FEMA Has Made More than
$3 Billion in Improper and
Potentially Fraudulent
Payments for Home Repair
Assistance since 2003
April 6, 2020
OIG-20-23
DHS OIG HIGHLIGHTS
FEMA Has Made More than $3 Billion in Improper
and Potentially Fraudulent Payments for
Home Repair Assistance since 2003
April 6, 2020
Why We Did
This
Audit
FEMA provides Federal
funds through its IHP for
home repairs to applicants
who claim to be uninsured
or are underinsured. From
2003 through 2018, FEMA
paid $7.4 billion to
individuals for home repair
assistance. We conducted
this audit to determine to
what extent FEMA’s IHP for
home repairs has controls
to verify applicants’
insurance coverage.
What We
Recommend
We made two
recommendations to FEMA
to improve its IHP home
repair documentation,
verification, and risk
management processes.
For Further Information:
Contact our Office of Public Affairs at
(202) 981-6000, or email us at
DHS-OIG.OfficePublicAffairs@oig.dhs.gov
What We Found
The Federal Emergency Management Agency’s (FEMA)
Individuals and Households Program (IHP) has a robust
process for collecting and verifying information provided
by underinsured disaster applicants. However, FEMA
does not collect sufficient supporting documentation or
verify that applicants claiming to have no insurance are
eligible for home repair assistance. Rather, according
to FEMA, it relies on applicant self-certifications
because no comprehensive repository of homeowner’s
insurance data exists and any additional verification
processes would delay home repair payments. As a
result, FEMA made, and we are questioning, more than
$3 billion in improper and potentially fraudulent
payments to individuals since 2003.
Additionally, FEMA did not properly assess and report
improper payment risks within IHP because it disregarded
significant internal control deficiencies and prior audit
findings when it evaluated program risks. Therefore, IHP
applicants who claimed no homeowner’s insurance received
less oversight even though they posed the greatest risk for
improper and fraudulent payments.
Without implementing changes to its home repair
assistance processes, FEMA cannot ensure it is being a
prudent steward of Federal resources and adequately
assessing its risks of improper payments and fraud.
FEMA Response
FEMA disagreed with our conclusions that it made
more than $3 billion in improper and potentially
fraudulent payments since 2003. FEMA also did not
concur with the two recommendations in this report.
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OFFICE OF INSPECTOR GENERAL
Department of Homeland Security
Background
The Federal Emergency Management Agency (FEMA) plays a critical role in
response and recovery from Presidentially-declared disasters, whether natural
or manmade. Through its Individuals and Households Program (IHP), FEMA
provides housing assistance to eligible individuals and households affected by
disasters that have uninsured or underinsured expenses and serious needs.
The amount of IHP housing assistance available to each applicant is annually
adjusted based on the Consumer Price Index. In 2017, each IHP applicant was
eligible to receive as much as $33,300.
Home Repair Housing Assistance
FEMA’s housing assistance is
Figure 1: IHP Insurance Requirements
intended to meet survivors’ basic
needs and supplement disaster
recovery efforts. One of the main
forms of housing assistance is home
repair assistance, which provides
funding to repair an applicant’s
residence to a safe and sanitary living
or functional condition. Home repair
funding can only be used to repair
disaster-caused damage not covered
by insurance. Figure 1 shows FEMA’s
IHP insurance requirements.
Home Repair Application Process
Disaster survivors may apply for IHP home repair assistance by phone, online,
or in person. Applicants provide FEMA with a variety of information, including
name, social security number, address of the damaged property, insurance
information, and a description of losses incurred. When applicants complete
their disaster applications, they self-certify whether they have any form of
home insurance. Those with insurance are required to file a claim with their
insurance provider and submit documentation identifying any insurance
settlements or benefits received or to be received as a result of disaster
damage. Once an application is submitted, FEMA conducts a series of
automated and manual checks to validate identity, ownership, and occupancy
to ensure applicant eligibility. The information provided by IHP applicants is
processed and maintained in FEMA’s National Emergency Management
Information System (NEMIS).
