GAO-24-106676, Disaster Relief Fund: Lessons Learned from COVID-19 Could Improve FEMA’s Estimates

Summary

GAO-24-106676, Disaster Relief Fund: Lessons Learned from COVID-19 Could Improve FEMA's Estimates, a Q&A report to congressional committees from the U.S. Government Accountability Office dated July 9, 2024. It reports that as of March 2024 FEMA reported obligations of $125.3 billion from the Disaster Relief Fund for COVID-19 assistance, of which $103.6 billion had been expended, and estimated $171.6 billion for the entire disaster. GAO finds that DRF appropriations have not kept pace with expected obligations and that FEMA underestimated its COVID-19 obligations in fiscal years 2021 and 2022. FEMA's initial estimate of $17.6 billion rose to $63.8 billion at 6 months and $122 billion at 12 months. GAO recommends FEMA identify and document lessons learned on estimating obligations for declared catastrophic disasters.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Page 1
GAO-24-106676 FEMA’s COVID-19 Assistance

On March 13, 2020, the President declared a nationwide emergency for the
COVID-19 pandemic, authorizing assistance from the Disaster Relief Fund
(DRF)—a key source of federal funding for natural disaster response and
recovery. The President subsequently issued 59 major disaster declarations for
all 50 states, the District of Columbia, five territories, and three Tribes. This
marked the first time the DRF has been used to respond to a nationwide public
health emergency. The Federal Emergency Management Agency (FEMA), which
manages the DRF, played a leading role in the federal COVID-19 response.
Members of Congress have raised questions about FEMA’s COVID-19
assistance and its effects on the DRF. Although the DRF received supplemental
appropriations in COVID-19 relief legislation, funding requirements for the DRF
threatened to exceed available resources by August 2023. In response, FEMA
implemented measures to prioritize response and immediate recovery efforts and
to pause new DRF obligations that were not essential for lifesaving and life-
sustaining activities.
The joint explanatory statement accompanying the Consolidated Appropriations
Act, 2023, includes a provision for us to evaluate various aspects of FEMA’s
COVID-19 response.1 This report examines the status of obligations and
expenditures related to COVID-19 and how FEMA estimated these costs.
.
•
As of March 2024, FEMA reported obligations of $125.3 billion from the DRF
for COVID-19 assistance, of which $103.6 billion had been expended. FEMA
estimated that obligations would total $141.3 billion through the end of fiscal
year 2024, and $171.6 billion for the entire disaster.
•
FEMA expects to obligate and expend funds through August 10, 2026, for
COVID-19 Public Assistance projects completed during the disaster incident
period (January 20, 2020, through May 11, 2023). In addition, FEMA
continues to accept applications for COVID-19 funeral assistance.
•
The amount FEMA has received in appropriations for the DRF has not kept
pace with the amount FEMA has expected to obligate for major disasters,
including COVID-19, increasing the risk of insufficient funding.
•
FEMA has a process to estimate its obligations for COVID-19. However,
FEMA underestimated its COVID-19 obligations in fiscal years 2021 and
2022 and generally has not met its own estimation accuracy goal. FEMA
officials told us that it was challenging to estimate obligations for the COVID-
19 disaster because changes in policies and other factors increased the
uncertainty of costs.
•
We recommend that FEMA identify and document lessons learned related to
estimating obligations for declared catastrophic disasters based on its
experience with COVID-19.

U.S. Government Accountability Office
Disaster Relief Fund: Lessons Learned from
COVID-19 Could Improve FEMA’s Estimates
GAO-24-106676
Q&A Report to Congressional Committees
July 9, 2024
Why This Matters
Key Takeaways

Page 2
GAO-24-106676 FEMA’s COVID-19 Assistance

The DRF is the primary source of federal disaster assistance for tribal, state, and
territorial governments, as well as individuals and households, when a major
disaster is declared. Through the DRF, FEMA can direct, coordinate, manage,
and fund eligible response and recovery efforts associated with major disasters
declared pursuant to the Robert T. Stafford Disaster Relief and Emergency
Assistance Act (Stafford Act).2
Following a disaster, a tribal chief executive or state or territorial governor may
submit a request to the President for a major disaster declaration if the Tribe,
state, or territory determines that an effective response is beyond its capabilities.
An approved major disaster declaration by the President provides a wide range
of federal disaster assistance programs from the DRF to tribal, state, and
territorial governments and certain nonprofit organizations, as well as individuals
and households.
According to the Congressional Research Service, costs incurred for major
disaster declarations account for more than 95 percent of DRF obligations.3 In
addition, the DRF supports activities outside of major disaster declarations, such
as preparing federal employees and resources prior to a declaration.

