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DHS OIG, FEMA Did Not Provide Sufficient Oversight of Project Airbridge (OIG-23-14, 2023-02-07)

Summary

Department of Homeland Security Office of Inspector General report OIG-23-14, dated February 7, 2023, "FEMA Did Not Provide Sufficient Oversight of Project Airbridge," sent by Inspector General Joseph V. Cuffari to FEMA Administrator Deanne Criswell. It states that FEMA spent $237.6 million to transport approximately 1.1 billion PPE items, and that the project supplemented the distributors' already large domestic inventories. It states that the office could only confirm distributors delivered 35 percent of the Airbridge PPE to designated healthcare facilities in prioritized locations instead of the 50 percent minimum requirement. The report makes two recommendations, and FEMA concurred with both.

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Full text

FEMA Did Not Provide
Sufficient Oversight of
Project Airbridge




                     February 7, 2023
                           OIG-23-14
                   OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security
                        Washington, DC 20528 / www.oig.dhs.gov


                                )HEUXDU\


MEMORANDUM FOR:          The Honorable Deanne Criswell
                         Administrator
                         Federal Emergency Management

FROM:                    Joseph V. Cuffari, Ph.D. JOSEPH V Digitally signed by
                         Inspector General
                                                           JOSEPH V CUFFARI
                                                           Date: 2023.02.03
                                                        CUFFARI 14:58:19 -07'00'
SUBJECT:                 FEMA Did Not Provide Sufficient Oversight of
                         Project Airbridge

For your action is our final report, FEMA Did Not Provide Sufficient Oversight of
Project Airbridge. We incorporated the formal comments provided by your
office.

The report contains two recommendations aimed at improving the overall
effectiveness of future public/private partnerships. Your office concurred with
both recommendations. Based on information provided in your response to
the draft report, we consider recommendations 1 and 2 open and resolved.
Once your office has fully implemented the recommendations, please submit a
formal closeout letter to us within 30 days so that we may close the
recommendations. The memorandum should be accompanied by evidence of
completion of agreed-upon corrective actions and of the disposition of any
monetary amounts.

Please send your response or closure request to
OIGAuditsFollowup@oig.dhs.gov.

Consistent with our responsibility under the Inspector General Act of 1978, as
amended, we will provide copies of our report to congressional committees
with oversight and appropriation responsibility over the Department of
Homeland Security. We will post the report on our website for public
dissemination.

If you have any questions please call me at (202) 981-6000, or your staff may
call Bruce Miller, Deputy Inspector General for Audits.




www.oig.dhs.gov
                                      DHS OIG HIGHLIGHTS
                       FEMA Did Not Provide Sufficient Oversight
                                 of Project Airbridge


 February 7, 2023                          What We Found
                                           The Federal Emergency Management Agency (FEMA) did
 Why We Did                                not provide sufficient oversight of Project Airbridge, a
 This Audit                                COVID-19 initiative. Under unprecedented pressure to
                                           mitigate disruptions in global medical supply chains,
                                           FEMA established Project Airbridge. The project was
 In response to COVID-19,                  intended as a temporary measure to address perceived
 FEMA initiated Project                    shortfalls in distributors’ personal protective equipment
 Airbridge to mitigate
                                           (PPE) inventories of gloves, gowns, and masks. However,
 shortfalls in medical supply
                                           the project actually supplemented the distributors’ already
 distributors’ PPE and                     large domestic inventories. We attribute Project Airbridge’s
 facilitate the delivery of                unnecessary air shipment of PPE to the pressure FEMA
 critical PPE to locations
                                           faced to get medical supplies distributed quickly. With a
 where it was most needed.
                                           limited understanding of commercial supply and demand,
 The objective of this audit               FEMA did not sufficiently assess whether medical supply
 was to determine the extent               distributors needed Project Airbridge to stabilize their
 to which FEMA provided                    supply chains.
 oversight of Project
 Airbridge and ensured its
                              In addition, FEMA did not ensure the distributors delivered
 commercial partners          PPE to healthcare facilities as agreed. We could only
 distributed medical          confirm distributors delivered 35 percent of Airbridge PPE
 supplies to prioritized
                              to designated healthcare facilities in prioritized locations
 healthcare facilities in
                              instead of the 50 percent minimum required by FEMA.
 designated locations.        Because FEMA did not properly define the project’s
                              requirements, it did not have sufficient controls to hold the
 What We                      distributors accountable. As a result, FEMA paid to
                              transport PPE that may not have been necessary to meet
 Recommend                    distributors’ needs and was not always delivered to
                              locations most in need. Accordingly, the project’s $238
 We made two                  million may have been better spent on other COVID-19
 recommendations to improve initiatives. FEMA should leverage lessons learned from
 FEMA’s management and        this audit when contemplating and undertaking future
 oversight of future          private-government partnerships.
 public/private partnerships.