Source: DHS Office of Inspector General (OIG),
derived from FEMA
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Home Repair Federal Funding
According to FEMA’s data from 2003 through 2018, home repair assistance is
its largest form of housing assistance in terms of payouts. From 2003 through
2018, FEMA paid approximately $16.7 billion in IHP housing assistance. Of
this amount, $7.4 billion (45 percent) went to individuals for home repair
assistance. FEMA paid more than $3 billion (41 percent) of the $7.4 billion to
applicants who self-certified having no home insurance, while the remaining
amount was paid to those who self-certified having home insurance but the
policy did not cover the damages claimed or the applicant was underinsured.
Figure 2 illustrates a breakdown of IHP home repair payments from 2003
through 2018.
Figure 2: IHP Home Repair Payments, 2003 – 2018
Source: DHS OIG analysis of FEMA IHP home repair payments
IHP Improper Payments and Risk Management Practices
Improper payments are harmful to the integrity and reputation of Federal
payment systems and to the Federal government as a whole. An improper
payment falls into three categories: (1) intentional fraud and abuse, (2)
unintentional payment errors, and (3) instances where the documentation for a
payment is so insufficient that the reviewer is unable to discern whether a
payment is proper. FEMA management conducts risk assessments to evaluate
agency operations contributing to significant improper payments. In disaster
situations, fraud risk is greater because the need to provide services quickly
can hinder the effectiveness of existing internal control processes and create
greater opportunities for fraud. Risk assessments take into consideration the
improper payment risks associated with agency program operations and
deficiencies highlighted in prior audit reports. Effective risk management
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practices within an internal control system help to reduce Federal agencies’
susceptibility to improper and fraudulent payments.
We conducted this audit to determine to what extent FEMA’s IHP for home
repairs has controls in place to verify applicants’ insurance coverage.
Results of Audit
Insufficient Documentation and Verification of IHP Home
Repair
FEMA’s IHP for home repair assistance has no assurance applicants claiming
no homeowner’s insurance are eligible for disaster assistance payments.
According to Federal requirements, when supporting documentation does not
exist to verify the accuracy of a payment to discern eligibility, the payment
must be considered an improper payment. Further, Federal law requires
FEMA to ensure property damaged or destroyed during a disaster is not
covered by the applicant’s insurance prior to making a home repair payment.
However, FEMA does not collect any documentation or verify whether
applicants claiming to have no insurance are eligible for home repair assistance
payments. Instead, according to FEMA officials, it relies on applicants’ self-
certification statements because no comprehensive repository of homeowner’s
insurance exists and any additional verification would delay home repair
payments. As a result, FEMA has made, and we are questioning, more than
$3 billion in improper and potentially fraudulent payments since 2003.
Reliance on Self-Certifications Led to Billions in Improper Payments
FEMA did not gather or maintain sufficient supporting documentation to
determine whether applicants, who claim not to have homeowner’s insurance,
were eligible to receive IHP home repair assistance payments. Although FEMA
collects documents and has a robust process for verifying information provided
by disaster applicants who have insurance and are underinsured, it does not
collect supporting documentation from applicants who report having no
homeowner’s insurance. Insured applicants are required to submit
documentation showing disaster-caused damages are not covered by their
insurance. FEMA manually reviews and validates this documentation prior to
making home repair payments. In contrast, when applicants self-certify they
do not have homeowner’s insurance, FEMA processes their applications in
NEMIS without requesting supporting documentation to validate the self-
certifications prior to making a home repair assistance payment. Figure 3
depicts FEMA’s home repair application process.
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Figure 3: FEMA’s IHP Home Repair Application Process
Source: DHS OIG’s assessment of FEMA’s IHP home repair application process
According to the Office of Management and Budget (OMB) Circular A-123,
Appendix C, when an agency’s review is unable to determine whether a
payment was proper to discern eligibility because of insufficient or lack of
documentation, this payment must be considered an improper payment.