Congress funds the DRF through a combination of annual and supplemental
appropriations. Appropriations to the DRF are generally no-year funding,
meaning the funds remain available indefinitely.4 Appropriations to the DRF are
generally not specific to individual disasters or events, including COVID-19.
For fiscal years 2020 through 2024, Congress passed both annual and
supplemental appropriations for the DRF. The supplemental appropriations
included three COVID-19 relief laws, which provided $97 billion in total to the
DRF (see fig. 1).
Figure 1: Disaster Relief Fund Appropriations, Fiscal Years (FY) 2020 through 2024
Notes: The Infrastructure Investment and Jobs Act, enacted in November 2021, made supplemental appropriations of $1 billion for the Disaster Relief
Fund (DRF) for the Building Resilient Infrastructure and Communities (BRIC) program for fiscal years 2022 through 2026. Specifically, it made available
until expended $200 million dollars for each fiscal year. Pub. L. No. 117-58, 1335 Stat. 429, 1387 (2021). The Continuing Appropriations Act, 2023,
transferred $2.5 billion from the amount appropriated to the DRF in the CARES Act to carry out the Hermit’s Peak/Calf Canyon Fire Assistance Act. Pub.
L. No. 117-180, § 136, 136 Stat. 2114, 2122 (2022). In September 2023, the Continuing Appropriations Act, 2024 and Other Extensions Act appropriated
$16 billion to the Federal Emergency Management Agency (FEMA) for the DRF, and in March 2024, the Further Consolidated Appropriations Act, 2024,
appropriated $20.3 billion to FEMA for the DRF. Pub. L. No. 118-15, § 129, 137 Stat. 71, 78 (2023); Pub. L. No. 118-47, 113 Stat. 460.
What is FEMA’s DRF?
How is the DRF
funded?

Page 3
GAO-24-106676 FEMA’s COVID-19 Assistance
FEMA officials told us that the amount the President requests for annual
appropriations for major disasters is based on a statutory formula. The formula
sets the maximum that can be appropriated as part of the disaster relief
adjustment to the discretionary spending cap.5 Further, the request includes a
reserve of $2 billion to ensure that FEMA maintains the ability to fund initial
response operations for new significant events. Given the uncertainty of future
disasters, FEMA’s annual appropriations requests note the assumption that any
new catastrophic events (those costing the federal government more than $500
million) that occur during the budget year will be funded separately with
supplemental appropriations.

Three FEMA programs and activities supported the COVID-19 response: (1)
Public Assistance, (2) Individual Assistance, and (3) mission assignments.6
FEMA uses the DRF for each of these programs and activities (see fig. 2).
Figure 2: FEMA Programs and Activities that Supported the COVID-19 Response

Following the COVID-19 major disaster declarations in early 2020, FEMA initially
estimated it would obligate a total of $17.6 billion for COVID-19 assistance,
according to FEMA officials. FEMA officials told us that this estimate was “blown
out of the water” by actual costs.
The initial estimate is known as the 30-day Life of Disaster estimate. FEMA
calculates the estimate 30 days after every major disaster declaration to estimate
how much the entire disaster could cost. FEMA then adjusts the Life of Disaster
estimate at several intervals as more information on obligations becomes
available, including at 6 months and 12 months, when the estimate begins to
stabilize and level off, according to officials. For COVID-19, FEMA updated its
What FEMA programs
and activities
supported the
COVID-19 response?
What was FEMA’s
initial estimate for
COVID-19 obligations?

Page 4
GAO-24-106676 FEMA’s COVID-19 Assistance
estimate to $63.8 billion at 6 months and $122 billion at 12 months. As of March
2024, the most current Life of Disaster estimate available was $171.6 billion.7
According to officials, due to the unprecedented nature and scale of COVID-19,
no one knew initially how much it would cost. FEMA officials said they could not
use the same information they typically use for the Life of Disaster estimate after
natural disasters, which involves reviewing historical information and assessing
physical damages in an affected area. Instead, FEMA officials told us they used
a national, top-down estimation process that relied on information such as
population data, numbers of COVID-19 cases, and average costs for eligible
items.
Further, FEMA officials told us they did not have visibility into what Tribes, states,
and territories were spending to respond to COVID-19—and therefore, what
FEMA would reimburse—until applicants began submitting Public Assistance
projects to FEMA for review and cost determination. This and other factors
increased the timeline for developing more accurate spending projections.