 For Further Information:
                                           FEMA Response
 Contact our Office of Public Affairs at
 (202) 981-6000, or email us at
 DHS-OIG.OfficePublicAffairs@oig.dhs.gov   FEMA concurred with our two recommendations. We
                                           consider both open and resolved.


www.oig.dhs.gov                                                                               OIG-23-14
                     OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security

                                       Background

The U.S. Department of Health & Human Services (HHS) determined that a
nationwide public health emergency existed starting on January 27, 2020,
due to COVID-19. In March 2020, the World Health Organization
characterized the COVID-19 outbreak as a pandemic1 and President Trump
declared a nationwide emergency.2 The Federal Emergency Management
Agency (FEMA) initially supported HHS in combating the COVID-19 pandemic,
but soon transitioned to leading the Federal response.

In 2020, the FEMA Administrator and HHS Assistant Secretary for
Preparedness and Response co-led the Unified Coordination Group3 and
assembled task forces to address top priorities for the pandemic response,
including supply chain disruption. For example, FEMA and HHS created a
Supply Chain Stabilization Task Force (Task Force), one of eight COVID-19-
focused task forces under the National Response Coordination Center. The
Task Force used a whole-of-America approach to increase the flow of medical
supplies and equipment to healthcare workers on the front line. It dealt with
personal protective equipment (PPE) supply shortages at different levels, such
as:
      (1) supply shortages for healthcare workers on the front line, and
      (2) supply shortages in medical distributors’ PPE supply base.

The National Resource Prioritization Cell, led by the Task Force, developed
data-driven recommendations to the Unified Coordination Group to ensure
distribution of the right resources to the right places at the right time. The
cell issued bulletins that identified priority places of care and specific
geographic locations that needed PPE the most.

In March 2020, FEMA initiated Project Airbridge to serve as a temporary
solution designed to address perceived shortages in medical supply
distributors’ inventories of PPE. FEMA covered the flight costs of shipping PPE
from overseas factories in several countries (such as Malaysia, China, and
Vietnam) to U.S. medical supply distributors. By using air freight instead of
sea shipments, Project Airbridge reduced shipment times from around 36 days
to about 4 days. In exchange for expedited flights at FEMA’s expense, the
medical supply distributors agreed to distribute at least 50 percent of the
transported PPE to distributors’ customers at a reasonable price in specific
areas prioritized by FEMA and HHS. The distributors would disseminate the

1 WHO Director-General's opening remarks at the media briefing on COVID-19, March 11, 2020.
2 Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease

(COVID-19) Outbreak, March 13, 2020.
3 On March 20, 2022, FEMA and HHS established a Unified Coordination Group to make

critical prioritization decisions in response to COVID-19. The group provided national-level
decision points to the White House Coronavirus Task Force.
www.oig.dhs.gov                                  2                                   OIG-23-14
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                          Department of Homeland Security

remainder of the shipments into the broader U.S. supply chain as part of their
regular course of business.

FEMA signed memorandums of agreement (MOAs) outlining the terms of its
public-private partnership with six medical supply distributors4 to transport
and distribute PPE.
                                                                 Table 1. PPE Transported into
                                                                 the United States by Project
On March 29, 2020, the first Project Airbridge flight            Airbridge
landed at New York’s John F. Kennedy International               PPE
Airport; the last flight landed on June 30, 2020, at             Type        Total Airbridge PPE
Ohio’s Rickenbacker International Airport. In total,
FEMA spent $237.6 million to transport to the                    Gloves      936.9M
United States approximately 1.1 billion PPE items,               Gowns       66.6M
primarily consisting of gloves, masks, and gowns.                Masks       122.4M
Table 1 identifies the type and amount of PPE                    Other       23.2M
transported by Project Airbridge.5
                                                                 Total       1.1B
                                                                 Source: Department of Homeland
The objective of this audit was to determine the                 Security Office of Inspector General
extent to which FEMA provided oversight of Project               analysis of FEMA Project Airbridge
Airbridge and ensured its commercial partners                    Tracker
distributed medical supplies to prioritized healthcare facilities in designated
locations.