Although not all improper payments are fraudulent, agency payments lacking
supporting documentation to verify an applicant’s eligibility are categorized as
improper.
Additionally, the Robert T. Stafford Disaster Relief and Emergency Assistance
Act, Section 312(a) (Stafford Act) requires Federal agencies that administer any
program providing financial assistance to ensure individuals suffering losses
from a major disaster or emergency have not received financial compensation
from their insurance or any other source for the same disaster-related losses.
Taken at face value, the self-certification statements submitted during the
application process are not sufficient to demonstrate applicants are qualified
for home repair assistance. Self-certifications provide no evidence regarding
whether a property owner has homeowner’s insurance for a damaged property.
Absent this documentation, FEMA is unable to discern home repair eligibility,
and potentially violates the Stafford Act by duplicating benefits covered under a
homeowner’s insurance policy.
By relying only on self-certifications for home repairs, FEMA made billions in
improper payments to applicants from 2003 through 2018. This lack of
documentation to discern eligibility resulted in more than $3 billion in
improper payments to more than a million applicants. According to FEMA
officials, its practice of accepting self-certification statements as sufficient
documentation to support home repair assistance payments to applicants
claiming no insurance has been in place since IHP’s inception in 2003. In
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addition, Federal requirements to ensure there is not duplication of assistance
have also remained the same. FEMA has not obtained documentation to
support applicant eligibility, leading to improper payments since 2003.
Documentation to support applicant eligibility is critical — especially because
41 percent of all applicants who received home repair payments self-certified
having no homeowner’s insurance between 2003 and 2018. Furthermore,
according to FEMA officials, applicants who self-certify they do not have
insurance are more likely to receive payments because their applications are
processed with no review, while those who claim to have insurance are
reviewed manually.
Not Verifying Insurance Leads to Potentially Fraudulent Payments
FEMA not verifying insurance prior to making a home repair payment
constitutes an improper payment, which may also be fraudulent. Although
Federal law requires FEMA to provide home repair assistance for losses not
covered by insurance, FEMA claims it cannot verify self-certifications of no
homeowner’s insurance prior to making payments because a reliable and
comprehensive insurance database does not exist. We conducted an analysis
of 2017 mortgage interest data to demonstrate that other means exist to collect
documentation and perform applicant verification besides using a
comprehensive database of active insurance policies.
Through our assessment of 2017’s top 13 financial institutions by mortgage
origination volume, we found that 100 percent of the lenders required their
borrowers to maintain homeowner’s insurance while having a mortgage.
1
FEMA officials responsible for processing home repair assistance applications
also stated that most applicants with mortgages should have homeowner’s
insurance. Lenders must report annual mortgage interest exceeding $600 for
each borrower’s property using Internal Revenue Service (IRS) Form 1098,
Mortgage Interest Statement. Therefore, if an IHP applicant has mortgage
interest reported on a damaged property, the applicant should be required to
maintain homeowner’s insurance.
After making this determination, we collaborated with the Treasury Inspector
General for Tax Administration (TIGTA) to verify the truthfulness of applicant
self-certification statements indicating they had no homeowner’s insurance on
damaged property.
1
According to an official from the National Association for Mortgage Brokers, each lender
establishes its own requirements for homeowner’s insurance as part of the lending process.
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TIGTA identified 4,342
2
of 201,468, or 2 percent, of the IHP applicants who
claimed to have no homeowner’s insurance had mortgage interest reported on
their damaged properties during 2017. Because FEMA did not verify the
accuracy of self-certified information, these applicants received more than $23
million in home repair payments that were potentially fraudulent. Additionally,
103 of the 4,342 applicants in 2017 received payments greater than $25,000,
totaling approximately $3 million, which were potentially high dollar
overpayments. According to the version of OMB Circular A-123, Appendix C in
effect in 2017, payments exceeding $25,000 were considered high dollar
overpayments.