As of March 2024, FEMA reported obligations of $125.3 billion from the DRF to
respond to COVID-19.8 FEMA reported obligating the majority of funds for Public
Assistance and Individual Assistance (see fig. 3).
Figure 3: FEMA Obligations for COVID-19 by Program and Activity, as of March 2024

Notes: FEMA incurs administrative costs, which support the delivery of major disaster assistance. For the
COVID-19 response, FEMA’s obligations for administrative costs included, for example, salaries and benefits
for the disaster workforce. Percentages do not add up to 100 percent due to rounding.
FEMA reported that as of March 2024, it has made obligations for about 33,100
projects under the Public Assistance program, with an additional 7,200 projects
in the review process. Examples of eligible expenses for Public Assistance
projects include COVID-19 vaccination and testing services, alternate care
facilities, and personal protective measures such as N95 respirators (see fig. 4).
How much has FEMA
obligated from the DRF
for COVID-19?

Page 5
GAO-24-106676 FEMA’s COVID-19 Assistance
Figure 4: Examples of COVID-19 Projects Eligible for FEMA Public Assistance

Within Individual Assistance, most of the obligations (about $36.5 billion) were for
lost wages assistance, followed by $3.5 billion for COVID-19 funeral assistance
and $428.6 million for Crisis Counseling, according to FEMA data.
As of March 2024, FEMA’s data show that the largest total COVID-19 obligations
have been to New York, Texas, and California, with more than $15 billion each
(see fig. 5). In addition, of the total obligations, FEMA has reported obligating
approximately $78.8 million to tribal governments. According to the
Congressional Budget Office, hurricanes constitute the largest category of DRF
spending. However, GAO previously reported that obligations from the DRF for
COVID-19 exceeded obligations for each of the five costliest storms (hurricanes
Katrina, Maria, Sandy, Harvey, and Irma).9

Page 6
GAO-24-106676 FEMA’s COVID-19 Assistance
Figure 5: Disaster Relief Fund Obligations for COVID-19, as of March 2024

As of March 2024, FEMA reported expenditures of $103.6 billion of the $125.3
billion obligated for COVID-19 from the DRF.10 Of the total expenditures,
approximately $69.2 million went to tribal governments. The remaining
unexpended obligations are definite commitments that have not yet been paid to
applicants.
According to the Congressional Budget Office, expenditures for COVID-19
assistance accounted for 20 percent of all DRF expenditures between 1992 and
2021 and were the largest amount spent for a single event.11 Further,
expenditures from the DRF in 2020 and 2021—75 percent of which were spent
on COVID-19 assistance—accounted for the two highest annual totals in the
DRF’s history.

In fiscal years 2023 and 2024, the amount FEMA has received in appropriations
for the DRF has not kept pace with the amount FEMA has expected to obligate
for major disasters, including COVID-19—increasing the risk of insufficient
funding.
Although FEMA received about $97 billion in total supplemental appropriations in
2020 and 2021 as part of the COVID-19 relief laws, the $125.3 billion FEMA has
obligated for COVID-19 assistance as of March 2024 exceeds that amount.
Meanwhile, FEMA has continued to make obligations from the DRF for other
How much has FEMA
expended from the DRF
for COVID-19?
Have appropriations
kept pace with
expected obligations
for COVID-19?

Page 7
GAO-24-106676 FEMA’s COVID-19 Assistance
ongoing and new major disasters, such as the 2017 hurricanes and the 2023
wildfires in Hawaii.
For each fiscal year from 2019 through 2024, figure 6 shows the budget authority
for the year, obligations from the fund during the year, the ending balance, and
appropriations for the next fiscal year (where available).
Figure 6: Disaster Relief Fund (DRF) Balance, Fiscal Years 2019 through 2024

Notes: Budget authority includes carryover balance from prior years as well as annual and supplemental appropriations, recoveries, recissions, and
transfers stipulated in law. Obligations are definite commitments that create a legal liability of the government for the payment of goods and services
ordered or received. DRF ending balances are those reported in FEMA’s reports to Congress for data as of the end of the fiscal year. Per these reports,
amounts were subject to change pending final closeout of the accounting system during October of each year. In addition, obligation amounts shown in
the figure were as of the point in time when the data were pulled and were subject to change, for example, due to deobligation or reconciliation when
actual project costs were lower than the original estimate. Amounts for fiscal year 2024 are projections through the end of the fiscal year as of March
2024.
In August 2023, due to a low balance in the DRF, FEMA implemented measures
to prioritize response and immediate recovery efforts and to pause new
obligations that were not essential for lifesaving and life-sustaining activities. As a
result, Tribes, states, and territories experienced delays in receiving
reimbursement for Public Assistance projects. FEMA lifted these restrictions after
receiving appropriations for the DRF in the October 2023 continuing resolution.
As shown in figure 6 above, FEMA is again projecting that expected costs will
exceed available DRF funding in fiscal year 2024, which may necessitate either
supplemental appropriations or the same measures as fiscal year 2023 to pause
new obligations for some projects.
FEMA officials told us that due to the statutory limit on what can be appropriated
annually for the DRF, any funding needs above this amount must be sourced
through supplemental appropriations. In October 2023, after Congress passed
the continuing resolution, the President submitted a request for supplemental
appropriations that included an additional $9 billion for the DRF. As of March
2024, FEMA had not received supplemental appropriations for the DRF in fiscal
year 2024.