                                   Results of Audit

Although Project Airbridge was a potential solution to address concerns about
insufficient PPE during an unprecedented pandemic, FEMA did not provide
sufficient oversight of Project Airbridge, which expended approximately $238
million to transport about 1.1 billion PPE items to the United States.
Specifically, FEMA did not assess medical supply distributors’ inventories of
PPE. This occurred because FEMA went from concept to implementation of
Project Airbridge in about 1 week, without assessing the capacity of the
distributors’ commercial supply chains. According to FEMA, although it
gathered demand signals based on PPE resource requests from states,
localities, tribes, and territories, as it does in traditional disasters, it operated
with a limited understanding of commercial supply and demand. As a result,
the project did not address shortfalls in the inventory of PPE. Rather, the
project supplemented the distributors’ already large domestic inventories of
gloves, gowns, and masks, which grew about one-third between March and
June 2020. Consequently, FEMA paid to transport PPE that may not have

4 The six distributors represented approximately 90 percent of the market share of the

domestic medical supply industry before the pandemic.
5 The PPE type “Masks” includes surgical and procedure masks but does not include N95 or

K95 respirators; the PPE type “Other” includes items such as N95 respirators, face shields,
thermometers, and other supplies transported through Airbridge in smaller amounts.
www.oig.dhs.gov                               3                                      OIG-23-14
                     OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security

been necessary to meet the distributors’ needs, meaning, the project’s $238
million may have been better spent on other COVID-19 initiatives.

In addition, FEMA did not ensure the distributors delivered PPE to healthcare
facilities as agreed. Specifically, we could only confirm distributors delivered
35 percent of the Airbridge PPE to designated healthcare facilities in prioritized
locations instead of the 50 percent minimum requirement. This occurred
because MOAs with the distributors, which were quickly signed and
implemented, contained ambiguous terms that made enforcing them
challenging. Because FEMA did not properly define the project’s requirements,
it did not have the controls necessary to hold the distributors accountable. As
a result, PPE was not always delivered to locations most in need. FEMA should
leverage lessons learned from this audit when contemplating future private-
government partnerships.

Project Airbridge was Not Needed to Stabilize Domestic Supply Chains

In March 2020, one of FEMA’s goals was to ensure it met the medical supply
and equipment needs of healthcare providers quickly through various
initiatives, including Project Airbridge. FEMA was charged with assessing the
medical supply chain to identify gaps and shortfalls. In response to anticipated
supply chain disruptions and an unprecedented surge in demand for critical
PPE in healthcare facilities, Project Airbridge was designed to mitigate medical
supply distributors’ immediate perceived PPE shortages in domestic medical
supply chains. In other words, the project was meant to temporarily stabilize
domestic medical supply chains so distributors could satisfy anticipated surges
in PPE demands.

Although it was not FEMA’s intent, Project Airbridge added to large quantities
of existing PPE items in distributors’ supply chains and inventories in the
United States. As set forth in Table 1, from March through June 2020, FEMA
transported into the United States approximately 1.1 billion PPE items for the
medical distributors. During that same period, PPE Monthly Distributor Volume
reports6 showed distributors already had 7.5 billion gloves, and imported about
25 billion of the same PPE items from their existing supply chains. This
occurred because, despite the pandemic and supply chain issues, the medical
distributors continued to use their own commercial supply chains to import
PPE throughout the duration of Project Airbridge. For perspective, Project
Airbridge PPE shipments represented just under 5 percent of total PPE
shipments received by distributors from March through June 2020.
Moreover, the distributors already had sufficient domestic inventories to
distribute PPE to their customers without Project Airbridge. For example,

6 Prepared by the Supply Chain Stabilization Task Force, PPE Monthly Distributor Volume

reports contained monthly PPE data on distributors’ domestic inventories, shipments from
manufacturers, and distributions to customers.
www.oig.dhs.gov                              4                                     OIG-23-14
                     OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security

FEMA transported approximately 937 million gloves during the project.
Concurrently, the six distributors imported 23 billion gloves through existing
channels and maintained an average PPE ending inventory of 8.5 billion across
all distributors. Figure 1 illustrates glove inventories compared to distributions
and Airbridge shipments.