According to FEMA officials, they were willing to accept this fraud risk to
provide home repair funds more timely to survivors. TIGTA officials noted
these results were conservative. Therefore, this data likely underrepresented
the extent of potentially fraudulent claims for home repairs. Appendix B
contains a summary of TIGTA’s comparative analysis of individuals who
requested home repair assistance against tax records.
Although our data match resulted in identifying $23 million in potentially
fraudulent payments, the entire population of $876 million is also subject to
intentional fraud and abuse due to the reliance on self-certifications without
verification. Therefore, the more than $3 billion improper IHP home repair
payments made to individuals from 2003 through 2018 is also subject to
potential fraud. Nonetheless, FEMA officials continue to assert they have no
comprehensive mechanism to validate applicants’ lack of insurance because
this data is not nationally available from the various real and personal property
insurers. FEMA officials also assert that implementing controls would hinder
the efficiency of providing disaster funds to survivors quickly. Consequently,
FEMA did not ensure only eligible individuals received assistance.
In continuing to not collect documentation or verify whether applicants
claiming to have no insurance are eligible for home repair assistance, FEMA
remains highly vulnerable to making improper and potentially fraudulent
payments within its IHP home repair program. Regarding the efficiency of
providing assistance quickly, FEMA on average already verifies 59 percent of
applicants claiming homeowner’s insurance by conducting manual reviews.
However, it cannot ensure that it is being a prudent steward of government
resources when the remaining 41 percent of applicants remains unverified.
This is concerning because from 2003 through 2018, it resulted in more than
$3 billion in improper and potentially fraudulent payments.
2
We could not identify these applicants due to privacy restrictions of Internal Revenue Code
Section 6103, which generally prohibits the disclosure of tax return information to parties
outside of the IRS. However, because of the potential fraud identified, we referred the findings
of this report to DHS OIG Office of Investigations for further review.
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Improper Payment Risks for Home Repair Assistance Not
Accurately Assessed
FEMA did not properly assess and report improper payment risks within IHP.
Specifically, it disregarded significant home repair assistance internal control
deficiencies and prior audit findings when it evaluated IHP improper payment
risks during fiscal year 2017. According to OMB Circular A-123, Appendix C,
Federal agencies must conduct improper payment risk assessments of all
programs and activities. In conducting these assessments, agencies should
consider various risk factors, such as the inherent risks of improper payments
due to the nature of agency operations and significant deficiencies from audit
reports of the agency Inspector General or the Government Accountability
Office (GAO).
In its FY 2017 improper payments reduction program comprehensive risk
assessment for IHP, FEMA indicated that frequent assessments of internal
controls are conducted through numerous internal and external audits and
that any identified deficiencies are handled promptly. However, the FY 2017
risk assessment did not include prior audit findings from 2014 and 2015
specifically related to improper payments.
3
These two audits identified internal control deficiencies that made FEMA
vulnerable to significant improper payments when providing home repair
assistance. Collectively, the two audit reports identified approximately
$252 million in home repair payments at risk of being improper because FEMA
did not have a process to document and verify whether IHP recipients had
homeowner’s insurance during Hurricane Sandy in October 2012. These
improper payment risks were not included in the risk assessment because
FEMA disregarded the known internal control deficiencies. By excluding
relevant audit findings from its risk assessment, FEMA did not accurately
report its significant improper payment risks.
Without accurately representing IHP’s risks in providing home repair
assistance, applicants claiming to have no insurance receive less oversight
even though they pose the greatest risk for improper payments. Less oversight
of IHP applicants claiming no insurance leaves FEMA highly vulnerable to
significant improper payments.
3
Hurricane Sandy – FEMA Has Improved Disaster Aid Verification but Could Act to Further Limit
Improper Assistance, GAO-15-15, December 2014; FEMA Faces Challenges in Verifying
Applicants’ Insurance Policies for the Individuals and Households Program, OIG-16-01-D,
October 2015.