Page 8
GAO-24-106676 FEMA’s COVID-19 Assistance
FEMA provides an annual report to Congress on the DRF’s funding
requirements, which identifies potential shortfalls that may occur in the budget
year. FEMA also provides Congress with monthly reports on the status of the
DRF, which include changes to fiscal year budget requirements and the
projected end-of-year balance.

According to FEMA officials, they expect obligations and expenditures for
COVID-19 assistance to continue through August 10, 2026, which FEMA
established as the end of the grant closeout period for Public Assistance (see fig.
7).
Figure 7: Key Dates in Closeout of FEMA’s COVID-19 Assistance

Notes: FEMA officials told us that following the May 11, 2023, work completion deadline, any additional costs
that applicants incur are most likely to be management costs. The officials further said that applicants may also
receive reimbursements due to reconciling actual costs from large projects developed using an estimate, but in
general, these reconciled costs should not include additionally incurred costs.
For Public Assistance, FEMA continues to review and make obligations for
applications submitted by November 7, 2023, the deadline for project
applications. FEMA officials told us that about 67 Public Assistance project
applications were approved for extensions beyond this deadline.
For Individual Assistance, FEMA announced it will continue to provide COVID-19
funeral assistance for funeral expenses incurred through September 30, 2025.
FEMA has not yet established an application deadline for the program.
Several factors contribute to the time frames for FEMA to complete COVID-19
obligations and expenditures. Compared to other disasters, officials told us the
volume of projects for COVID-19 was much greater, considering the disaster
spanned 59 declarations over a 3-year incident period. Further, FEMA officials
told us they saw a surge in requests for Public Assistance after January 2021,
when FEMA’s reimbursement rate changed from 75 percent to 100 percent.12
Officials from one state told us they did not apply for Public Assistance until this
point and after they had exhausted other sources of funding.
When does FEMA
expect to complete its
COVID-19 obligations
and expenditures?

Page 9
GAO-24-106676 FEMA’s COVID-19 Assistance

FEMA officials told us they estimate obligations for COVID-19 (as for any major
disaster) by adding together the amounts FEMA expects to spend for each
program across all affected Tribes, states, and territories, on a monthly and
yearly basis.
The process starts in the FEMA regions, where FEMA staff obtain information on
projected spending and update the region’s spend plan for each COVID-19
declaration (i.e., Tribe, state, or territory). Regional staff review the spend plans
on a weekly basis and refine them as additional information becomes available.
FEMA’s National Spend Plan team uses the regional spend plans to develop an
overall spend plan for COVID-19 each fiscal year, including annual and monthly
baseline estimates. FEMA continuously updates the information in the overall
spend plan and revises the estimates throughout the year, comparing the
updated estimates against the baseline estimates.
•
Public Assistance. FEMA staff develop “bottom-up” estimates by accounting
for (1) the estimated or actual amounts for each known project and (2) the
expected timing for obligation of funds. This is based on the time anticipated
for FEMA to complete the application review process. FEMA regional officials
add these amounts into the region’s spend plan along with the predicted date
when FEMA is likely to complete the review process and obligate funds for
each project.

FEMA provided guidance to regional staff to help them predict when funds
would be obligated. However, FEMA officials told us that predicting timing
can be challenging due to the many factors that affect how quickly projects
move through the process, such as project delays, additional eligibility
reviews, and required duplication of benefits reviews for projects involving
patient care.13 One FEMA official referred to relying on a “gut feel” for
predicting obligation dates.
•
Individual Assistance. FEMA headquarters staff developed “top-down”
estimates for programs, including COVID-19 funeral assistance and lost
wages assistance. According to FEMA officials, they estimated obligations for
each state and territory based on factors such as the projected number of
recipients, the eligibility rate, and the average payout per applicant, which
they then input into the regional spend plans.

For example, for lost wages assistance, FEMA officials told us they worked
with actuaries from the Department of Labor who are knowledgeable about
unemployment insurance to develop an estimate. Given that the program had
a fixed cap of $44 billion as directed by the President, FEMA staff then
worked with states and territories to determine the total dollar amount that
would be available for each jurisdiction.14

FEMA’s COVID-19 estimates were not accurate based on FEMA’s accuracy
goal. FEMA has a goal for its actual obligations to fall within 10 percent of the
baseline estimate by the end of the fiscal year. This is for individual disasters and
for the DRF overall. Although the COVID-19 estimates improved over time,
FEMA did not meet the accuracy goal in any fiscal year from 2021 through 2023.
FEMA is currently on track to meet the goal in fiscal year 2024 (see fig. 8).
How does FEMA
estimate future
COVID-19 obligations?
Were FEMA’s COVID-19
and overall DRF
estimates accurate?