Figure 1. Glove Inventory Capacity vs. Distributed Inventory (in billions),
March – June 2020




Source: DHS OIG analysis of Supply Chain Stabilization Task Force PPE Monthly Distributor
Volume reports

Instead of acting as a temporary measure to address supply chain shortages,
Project Airbridge created unnecessary increases to already large domestic
inventories of gloves, gowns, and masks. During the project, the PPE inventory
increased by about 2.6 billion items (32 percent). Although never intended to
augment growing commercial inventories, Project Airbridge contributed to 5
percent of the overall 32 percent inventory growth. The most significant growth
occurred in surgical mask inventories, which grew by about 568 million (almost
180 percent). Project Airbridge contributed to 8 percent of the mask inventory
growth. Table 2 provides information about PPE imported and present in
inventories during Project Airbridge.




www.oig.dhs.gov                             5                                    OIG-23-14
                     OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security


Table 2. PPE in the United States Brought in and Present during Project
Airbridge by the Six Distributors, March to June 2020

  PPE      Beginning       Total PPE      Ending       Average    Number        Percent
  Type     Inventory     Brought in by   Inventory    Inventory    of PPE      Growth in
             March        Distributors     June                     Items     Inventories
             2020                          2020                    Project
                                                                  Airbridge
                                                                  Brought
                                                                   to the
                                                                   United
                                                                   States
                                                                  March 29
                                                                   - June
                                                                  30, 2020
 Gloves      7.5B            23.0B           9.6B         8.5B      936.9M        27%
 Gowns      244.7M          473.7M         248.1M       186.1M       66.6M         1%
 Masks      320.9M            1.5B         889.0M       510.8M      122.4M       177%
 Total       8.1B            24.9B          10.7B         9.2B        1.1B       32%
Source: DHS OIG analysis of Supply Chain Stabilization Task Force PPE Monthly Distributor
Volume reports

FEMA Did Not Assess Medical Supply Distributors’ Supply Chains

We attribute Project Airbridge’s unnecessary air shipment of PPE items to the
pressure FEMA faced to get medical supplies distributed quickly. As a result,
FEMA did not sufficiently assess whether medical supply distributors needed
Project Airbridge to stabilize their supply chains. FEMA initiated Project
Airbridge in about a week without first considering the distributors’ existing
domestic supply chains, including inventory levels, scheduled sea shipments,
and actual customer deliveries. According to FEMA, despite early engagement
with private sector partners, neither FEMA nor the partners were able to assess
PPE capacity given the uncertainty about supply chains and the urgency of
rising demand. FEMA further explained that, given its reliance on Resource
Request Forms from states, localities, tribes, and territories to determine
demand, it operated with the belief that demand would rapidly deplete
available supply because domestic PPE consumption was far greater than
usual. Although FEMA eventually obtained some private sector supply data, it
still did not have a comprehensive overview of the distributors’ inventories
during the project. According to FEMA, without a comprehensive
understanding of the evolving national supply and demand, it could not fully
evaluate the cost and operational effectiveness of the project.

FEMA did not conduct a cost-benefit analysis until mid-April 2020. FEMA
justified continuation of the project based on high PPE demand signals and
reduced shipping times from an average of 36 to 4 days, emphasizing air
www.oig.dhs.gov                             6                                    OIG-23-14
                   OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security

freight delivery speed over larger sea shipment volumes. Although air freight is
quicker, one air shipment can only transport about 1/1,100 of the volume of
one container vessel and at a much higher cost. Thus, high demand signals
and reduced shipping times are not sufficient justification given that, during
Project Airbridge, the distributors continued to import high volumes of PPE at
their own expense to increase existing large inventories.

FEMA also did not establish procedures for determining when to sunset Project
Airbridge and did not define guidelines for assessing the distributors’ ability to
sustain supplies delivered by sea. Instead, FEMA based decisions on ad hoc
discussions with distributors about PPE needs. FEMA expressed concerns that
switching to sea shipments too early in the project might result in a lack of PPE
importation into the United States for an extended period. To mitigate this
risk, the Unified Coordination Group, at FEMA’s recommendation, decided to
gradually transition from air to sea shipments in May 2020, with only gowns
flown through Project Airbridge during June 2020. By that time, 82 percent of
the Project Airbridge shipped gloves, masks, and gowns had already arrived in
the United States and been delivered to the distributors. Because FEMA did
not assess supply needs at the outset of Project Airbridge, FEMA paid to
transport PPE that may not have been necessary to meet immediate distributor
needs. Accordingly, the project’s $238 million may have been better spent on
other COVID-19 initiatives.