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Conclusion
FEMA cannot continue to rely on applicant self-certification statements as a
means of documenting and verifying eligibility because this practice does not
comply with Federal improper payments standards. Additionally, FEMA’s
improper payment risk assessments need to ensure risks specific to the IHP for
home repair assistance are accurately assessed and considered. FEMA’s more
than $3 billion in improper and potentially fraudulent payments, along with
previous audit findings, clearly demonstrate the IHP is susceptible to
significant improper payments. FEMA must take action to improve its fiscal
accountability by reducing the potential for improper payments and fraud in
the future.
Recommendations
Recommendation 1: We recommend the Federal Emergency Management
Agency Administrator, due to the questioned costs exceeding $3 billion,
implement a process to collect documentation and verify eligibility for
applicants claiming no homeowner’s insurance prior to providing IHP home
repair assistance payouts.
Recommendation 2: We recommend the Federal Emergency Management
Agency Administrator include the IHP as susceptible to significant improper
payments subject to annual improper payments estimation and reporting.
Management Comments and OIG Analysis
FEMA did not concur with our two recommendations. FEMA strongly
disagreed with our conclusion and methodology for determining that it made
more than $3 billion in improper and potentially fraudulent payments for home
repair assistance since 2003. Specifically, FEMA believed we overstated the
amount of questionable assistance it provided for home repair assistance
because we categorically questioned payments made to applicants who self-
certified that they lacked homeowner’s insurance.
According to FEMA, no documentation existed to verify whether applicants had
homeowner’s insurance prior to approving assistance. Therefore, FEMA relied
on self-certification, offering IHP home repair assistance without the ability to
determine applicant eligibility. However, according to OMB Circular A-123,
FEMA’s reliance on self-certification did not constitute sufficient
documentation to substantiate applicant eligibility. FEMA continues to provide
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individuals as much as $35,500
4
in assistance, possibly duplicating benefits
covered under homeowner’s insurance policies and, as a result, potentially
violating the Robert T. Stafford Disaster Relief and Emergency Assistance Act.
This is highly concerning, given that 41 percent of IHP applicants claimed not
to have homeowner’s insurance from 2003 through 2018. We continue to
question the more than $3 billion as improper and potentially fraudulent
payments made to individuals since 2003.
FEMA officials also asserted that no comprehensive system existed to collect
documentation and verify the information. Our analysis of 2017 mortgage
interest data demonstrated that other means exist to collect documentation
and perform applicant verification besides using a comprehensive database of
active insurance policies. For example, our verifying whether applicants had
received IRS Form 1098 mortgage interest statements on their damaged
properties constituted a strong indicator that applicants likely had
homeowner’s insurance. Nonetheless, we did not assume all mortgage-holders
who received IHP assistance had committed fraud. Rather, we concluded that
these same individuals who self-certified — under penalty of perjury — to not
have homeowner’s insurance — may not have been truthful in doing so,
resulting in potentially fraudulent claims.
We did not recommend an infeasible or impossible approach to reducing the
risk of fraudulent claims, but instead requested that FEMA implement a
process adhering to Federal law and guidance. Until FEMA implements a more
robust documentation and verification process of self-certifying applicants
within the IHP, we will continue to question these payments as improper.
Appendix A contains FEMA’s management comments in their entirety. We also
received technical comments to the draft report and revised the report as
appropriate.
FEMA Response to Recommendation 1: Non-concur. FEMA expressed
concerns about the feasibility of confirming a lack of insurance based on
supporting documentation. According to FEMA, absent self-certification, no
standard documentation existed to prove an applicant lacks insurance.
Additionally, FEMA claimed there was not a comprehensive database it might
use to validate self-certifying applicants’ lack of homeowner’s insurance. FEMA
stated it was undertaking several efforts to identify viable and timely methods
to verify insurance coverage. According to FEMA, it has conducted extensive
research to identify ways of accessing information from private sector entities
to determine whether an applicant has homeowner’s insurance. FEMA will
continue its efforts to find feasible solutions to improve the verification process
4
For fiscal year 2020, the IHP maximum award is $35,500 for housing assistance.