Page 10
GAO-24-106676 FEMA’s COVID-19 Assistance
Figure 8: FEMA DRF Baseline Estimates and Actual Obligations, Fiscal Years 2021 through
2024

Notes: From August 2023 through September 2023, due to a low balance in the Disaster Relief Fund (DRF),
FEMA implemented measures to prioritize response and immediate recovery efforts and to pause new
obligations that were not essential for lifesaving and life-sustaining activities. As a result, FEMA delayed
obligating funds for some projects until fiscal year 2024 when additional appropriations to the DRF were
available.
With regard to FEMA’s estimates for total DRF obligations since the start of
COVID-19, FEMA met its accuracy goal in fiscal year 2022 and is on track to
meet the goal in fiscal year 2024. FEMA officials told us that they focus on
meeting the accuracy goal for the DRF overall, which could mean that FEMA
obligates more or less for some disasters than what was reported in the original
baseline due to the agency strategically reprioritizing available resources.

FEMA officials told us that COVID-19-related policy changes and the
complexities of COVID-19-related costs affected the accuracy of the baseline
estimates for COVID-19.
•
Policy changes post-declaration. FEMA officials said that frequent changes
to available programs and eligibility rules increased FEMA’s funding
requirements above the baseline estimates. These changes included, for
example, lost wages assistance, for which up to $44 billion was authorized,
and the decision to increase FEMA’s reimbursement rate for Public
Assistance projects from 75 to 100 percent. FEMA regional officials told us
that COVID-19-related policy changes meant that some work originally
determined to be ineligible later became eligible, resulting in rework of
previous applications and changes in obligations.
•
Complexities of COVID-19 costs. Officials from FEMA headquarters and
some regions also said that the complexity of COVID-19 costs made the
pandemic a challenging disaster for estimating obligations. Factors included
duplication of benefits reviews, uncertainty about costs of supplies and how
much would be needed, and the variation in approaches by different
What factors affected
the accuracy of the
baseline estimates for
COVID-19?

Page 11
GAO-24-106676 FEMA’s COVID-19 Assistance
jurisdictions. FEMA officials also told us that because Tribes, states, and
territories had multiple funding sources, it was not always clear what FEMA
would fund versus other federal agencies.

FEMA officials told us the agency has not identified lessons learned for its
estimation processes or methodologies for declared catastrophic disasters based
on its experience with COVID-19, nor does it plan to do so. In March 2024,
FEMA officials told us that COVID-19 was an unprecedented event for FEMA,
with 59 simultaneous disaster declarations across the country and a lack of
physical damages to assess—in contrast to most disasters FEMA responds to.
The officials said they do not expect another pandemic to occur, therefore the
agency does not plan to assess or change the overall estimation process for
declared catastrophic disasters based on its experience with COVID-19.
However, FEMA may face challenges responding to catastrophic events in the
future that are similar to the challenges posed by COVID-19. For example, FEMA
may be faced with responding to another nationwide disaster; another public
health emergency that involves patient care and lacks physical damages;
another large-scale, long-duration disaster; or multiple large disasters at one time
that strain its resources. FEMA documentation shows that the number of
disasters it manages per year has risen significantly—from 108 on average in
2012 to 311 in 2022—and that demands on the agency will only increase
further.15 All these scenarios present challenges to FEMA’s disaster
management, including how it estimates obligations for declared catastrophic
disasters from the DRF.
While we agree that the COVID-19 disaster was unprecedented, according to
key practices that we and others have identified for project management, it is
important to identify and apply lessons learned from events to inform future
efforts and limit the chance of recurring challenges.16 Lessons learned provide a
powerful way to share knowledge about improving work processes, quality,
safety, and cost effectiveness.
FEMA officials told us that if another pandemic occurs, FEMA can review its
estimation processes at that point to identify lessons learned from COVID-19.
However, our prior work on the COVID-19 pandemic has stressed that lessons
learned should be prepared promptly so that knowledgeable personnel, for
example, are available to contribute to the reports; important details are recalled
accurately; and there are no delays in the dissemination of lessons learned.17
Further, federal internal control standards state that in the event of a significant
change, management should review relevant policies and procedures in a timely
manner to determine that they remain appropriate in light of the change.18
In addition, by preparing lessons learned promptly, FEMA may be able to apply
the lessons in a timely way to its estimation processes for COVID-19 and other
declared catastrophic disasters going forward. As described above, FEMA is
projecting that expected costs will exceed available DRF funding in fiscal year
2024. Additional catastrophic disasters during the fiscal year, such as multiple
severe hurricanes, could increase the risk of running a low DRF balance.
Lessons learned may help FEMA to better anticipate its funding needs and avoid
this outcome in the future.
By identifying and documenting lessons learned related to estimating obligations
for declared catastrophic disasters based on its experience with COVID-19,
FEMA can better position itself to adapt to similar estimation challenges in the
future and better ensure it provides Congress with accurate estimates of its
funding needs.
Has FEMA identified
lessons learned for its
estimation processes
based on COVID-19?

