2019. Disaster Contracting: Actions Needed to Improve the Use of Post- Disaster Contracts to Support Response and Recovery, GAO-19-281. Washington, D.C.: April 24, 2019. 2017 Hurricane Season: Federal Support for Electricity Grid Restoration in the U.S. Virgin Islands and Puerto Rico. GAO-19-296. Washington, D.C.: April 18, 2019. FEMA Grants Modernization: Improvements Needed to Strengthen Program Management and Cybersecurity. GAO-19-164. Washington, D.C.: April 9, 2019. Disaster Recovery: Better Monitoring of Block Grant Funds Is Needed. GAO-19-232. Washington, D.C.: March 25, 2019. Puerto Rico Hurricanes: Status of FEMA Funding, Oversight, and Recovery Challenges. GAO-19-256. Washington, D.C.: March 14, 2019. Huracanes de Puerto Rico: Estado de Financiamiento de FEMA, Supervisión y Desafíos de Recuperación. GAO-19-331. Washington, D.C.: March 14, 2019. High-Risk Series: Substantial Efforts Needed to Achieve Greater Progress on High-Risk Areas. GAO-19-157SP. Washington, D.C.: March 6, 2019. U.S. Virgin Islands Recovery: Status of FEMA Public Assistance Funding and Implementation. GAO-19-253. Washington, D.C.: February 25, 2019. 2017 Disaster Contracting: Action Needed to Better Ensure More Effective Use and Management of Advance Contracts. GAO-19-93. Washington, D.C.: December 6, 2018. Continuity of Operations: Actions Needed to Strengthen FEMA’s Oversight and Coordination of Executive Branch Readiness. GAO-19-18SU. Washington, D.C.: November 26, 2018. Homeland Security Grant Program: Additional Actions Could Further Enhance FEMA’s Risk-Based Grant Assessment Model. GAO-18-354. Washington, D.C.: September 6, 2018. 2017 Hurricanes and Wildfires: Initial Observations on the Federal Response and Key Recovery Challenges. GAO-18-472. Washington, D.C.: September 4, 2018. Federal Disaster Assistance: Individual Assistance Requests Often Granted but FEMA Could Better Document Factors Considered. GAO-18-366. Washington, D.C.: May 31, 2018. 2017 Disaster Contracting: Observations on Federal Contracting for Response and Recovery Efforts. GAO-18-335. Washington, D.C.: February 28, 2018. Disaster Recovery: Additional Actions Would Improve Data Quality and Timeliness of FEMA’s Public Assistance Appeals Processing. GAO-18-143. Washington, D.C.: December 15, 2017. Disaster Assistance: Opportunities to Enhance Implementation of the Redesigned Public Assistance Grant Program. GAO-18-30. Washington, D.C.: November 8, 2017. Climate Change: Information on Potential Economic Effects Could Help Guide Federal Efforts to Reduce Fiscal Exposure. GAO-17-720. Washington, D.C.: September 28, 2017. Federal Disaster Assistance: Federal Departments and Agencies Obligated at Least $277.6 Billion during Fiscal Years 2005 through 2014. GAO-16-797. Washington, D.C.: September 22, 2016. Disaster Recovery: FEMA Needs to Assess Its Effectiveness in Implementing the National Disaster Recovery Framework. GAO-16-476. Washington, D.C.: May 26, 2016. Disaster Response: FEMA Has Made Progress Implementing Key Programs, but Opportunities for Improvement Exist. GAO-16-87. Washington, D.C.: February 5, 2016. Hurricane Sandy: An Investment Strategy Could Help the Federal Government Enhance National Resilience for Future Disasters. GAO-15-515. Washington, D.C.: July 30, 2015. Budgeting for Disasters: Approaches to Budgeting for Disasters in Selected States. GAO-15-424. Washington, D.C.: March 26, 2015. High-Risk Series: An Update. GAO-15-290. Washington, D.C.: February 11, 2015. Emergency Preparedness: Opportunities Exist to Strengthen Interagency Assessments and Accountability for Closing Capability Gaps. GAO-15-20. Washington, D.C.: December 4, 2014. Fiscal Exposures: Improving Cost Recognition in the Federal Budget. GAO-14-28. Washington, D.C.: October 29, 2013. Federal Disaster Assistance: Improved Criteria Needed to Assess a Jurisdiction’s Capability to Respond and Recover on Its Own. GAO-12-838. Washington, D.C.: September 12, 2012.