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without hindering the expeditious delivery of disaster assistance. Based on
these assertions, FEMA requested the recommendation be resolved and closed.
Estimated Completion Date: Not Applicable.
OIG Analysis: The absence of a documentation and a verification process to
determine eligibility for home repair assistance results in improper payments.
We do not seek an impossible or infeasible approach, but rather recommend
FEMA adhere to Federal law by implementing such a process to validate that
applicants qualify for home repair assistance. The methodology we used
throughout our audit demonstrates one feasible process—the use of IRS Form
1098 Mortgage Interest Statements to document and verify applicant eligibility.
This recommendation will remain unresolved and open until FEMA implements
a process to collect documentation to verify assistance eligibility for applicants
claiming no homeowner’s insurance.
FEMA Response to Recommendation 2: Non-concur. FEMA neither believes
IHP is susceptible to improper payments, nor considers payments to self-
certifying applicants as overpayments. IHP underwent an Improper Payments
Elimination and Recovery Act of 2010 (IPERA) comprehensive risk assessment
in FY 2018 based on its more than 20 percent increase in disbursements from
2016 to 2017. FEMA’s assessment identified IHP as low risk. OMB M-18-20,
dated June 20, 2018, requires any program or activity that disburses $10
million or more be subject to IPERA testing. According to FEMA, only if IHP
disbursements exceeded the established threshold in 2018, would it test IHP
for improper payments in FY 2020. However, FEMA will test IHP because it
received supplemental funding in FY 2018 due to disasters resulting from
hurricanes Harvey, Irma, and Maria. FEMA will report the testing results in
DHS’ 2020 Annual Financial Report. FEMA requested this recommendation be
resolved and closed. Estimated Completion Date: Not Applicable.
OIG Analysis: Previous IHP risk assessments performed by FEMA overlooked
internal control risks and weaknesses in processes for documenting and
verifying applicant eligibility for assistance. Applicant eligibility should have
been subjected to IHP reporting, regardless of the $10 million threshold.
Further, based on OMB M-18-20, FEMA’s unjustified payments exceeding the
$10 million threshold identify IHP as susceptible to significant improper
payments. As such, this recommendation will remain unresolved and open
until FEMA reports its IHP as susceptible to significant improper payments
subject to annual improper payments estimation and reporting.
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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 to what extent FEMA’s IHP for home repairs has controls in place to
verify applicants’ insurance coverage.
To accomplish our objective, we conducted interviews with officials from the
FEMA Headquarters Recovery Directorate, the Fraud and Internal
Investigations Division, and the Recovery Programs Technology Division. We
also conducted interviews with program officials from FEMA’s Individual
Assistance Division, including the Application Processing Section, Audits
Section, Field Services Section, and Program Management Section.
We reviewed prior audits and reports related to the audit objective, including
DHS OIG audits, GAO reports, and congressional testimony. We also analyzed
applicable Federal requirements regarding management’s responsibility for
implementing internal controls and managing the risks of fraud and improper
payments in Federal agencies. Specifically, we reviewed the Robert T. Stafford
Disaster Relief and Emergency Assistance Act; OMB Circular A-123,
Management’s Responsibility for Enterprise Risk Management and Internal
Control; and OMB Circular A-123, Appendix C. We assessed FEMA’s control
structure, policies, procedures, and risk management practices applicable to
oversight of IHP home repair assistance payments.
For audit testing purposes, we focused on all Presidentially-declared disasters
in 2017 with IHP payouts to applicants who self-certified not having
homeowner’s insurance for home repairs. The resulting population was
201,468 applicants who received approximately $876 million in home repair
assistance payments for declared disasters in 2017. We assessed the
completeness of this data by comparing the number of applicants and payouts
to publicly available reports of home repairs assistance published by FEMA.