Page 12
GAO-24-106676 FEMA’s COVID-19 Assistance

COVID-19 was an unprecedented event for FEMA, marking the first time it used
the DRF to respond to a nationwide public health emergency. FEMA officials told
us the agency followed its standard processes for estimating total obligations for
major disasters (including catastrophic disasters) but faced several challenges
accurately estimating obligations for COVID-19. FEMA could face another
catastrophic disaster in the future that poses similar challenges.
However, FEMA has not identified or documented lessons learned regarding
estimation processes for declared catastrophic disasters based on its experience
with COVID-19, nor does it plan to do so. Identifying and documenting lessons
learned would better position FEMA to adapt to challenges related to estimating
obligations during future catastrophic disasters that may be similar in scope or
duration to COVID-19. Moreover, there are presently numerous concurrent
demands on the DRF, including remaining COVID-19 assistance, a significant
number of other active disasters in different stages of recovery, and activities to
prepare staff and resources for future response needs that are difficult to predict.
Having lessons learned for estimating obligations can help FEMA more
accurately project its future funding needs and more effectively oversee the DRF.

The FEMA Administrator should identify and document lessons learned related to
estimating obligations for declared catastrophic disasters based on its experience
with COVID-19. (Recommendation 1)

We provided a draft of this report to DHS for review and comment. In its written
comments, which are reproduced in appendix I, DHS did not concur with our
recommendation. DHS also provided technical comments that we incorporated,
as appropriate.
In its comments, DHS noted that FEMA had conducted two after-action reviews
in 2021 to identify lessons learned based on its operations in response to the
pandemic. FEMA provided one of the two after-action reports during our review,
and we found that it did not assess FEMA’s procedures for estimating obligations
to respond to COVID-19. According to DHS’s comments, the second after-action
report reviewed vaccine mission operations, which similarly would not focus on
estimating obligations. Further, these after-action reviews were conducted in
2021, and as such could only capture lessons from early in the COVID-19
incident period.
Additionally, DHS stated that FEMA leadership believes identifying lessons
learned for estimating obligations specific to COVID-19 is not justified because
FEMA does not anticipate being directed to implement similar forms of
assistance in the future. Officials also stated that FEMA previously implemented
cost estimation improvements in 2019 after responding to the catastrophic
hurricanes Harvey, Irma, and Maria, which represent a hazard type more likely to
occur in the future. However, our findings—specifically, that FEMA’s COVID-19
estimates were not accurate—indicate that any changes implemented prior to
COVID-19 were not sufficient to enable FEMA to accurately estimate costs for
COVID-19.
As we noted in this report, while we agree that the COVID-19 disaster was
unprecedented, FEMA may face challenges responding to catastrophic events in
the future that are similar in scope or duration to the challenges posed by
COVID-19. Thus, it is important to identify and apply lessons learned from events
to inform future efforts and limit the chance of repeating past missteps. As such,
we maintain that our recommendation is warranted. In the event that FEMA is
faced with another catastrophic disaster with any characteristics similar to those
of COVID-19, such as a nationwide disaster or a public health emergency,
Conclusions
Recommendation for
Executive Action
Agency Comments and
Our Evaluation

Page 13
GAO-24-106676 FEMA’s COVID-19 Assistance
having lessons learned for estimating obligations can better position FEMA to
adapt to estimation challenges in the future.

