Report | June 9, 2021

Audit of the Reimbursement for Department of Defense Mission Assignments for Coronavirus Disease–2019 Pandemic Response in the U.S. Northern Command Area of Responsibility (DODIG-2021-091)

Audit

Publicly Released: June 11, 2021

 

Objective

The objective of this audit was to determine whether DoD Components (tasked units) requested and received reimbursement of costs incurred for support provided to coronavirus disease–2019 (COVID‑19) pandemic response mission assignments in the U.S. Northern Command (USNORTHCOM) area of responsibility in accordance with DoD policies.

 

Background

On March 11, 2020, the World Health Organization declared the COVID‑19 outbreak a pandemic. On March 13, 2020, the President declared the COVID‑19 pandemic a national emergency and invoked the Stafford Act. The DoD, in support of the Federal Emergency Management Agency (FEMA), provides COVID‑19 response and relief efforts to state and local governments on a reimbursable basis under the Stafford Act.

The DoD supports COVID‑19 response and relief efforts through FEMA-issued mission assignments, which are work orders for the DoD to complete specific tasks at an estimated reimbursable cost for the work performed. DoD units tasked to support mission assignments initially fund the cost of COVID‑19 response and relief efforts through their own appropriations and then request reimbursement for costs incurred from FEMA.

DoD policy requires that tasked‑unit personnel submit requests for reimbursement of actual expenditures within 30 calendar days after the month in which the performance occurred and final reimbursement requests within 90 calendar days after the termination of the mission assignment.

We selected and reviewed a non-statistical sample of 12 mission assignments that had estimated total reimbursable costs of $470.9 million.

 

Finding

DoD tasked-unit personnel did not submit timely requests for partial or final reimbursement from FEMA for mission assignment support. As of July 31, 2020, DoD Components had reported $221.6 million, to the Office of the Deputy Comptroller (Program/Budget), Office of the Under Secretary of Defense (Comptroller)/Chief Financial Officer, in incurred reimbursable costs for 11 of the 12 COVID‑19 pandemic response mission assignments we selected for review, but had not submitted timely reimbursement requests for those costs. Specifically, DoD Components had incurred reimbursable costs of $50.7 million for seven completed mission assignments and $170.9 million for four active mission assignments.

Based on our review of the DoD reimbursable summary reports, the untimely submission of reimbursement requests for COVID‑19 pandemic response mission assignment costs was pervasive and systemic. Specifically, for all DoD COVID‑19 pandemic response mission assignments in the USNORTHCOM area of responsibility, as of July 31, 2020, DoD Components had incurred a total reimbursable cost of $1.1 billion, but had requested reimbursement for only $16.4 million (about 1.5 percent of the total cost incurred).

DoD tasked-unit personnel did not submit timely reimbursement requests because:

  • DoD Component comptroller officials provided incorrect reimbursement guidance to tasked units, and
  • DoD tasked-unit personnel lacked training and experience in capturing mission assignment costs and providing required documentation to FEMA for reimbursement of those costs.

As a result of untimely reimbursement requests, the DoD was not able to use $221.6 million as intended in the DoD appropriations. If DoD tasked-unit personnel had submitted timely and supported reimbursement requests, FEMA would have reimbursed the DoD. The DoD then could have used the $221.6 million from its support of COVID‑19 pandemic response mission assignments to support DoD operations, rather than leaving the funds obligated and unused in FEMA’s reimbursable account. Considering the DoD’s increased costs related to the COVID‑19 pandemic, it is critical that DoD tasked-unit personnel request timely reimbursement from FEMA for costs incurred in support of COVID‑19 pandemic response mission assignments to restore the units’ budgeted funds.

Additionally, FEMA officials stated that because of the DoD’s untimely requests for reimbursement, they could not deobligate and redirect unused funds to support other disasters. Furthermore, FEMA officials stated that because of the untimely requests for reimbursement, they could not accurately report disaster relief funding to Congress or bill states for their shared portion of the mission assignment costs.