We assessed the accuracy of the data by reconciling home repair data elements
for a limited number of records with actual records in NEMIS. We determined
the data was sufficiently complete and accurate and therefore reliable for audit
testing purposes.
We selected a statistical sample from our 2017 population using a 95 percent
confidence interval, 5 percent sampling error, and 50 percent population error,
which resulted in 383 applicant records. To confirm whether FEMA disbursed
IHP home repair payments for these 383 applicants, we reviewed FEMA’s
financial system of record. Additionally, to determine these applicants’
eligibility for the home repair assistance payments, we reviewed whether
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supporting documentation existed in NEMIS. Because all 383 applicant
records lacked documentation in support of eligibility decisions in NEMIS, we
confirmed that FEMA relies on self-certifications and lacks documentation to
support eligibility decisions.
Furthermore, FEMA officials confirmed their process of not collecting
supporting documentation has been in place since DHS’ inception in 2003. In
addition, Federal requirements for ensuring duplication of assistance has also
remained the same. FEMA officials provided the number of applicants and
payments for those who received home repair assistance payments from 2003
to 2018 after self-certifying they did not have homeowner’s insurance. We did
not conduct data reliability testing. Rather, we relied on FEMA’s quantification
of the home repair assistance payments made to applicants without
homeowner’s insurance from 2003 to 2018.
To assess whether a means to collect documentation and perform applicant
verification exists besides using a comprehensive database of active insurance
policies, we analyzed the entire 2017 population of 201,468 records
representing IHP applicants who self-certified they did not have homeowner’s
insurance.
We reviewed financial industry publications from the top 13 private lending
institutions for mortgage origination volume within the United States during
2017 to determine the requirements for property owners to maintain
homeowner’s insurance while having active mortgages. The lenders used in
our analysis were Bank of America, Caliber Home Loans, Chase Bank, Fairway
Independent Mortgage, Freedom Mortgage, Guaranteed Rate, Loan Depot, PHH
Mortgage, Quicken Loans, Stearns Lending, United Wholesale Mortgage, US
Bank, and Wells Fargo Bank. Our analysis of lending institutions confirmed
an active mortgage requires a property owner to maintain homeowner’s
insurance.
We shared our 2017 IHP home repair assistance applicant data with TIGTA,
who used this data to determine whether each applicant who received a home
repair assistance payment had reportable mortgage interest on the damaged
property for which they certified having no homeowner’s insurance. This data
included the disaster number, full name, social security number, damaged
property address, and FEMA-approved payment amount. TIGTA performed
data matching of each applicant against the applicant’s IRS Form 1098
Mortgage Interest Statement for tax year 2017. TIGTA subsequently provided
us the results of its analysis, which is included in Appendix B.
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We conducted this performance audit between January 2018 and June 2019
pursuant to the Inspector General Act of 1978, as amended, and according to
generally accepted government auditing standards. Those standards require
we plan and perform the audit to obtain sufficient, appropriate evidence to
provide a reasonable basis for our findings and conclusions based upon our
audit objectives. We believe the evidence obtained provides a reasonable basis
for our findings and conclusions based upon our audit objectives.
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Appendix C
Report Distribution
Department of Homeland Security
Secretary
Deputy Secretary
Chief of Staff
Deputy Chiefs of Staff
General Counsel
Executive Secretary
Director, GAO/OIG Liaison Office
Assistant Secretary for Office of Policy
Assistant Secretary for Office of Public Affairs
Assistant Secretary for Office of Legislative Affairs
Director, GAO/OIG Audit Liaison Office
Federal Emergency Management Agency
Administrator
Chief of Staff
Chief Financial Officer
Office of Response and Recovery
Office of Policy and Program Analysis
Office of Chief Counsel
Individual Assistance Directorate
Audit Liaison, FEMA
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: [email protected].
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" tab. If you cannot access our website, call our hotline at
(800) 323-8603, fax our hotline at (202) 254-4297, or write to us at:
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Washington, DC 20528-0305