We reviewed relevant laws and FEMA policies, procedures, and guidance related
to estimating obligations for COVID-19. We also reviewed documentation for
FEMA programs implemented in response to COVID-19, such as eligibility and
award closeout deadlines. We conducted interviews with officials at FEMA’s
headquarters and requested information from FEMA’s 10 regional offices on the
status of DRF obligations and expenditures for COVID-19 and their experiences
estimating for COVID-19 and previous disasters, as well as any lessons learned.
Nine of the 10 regional offices provided information.
Further, we interviewed emergency managers in three states—Illinois, South
Dakota, and Texas—to understand the recipient’s role in estimating project costs.
We selected these states to represent a range of experiences with natural
disasters and effects from COVID-19 such as numbers of deaths and hospital
admissions. The information gathered from these interviews was not
generalizable, but it allowed us to gain insights into the similarities and
differences in project cost estimation by states.
To describe the status of obligations and expenditures related to COVID-19, we
obtained and analyzed data that covered costs incurred for COVID-19 from
January 2020 to March 2024 from FEMA’s COVID-19 Financial Information Tool
report. This report contains data on DRF obligations and expenditures for
COVID-19. The COVID-19 Financial Information Tool uses data from FEMA’s
financial and accounting system, the Integrated Financial Management
Information System. To assess the reliability of these data, we reviewed data
system documents, interviewed agency officials about the data provided, and
tested the data for potential reliability concerns. Further, we compared the data to
FEMA’s monthly DRF reports to Congress and followed up with FEMA to better
understand the data elements. We determined the data were sufficiently reliable
for reporting the amount of funds obligated and expended for COVID-19.
To assess how FEMA estimated COVID-19 obligations for the DRF, we analyzed
data from FEMA’s monthly DRF reports to Congress from September 2021 to
March 2024 on COVID-19 baseline estimates and actual obligations to determine
if FEMA’s actual obligations met FEMA’s accuracy goal. To assess the reliability
of these data, we reviewed examples of spend plans that are used to compile
FEMA COVID-19 estimates, interviewed agency officials about their processes,
and reviewed the data for potential reliability concerns such as irregularities. We
determined the data were sufficiently reliable for reporting COVID-19 baseline
estimates and actual obligations. We compared the information we obtained from
FEMA officials about lessons learned to key practices that we and others, such
as the Project Management Institute, have identified for project management.
We conducted this performance audit from February 2023 to July 2024 in
accordance with generally accepted government auditing standards. Those
standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objectives. We believe that the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.

The Honorable Chris Murphy
Chair
The Honorable Katie B. Britt
Ranking Member
How GAO Did This
Study
List of Addressees

Page 14
GAO-24-106676 FEMA’s COVID-19 Assistance
Subcommittee on Homeland Security
Committee on Appropriations
United States Senate
The Honorable Mark Amodei
Chairman
The Honorable Lauren Underwood
Acting Ranking Member
Subcommittee on Homeland Security
Committee on Appropriations
House of Representatives
We are sending copies of this report to the appropriate congressional
committees, the Secretary of Homeland Security, and other interested parties. In
addition, the report is available at no charge on the GAO website at
https://www.gao.gov.

For more information, contact: Chris Currie, Director, Homeland Security and
Justice, CurrieC@gao.gov, (404) 679-1875.
Sarah Kaczmarek, Acting Managing Director, Public Affairs,
KaczmarekS@gao.gov, (202) 512-4800.
A. Nicole Clowers, Managing Director, Congressional Relations,
ClowersA@gao.gov, (202) 512-4400.
Staff Acknowledgments: Alana Finley (Assistant Director), Marissa Esthimer
(Analyst-in-Charge), Jennifer Kamara, and Herrica Telus made key contributions
to this report. Nasreen Badat, Elizabeth Dretsch, Eric Hauswirth, John Karikari,
and Tracey King also contributed.
Connect with GAO on Facebook, Flickr, Twitter, and YouTube. Subscribe to our
RSS Feeds or Email Updates. Listen to our Podcasts.
Visit GAO on the web at https://www.gao.gov.
This work of the United States may include copyrighted material, details at
https://www.gao.gov/copyright.

GAO Contact
Information

Page 15
GAO-24-106676 FEMA’s COVID-19 Assistance

Appendix I: Comments
from the Department of
Homeland Security

Page 16
GAO-24-106676 FEMA’s COVID-19 Assistance

Page 17
GAO-24-106676 FEMA’s COVID-19 Assistance

1Staff of H. Comm. on Appropriations, 117th Cong., Explanatory Statement on the Consolidated
Appropriations Act, 2023, Pub. L. No. 117-328, 136 Stat. 4459 (2022), at 1361 (Comm. Print 2022).
2Federal assistance provided pursuant to the Stafford Act supports tribal, state, local, and territorial
governments, and certain nonprofit organizations, as well as individuals and households, with
response to and recovery from a declared major disaster or emergency. 42 U.S.C. § 5121 et seq.
3Congressional Research Service, The Disaster Relief Fund: Overview and Issues, R45484
(Washington, D.C.: Jan. 22, 2024).
4The American Rescue Plan Act of 2021 appropriated to FEMA $50 billion for the DRF with a 5-
year period of availability, ending on September 30, 2025. Pub. L. No. 117-2, § 4005, 135 Stat. 4,
79 (2021).
5See 2 U.S.C. § 901(b)(2)(D). This provision outlines the methodology for calculating the maximum
amount that can be appropriated for major disaster assistance for fiscal years 2024 and 2025. The
Endnotes