FEMA Did Not Ensure Medical Supply Distributors Delivered PPE to
Healthcare Facilities in Designated Locations
According to the MOAs signed in March 2020, in exchange for transportation at
FEMA’s expense, medical supply distributors agreed to distribute at least 50
percent of the transported PPE to FEMA and HHS-designated locations.
Designated locations included hospitals, nursing homes, long-term care
facilities, and state and local governments in geographic locations with the
greatest needs. Distributors also agreed to sell the PPE to existing customers
at a reasonable price. On April 8, 2020, at the direction of the FEMA
Administrator, the National Resource Prioritization Cell issued Resource
Prioritization Bulletin #2, which identified recommended priority sites of care,
such as hospitals and nursing homes, as well as priority county locations. In
accordance with MOA requirements, FEMA provided the distributors with
spreadsheets that identified, by county, priority locations with the greatest need
for PPE. FEMA updated the spreadsheets weekly or biweekly.
We were only able to confirm that the six medical supply distributors delivered
35 percent (395 million PPE items) of total Project Airbridge shipments to
healthcare facilities in designated locations instead of a minimum of 50 percent
required by the Project Airbridge MOAs. Although the distributors delivered 35
percent of Project Airbridge PPE to healthcare facilities in prioritized locations,
we could not determine the extent to which they prioritized hospitals and
www.oig.dhs.gov                         7                                OIG-23-14
                   OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security

nursing homes over other medical customers. The MOAs clearly identified
targeted recipients, but they did not limit distribution to them. This ambiguity
allowed distributors to continue with their normal distribution processes to
their customers, including medical professionals who provide non-critical,
elective medical services, such as chiropractors, plastic surgeons, dentists, and
ophthalmologists — many of whose practices were closed during the project’s
timeframe — and retail, wholesale, and home improvement stores.
The distributors made non-compliant distributions, meaning PPE was not
delivered to healthcare facilities in the designated locations for the minimum
50 percent requirement or the final delivery location of PPE could not be
determined from FEMA’s records. Specifically, although distributors delivered
696 million gloves, gowns, masks, and N95 respirators, 301 million of these
items were non-compliant distributions. Almost 36 percent (107 million) of
non-compliant distributions went to customers in non-priority locations.
About 61 percent (184 million) of non-compliant distributions went to other
distributors instead of healthcare facilities in designated locations. Five of the
six distributors had sales to other distributors, ranging from 2 percent to 65
percent of their total distributions. Although the MOAs did not strictly prohibit
distributor-to-distributor sales, distributors are not final consumers.
Therefore, for distributor-to-distributor sales, we could not determine the
geographic location of final recipients for compliance reporting purposes,
making these distributions non-compliant. The final 4 percent of non-
compliant distributions went to non-medical customers, such as hair salons,
veterinarians, or other retail establishments. Figure 2 sets forth information
regarding compliant and non-compliant distributions. Appendix B summarizes
the distribution locations of the 696 million Project Airbridge PPE.




www.oig.dhs.gov                        8                                 OIG-23-14
                      OFFICE OF INSPECTOR GENERAL
                           Department of Homeland Security

Figure 2. Airbridge PPE Distribution Compliance with MOA Requirements7




Source: DHS OIG analysis of medical distributors’ Airbridge Compliance Reports

The distributors’ compliance rates varied significantly. Individual compliance
rates for the six distributors ranged from 6 percent to 58 percent, with only one
distributor exceeding the minimum 50 percent requirement. One distributor
delivered about 19 million PPE items to its priority customers out of 322
million PPE items shipped to it through Project Airbridge. Another exceeded its
overall required distribution to priority locations by more than 3 million PPE
items, but it distributed just 13 percent of the 1.2 million N95 respirators it
received. Table 3 shows the six distributors’ compliance with MOA
requirements.




