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We recommend that the FEMA Administrator resolve questioned costs totaling an estimated $24,438,662 for expenses deemed ineligible by FEMA’s Individual Assistance Program and Policy Guide and determine the amount of any debts owed by recipients for erroneous payments.

We recommend that the FEMA Administrator resolve other questioned costs included in our report and determine the amount of any debts owed by recipients for erroneous payments. Other questioned costs requiring resolution include: a) $1,348,546 for awards issued to multiple applicants for the same decedents; b) $554,653 for awards issued for applications that exceeded the $9,000 per decedent award limit; and c) $591,805 for 93 applications for which FEMA did not adequately review eligibility criteria of the applications.

We recommend that the FEMA Administrator ensure that future iterations of the Individual Assistance Program and Policy Guide and supporting procedures (a) provide consistent guidance on eligibility of funeral expenses for all future disaster declarations; and (b) allow for reimbursement of only necessary expenses and serious needs, consistent with the law.

We recommend that the FEMA Administrator strengthen and monitor improvement of FEMA’s COVID-19 Funeral Assistance training practices with particular focus on: a) distinguishing legitimate sources of potential duplication such as decedent’s name and social security number from potential duplications that arise due to FEMA using a repurposed Individual Assistance processing system, with a data field such as damaged dwelling address; b) preventing FEMA from reimbursing expenses exceeding the maximum $9,000 per decedent; and c) deducting financial assistance received from outside sources such as pre-need funeral arrangements, burial insurance, and assistance from other voluntary or government agencies.

We recommend that the FEMA Administrator ensure that FEMA provides its COVID-19 Funeral Assistance call center contractor the guidance and training necessary to meet the quality control and production monitoring metrics as prescribed by its agreement with the contractor.