Page 18
GAO-24-106676 FEMA’s COVID-19 Assistance

methodology is based on three components: the average of major disaster assistance funding over
the previous 10 years (excluding the highest and lowest years); 5 percent of supplemental DRF
appropriations designated as emergency requirements over the previous 10 years; and the
difference between the total adjustment allowed and the enacted appropriations for each year from
fiscal year 2018 and after.
6In addition to these three programs and activities, in August 2021, the President approved FEMA
to spend up to $3.5 billion from the DRF for the Hazard Mitigation Grant Program in connection with
COVID-19. This decision allows all 59 Tribes, states, and territories that received a major disaster
declaration for COVID-19 to receive grants of up to 4 percent of their COVID-19 disaster costs for
mitigation projects that reduce risks from natural disasters. We do not include the Hazard Mitigation
Grant Program in our obligation and expenditure totals because this program does not support the
COVID-19 response. As of March 2024, FEMA reported obligating about $628.7 million for hazard
mitigation grants tied to COVID-19 declarations.
7This Life of Disaster estimate includes estimated costs for hazard mitigation grants tied to COVID-
19 declarations.
8An obligation is a definite commitment that creates a legal liability of the government for the
payment of goods and services ordered or received.
9GAO, COVID-19: Urgent Actions Needed to Better Ensure an Effective Federal Response, GAO-
21-191 (Washington, D.C.: Nov. 30, 2020).
10FEMA defines expenditures as liquidated obligations.
11Congressional Budget Office, FEMA’s Disaster Relief Fund: Budgetary History and Projections
(Washington, D.C.: Nov. 2022).
12Typically, FEMA’s reimbursement rate (the federal cost share) for Public Assistance is 75 percent
of eligible costs, with Tribes, states, and territories covering the remaining 25 percent. See 44
C.F.R. § 206.47(a). For COVID-19, the President announced in January 2021 that FEMA would
reimburse 100 percent of eligible costs, a cost share that remained in place for costs incurred
through July 1, 2022. Subsequently, FEMA reduced its cost share to 90 percent for costs incurred
through May 11, 2023, the end of the incident period for COVID-19.
13For Public Assistance projects involving COVID-19 patient care revenue, FEMA conducted
duplication of benefits reviews that examined whether a reported cost was covered by another
source of funding, such as health insurance, which would make the cost ineligible. FEMA uses a
risk-based approach for these reviews, considering factors such as project size, work claimed, and
work that is billable to patients, according to FEMA documentation.
14The presidential memorandum establishing the lost wages program directed that the program
would end when $44 billion had been obligated; the balance of the Disaster Relief Fund reached
$25 billion; on December 27, 2020; or upon the enactment of legislation providing supplemental
federal unemployment compensation, whichever would come first. The White House, Memorandum
on Authorizing the Other Needs Assistance Program for Major Disaster Declarations Related to
Coronavirus Disease 2019 (Aug. 8, 2020).
15FEMA, 2022-2026 FEMA Strategic Plan: Building the FEMA our Nation Needs and Deserves
(2022).
16GAO, COVID-19: Pandemic Lessons Highlight Need for Public Health Situational Awareness
Network, GAO-22-104600 (Washington, D.C.: June 23, 2022); GAO, Federal Hiring: OPM Should
Collect and Share COVID-19 Lessons Learned to Inform Hiring during Future Emergencies, GAO-
22-104297 (Washington, D.C.: Oct. 25, 2021); and GAO, Project Management: DOE and NNSA
Should Improve their Lessons-Learned Process for Capital Asset Projects, GAO-19-25
(Washington, D.C.: Dec. 21, 2018). We also identified lessons learned practices from the Project
Management Institute. Project Management Institute, Inc., The Standard for Project Management
and a Guide to the Project Management Body of Knowledge (PMBOK® Guide), Seventh Edition
(2021).
17GAO-22-104600; GAO-22-104297.
18GAO, Standards for Internal Control in the Federal Government, GAO-14-704G (Washington,
D.C.: Sept. 2014).

File and source

File

24-106676-disaster-relief-fund-lessons-learned-from-covid.pdf

Size

3,777,102 bytes

SHA-256

a1850ce2ea81befdb83874a957afa53c69ea34965eb4adb33b1eee32e31a3e3a

Our copy

24-106676-disaster-relief-fund-lessons-learned-from-covid.pdf

Original

www.gao.gov