7 Airbridge Compliance Reports did not include all Project Airbridge distributions, only what

was distributed in relationship to the minimum 50 percent compliance requirement of total
shipments. The PPE amount labeled as “Non Subject to MOA Compliance” in Figure 2 does not
represent distributions but instead the portion of Project Airbridge PPE that distributors could
sell through their regular distribution networks into the broader U.S. supply chain.
www.oig.dhs.gov                                9                                       OIG-23-14
                      OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security

Table 3. Airbridge PPE Distribution Compliance with MOA Requirements

                                                                                       Compliant
                                                                                      Distribution
   Medical          Project                     Non-        Non-                          as a
                               Distributor-                            Compliant
   Supply          Airbridge                   Priority    Medical                    Percentage
                                   to-                                Distributions
 Distributors     Shipments                   Locations   Customers                    of Project
                               Distributor
                                                                                       Airbridge
                                                                                      Shipments
 Distributor 1        42M              5M       472K            2M            24M            58%
 Distributor 2        11M              2K        76K           97K             5M            43%
 Distributor 3        67M              1M         5M          132K            25M            37%
 Distributor 4       430M              6M        45M          839K           200M            46%
 Distributor 5       250M            21M        583K            3M           122M            49%
 Distributor 6       322M           150M         56M            5M            19M             6%
 Grand Total          1.1B          184M       107M            10M           395M            35%
 PPE Items in: Billions (B); Millions (M); Thousands (K)
Source: DHS OIG analysis of medical distributors’ Airbridge Compliance Reports


FEMA Did Not Implement Controls to Enforce Compliance with MOAs
FEMA did not establish a process to enforce compliance with the MOAs before
coordinating flights to deliver PPE. Specifically, FEMA began coordinating
Project Airbridge flights prior to finalizing the MOAs, with most signed the day
of the first flight. FEMA did not implement sufficient controls because it
advanced from concept to implementation of MOAs in less than 1 week.
According to one FEMA official, FEMA established processes throughout the
project’s life. The FEMA official described it as building the plane while it was
flying. Because FEMA did not properly define the project’s requirements, such
as priority facilities and reporting requirements, in the MOAs, it did not have
the controls necessary to hold the distributors accountable, which made
assessing and enforcing Project Airbridge requirements even more challenging.

FEMA also experienced problems with distributors’ reporting because of issues
with timeliness, completion, and accuracy. The reports for the six distributors
were missing facility types, delivery dates, and pricing information. Five of the
six distributors delayed reporting for various reasons described by FEMA
including reluctance to share data, internal reporting difficulties, and an
inability to determine where they delivered PPE. Due to the omission of basic
program metrics, FEMA could not determine if the project helped the
distributors accelerate PPE distribution to prioritized healthcare facilities at
reasonable prices.




www.oig.dhs.gov                               10                                 OIG-23-14
                   OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security

                                  Conclusion

COVID-19 became the first national pandemic response led by FEMA since its
inception. After the President declared a nationwide emergency on March 13,
2020, FEMA needed to develop novel approaches to address potential PPE
supply shortages at healthcare facilities throughout the United States.
We understand the need to mitigate supply chain disruptions. However, FEMA
still had a responsibility to spend funds on verified needs. Although airlift
initiatives move items quickly, they are not justified when inventory growth
exceeds distribution rates. During Project Airbridge, the distributors’ supply
chains were functioning, they had significant PPE inventories, and they
imported more PPE than Project Airbridge. FEMA should have implemented
better controls to assess and adjust operations based on distributors’
inventories and supply lines, but it did not. Additionally, Project Airbridge
appears to have had little impact in reducing critical PPE shortages for
healthcare workers who needed supplies most. Only one of the six distributors
satisfied the MOA minimum 50 percent compliance requirement of total
shipments. Thus, the project’s $238 million may have been better spent on
other COVID-19 initiatives. FEMA should leverage lessons learned from this
audit when contemplating and undertaking future private-government
partnerships.
                             Recommendations

Recommendation 1: We recommend the FEMA Administrator develop and
implement assessment criteria for public/private partnerships with
distributors in response to life-threatening circumstances or events. At a
minimum, assessment criteria should include:
   x a justification memorandum explaining why each partnership is
       necessary, including a clear definition of the problem and why the
       partnership is an effective solution with consideration of needs, costs,
       and alternatives;
   x an assessment of alternatives;
   x a cost/benefit analysis; and
   x information regarding the partners’ existing supply chain, including
       existing inventories, supply replenishment shipments and customer
       orders and deliveries to support public/private partnerships.
Recommendation 2: We recommend the FEMA Administrator develop and
implement policies and procedures for the use of memorandums of agreement
when establishing public/private partnerships in response to life-threatening
circumstances or events. The policies and procedures should ensure FEMA
can enforce and assess compliance with the memorandums of agreement
requirements and address, at a minimum:
    x the review and approval process;
www.oig.dhs.gov                        11                                OIG-23-14
                  OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security

   x   statutory authorities;
   x   roles and responsibilities;
   x   evaluation and reporting requirements;
   x   targeted end-use, users, and locations; and
   x   industry information necessary to monitor compliance.