 

Recommendations

We recommend that the Deputy Comptroller (Program/Budget), Office of the Under Secretary of Defense (Comptroller)/Chief Financial Officer, DoD, in coordination with DoD Component comptrollers, initiate a review of all COVID‑19 pandemic response mission assignments to ensure reimbursement requests for costs incurred are submitted in accordance with DoD policy.

We also recommend that DoD Component comptrollers immediately require tasked-unit personnel review mission assignment costs incurred as of July 31, 2020, for completeness and accuracy, and submit reimbursement requests for those costs to FEMA in accordance with DoD policy.

Finally, we recommend that DoD Component comptrollers develop and provide to tasked units Component-specific desk manuals for mission assignments that include, at a minimum, step-by-step procedures for initial set-up, real-time cost input, cost tracking, cost reporting, and submitting partial and final billing to ensure compliance with DoD policy. DoD Component comptrollers should then provide training to tasked-unit personnel on how to navigate Component-specific desk manuals and apply the procedures appropriately.

 

Management Comments and Our Response

The Director for Operations, Program/Budget, Office of the Under Secretary of Defense (Comptroller), responding for the Deputy Comptroller, agreed with the recommendation. However, the Director did not state that Office of the Under Secretary of Defense (Comptroller) officials would coordinate with DoD Component comptrollers and initiate a review of all COVID‑19 pandemic response mission assignments to ensure timely reimbursement requests. Therefore, this recommendation is unresolved. We request that the Deputy Comptroller initiate a review in coordination with DoD Component comptrollers of all COVID‑19 pandemic response mission assignments.

The Army, Air Force, and National Guard Bureau comptrollers agreed with the recommendation to immediately require tasked-unit personnel to review mission assignment costs incurred as of July 31, 2020, for completeness and accuracy, and submit reimbursement requests for those costs to FEMA in accordance with DoD policy. These recommendations are resolved but will remain open until we verify the corrective actions have been implemented. The Navy and Marine Corps comptrollers did not respond to the recommendation; therefore, their recommendations are unresolved.

The Army, Air Force, and National Guard Bureau comptrollers agreed to develop and provide tasked units Component-specific desk manuals for mission assignments to ensure compliance with DoD policy. Therefore, these recommendations are resolved but will remain open for DoD Component comptrollers until we verify the corrective actions have been implemented. The Navy and Marine Corps comptrollers did not respond to the recommendation; therefore, their recommendations are unresolved.

In addition, the Army and National Guard Bureau comptrollers agreed to provide training to tasked‑unit personnel on how to navigate Component-specific desk manuals and apply the procedures appropriately. Therefore, these recommendation are resolved but will remain open for DoD Component comptrollers until we verify the corrective actions have been implemented. The Navy, Air Force, and Marine Corps comptrollers did not response to the recommendation; therefore, their recommendations are unresolved.

The Army and National Guard Bureau comptrollers disagreed with the potential monetary benefits that we identified of $42.4 million and $170.9 million, respectively, and stated that untimely requests for reimbursement did not affect their appropriated funds. Furthermore, the comptrollers incorrectly characterized reimbursable budget authority as funding directly allocated or apportioned to them. Reimbursable budget authority is not actual funding; rather, it provides DoD Components the authority to incur costs and then request reimbursement from FEMA to cover those incurred costs. The DoD Components used their own appropriations (personnel, operations and maintenance) to fund mission assignments.

By not submitting reimbursement requests in a timely manner, the Army and the National Guard Bureau were prevented from executing their base appropriations for their principle non-COVID‑19 mission in the most efficient and expeditious manner. Therefore, we determined that, as of July 31, 2020, the Army’s $42.4 million and the National Guard Bureau’s $170.9 million in mission assignment costs were potential monetary benefits as no reimbursements were requested or received.

Responding officials for the Navy, Air Force, and Marine Corps did not comment on the potential monetary benefits. We request comments from these officials on the potential monetary benefits.

 

This report is the result of Proj. No. D2020-D000AU-0143.000.