              Management Comments and OIG Analysis

The Acting Associate Administrator Office of Policy and Program Analysis
provided written comments on a draft of this report, which are included in their
entirety in Appendix A. FEMA concurred with our two recommendations. Prior
to drafting our report, FEMA provided technical comments in response to
potential findings and recommendations. We made revisions where
appropriate to the findings. Following the issuance of our draft report, FEMA
did not provide additional technical comments. We consider both
recommendations open and resolved.

In its response to our draft report, FEMA stated the OIG concluded there was
no shortage of PPE in the early days of COVID-19, and therefore, FEMA did not
need to accelerate PPE delivery. FEMA disagreed with that conclusion and
cited reports of PPE supply chain disruptions, rising PPE demand signals, and
shortages of PPE among hospital staff. However, our findings do not question
whether PPE supply chain disruptions existed or whether PPE shortages
existed among healthcare workers, but rather whether Project Airbridge was an
effective and efficient solution as implemented. We found that Project Airbridge
supplemented large and growing PPE inventories of participating medical
supply distributors, and FEMA did not ensure those distributors delivered PPE
to healthcare facilities as agreed. Therefore, Project Airbridge appeared to have
had little impact in reducing critical PPE shortages for healthcare workers who
needed supplies most.

FEMA’s Response to Recommendation 1: FEMA officials concurred and will
develop assessment criteria that apply when a public/private partnership is
necessary to effectuate the delivery of emergency protective measure assistance
under the Stafford Act. FEMA’s estimated completion date is December 31,
2024.

OIG Analysis: FEMA’s proposed actions are responsive to this
recommendation, which we consider open and resolved. It will remain open
until we receive evidence of FEMA’s implementation of public/private
partnership assessment criteria.

FEMA’s Response to Recommendation 2: FEMA officials concurred and will
develop policies and procedures to establish memoranda of agreement or other
www.oig.dhs.gov                       12                                OIG-23-14
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                       Department of Homeland Security

appropriate agreements that apply when a public/private partnership is
necessary to effectuate emergency protective measures assistance under the
Stafford Act. FEMA’s estimated completion date is December 31, 2024.

OIG Analysis: FEMA’s proposed actions are responsive to this
recommendation, which we consider open and resolved. It will remain open
until we receive evidence of FEMA’s implementation of the applicable policies
and procedures.

                  Objective, Scope, and Methodology

The Department of Homeland Security Office of Inspector General was
established by the Homeland Security Act of 2002 (Public Law 107−296) by
amendment to the Inspector General Act of 1978.

Our audit objective was to determine the extent to which FEMA provided
oversight of Project Airbridge and ensured its commercial partners distributed
medical supplies to prioritized healthcare facilities in designated locations. Our
audit scope covered all Project Airbridge flights from March 2020 through June
2020 and distributions made by medical distributors from March 2020 through
August 2020.

We assessed internal controls related to FEMA’s oversight of Project Airbridge.
Because our review was limited to addressing our audit objective it may not
have disclosed all internal control deficiencies that may have existed at the
time of the audit. As discussed in the body of this report, we identified
weaknesses related to FEMA’s establishment and administration of the project.

To gain an understanding of Project Airbridge, we met with Supply Chain
Stabilization Task Force leadership, counsel, and staff and with the FEMA
Logistics Management Directorate to discuss the intent of the project and the
process used to develop its requirements. We reviewed meeting minutes,
planning documents, congressional testimony, reports, and MOAs between
FEMA and Project Airbridge distributors to understand Project Airbridge
requirements and how it was managed and overseen.

To determine the quantity and type of supplies FEMA imported through Project
Airbridge, we reviewed FEMA’s Project Airbridge Tracker. We assessed the
reliability of the tracker by validating the flight numbers, dates, distributor
names, quantity, and type of PPE on each flight through reviews of cargo
Airway bills, U.S Customs and Border Protection entry forms, distributor
inventory controls sheets, packing slips, and transportation provider shipping
reports. We also interviewed individuals responsible for maintaining the
tracker. We believe the data is sufficiently reliable for our reporting purposes.

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                       Department of Homeland Security

To determine the amount of PPE distributed by the distributors, we reconciled
FEMA’s Project Airbridge Tracker to the six medical distributors’ distribution
reports by flight date, flight number, and PPE type. Once reconciled, we
compared the distributor reports with FEMA’s prioritization bulletins and
identified shipments sent to prioritized areas using a combination of state and
county codes and/or ZIP Codes. We determined the compliance rate by
comparing the amount of PPE distributed to FEMA designated locations to the
total amount of Project Airbridge shipments on an individual flight and overall
distributor level. We compared our results to FEMA’s compliance reports and
noted any major discrepancies. Although we did not directly test the accuracy
of the distribution reports to supporting documentation, we believe they are
sufficiently reliable for reporting purposes because we were able to reconcile
them to the Project Airbridge Tracker.

To determine the type of customer that received Project Airbridge supplies, we
reviewed and sorted distribution reports by the quantity of PPE distributed and
selected the top 50 customers that received the most PPE from each of the
distributors. For each of the distributor’s top 50 customers, we used
customers’ names, addresses, and open-source research to identify customer
type. We continued customer type testing for all other reported distributions,
to identify non-compliant distributions to other distributors and to non-medical
customers. We did this by searching known distributor names and non-
medical customers, such as non-medical retailers, corporations, salons, spas,
veterinary services, and other similar entities.

To determine the extent to which FEMA’s Project Airbridge shipments alleviated
disruptions in the distributor PPE supply chains, we analyzed Monthly
Distributor Volume reports prepared by the Supply Chain Control Tower.
These reports included distributor furnished data on their PPE inventory levels,
imports, and domestic distributions from March through July 2020. We were
able to partially validate Supply Chain Control Tower information. Specifically,
we determined the import amounts to be reasonable when compared to
corresponding PPE import reporting by the U.S. International Trade
Commission. Additionally, we contacted distributors and discussed the reports
to ensure information was accurate. Based on our analytical reviews, we
determined the data to be sufficiently reliable for our audit. We limited our
review to gloves, masks, and gowns supply types because they consisted of 98
percent of supplies imported through Project Airbridge.

We conducted this performance audit between July 2020 and September 2022
pursuant to the Inspector General Act of 1978, as amended, and according to
generally accepted government auditing standards. Those standards require
that we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based upon our


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                  OFFICE OF INSPECTOR GENERAL
                       Department of Homeland Security

audit objectives. We believe that the evidence obtained provides a reasonable
basis for our findings and conclusions based upon our audit objectives.

The Office of Audits major contributors to this report are Ruth Blevins, Audit
Director; Armando Lastra, Audit Manager; Matthew Noll, Auditor-in-Charge;
Henry Kim, Auditor; Dennisse Lecaro, Program Analyst; Rolando Chavez,
Independent Reference Reviewer.




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                    Department of Homeland Security

Appendix A
FEMA Comments to the Draft Report




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                    Department of Homeland Security




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                     OFFICE OF INSPECTOR GENERAL
                          Department of Homeland Security

Appendix B
Map of Airbridge PPE Distributions




Source: DHS OIG Analysis of Medical Distributors’ Airbridge Compliance Reports




www.oig.dhs.gov                             21                                   OIG-23-14
                  OFFICE OF INSPECTOR GENERAL
                      Department of Homeland Security

Appendix C
Report Distribution

Department of Homeland Security

Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, Government Accountability Office/OIG Liaison Office
Under Secretary, Office of Strategy, Policy, and Plans
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
FEMA, Audit Liaison

Office of Management and Budget

Chief, Homeland Security Branch
DHS OIG Budget Examiner

Congress

Congressional Oversight and Appropriations Committees




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                   Additional Information and Copies

To view this and any of our other reports, please visit our website at:
www.oig.dhs.gov.

For further information or questions, please contact Office of Inspector General
Public Affairs at: DHS-OIG.OfficePublicAffairs@oig.dhs.gov.
Follow us on Twitter at: @dhsoig.




                                  OIG Hotline

To report fraud, waste, or abuse, visit our website at www.oig.dhs.gov and click
on the red "Hotline" ER[. If you cannot access our website, call our hotline at
(800)323-8603, or write to us at:

                         Department of Homeland Security
                         Office of Inspector General, Mail Stop 0305
                         Attention: Hotline
                         245 Murray Drive, SW
                         Washington, DC 20528-0305


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