The Federal Emergency Management Agency in an Oct. 22 letter to the Governor's Chief of Staff Jon Junior Calvo and Guam Homeland Security and Office of Civil Defense Advisor Esther Aguigui identified 10 open compliance findings in its review of Guam’s management of federal grant funds, including recurring issues with record keeping, reporting deadlines, internal controls and oversight of subrecipients.

In the letter, FEMA Region 9 outlined findings from a recent Aug. 29 Enhanced Monitoring site visit to GHS-OCD, providing a federal compliance report card for the financial and programmatic reviews on fiscal 2026 FEMA grants. GHS-OCD in a release that followed highlighted improvements in payroll controls while acknowledging the need for continued work to meet federal requirements.

FEMA looked at 20 awards across eight grant programs including Assistance to Firefighters, Emergency Management Performance Grants, Homeland Security Grants, Nonprofit Security, Crisis Counseling, Public Assistance, Hazard Mitigation, and Building Resilient Infrastructure and Communities, (BRIC).

GHS-OCD said FEMA monitors recognized the implementation of new personnel accounting controls after reviewing timesheets, providing assurance that payroll charges were accurate and properly allocated. The agency also highlighted that the Assistance to Firefighters Grant review resulted in zero findings.

“This review highlights the real, measurable progress achieved in bringing financial controls up to federal standards,” said Gov. Lou Leon Guerrero. “FEMA's commendation of our updated payroll systems proves that our corrective actions are working."

FEMA issued 10 findings identified as areas of noncompliance listed as "Open," many of them "repeat" findings that date back to fiscal years 2018 and 2020.

Records, reporting and deadlines

For records and reporting, FEMA officials reported four areas of noncompliance:

Finding #2026-01, Non-responsive: "Guam failed to provide complete and timely access to requested documentation, as required under 2 C.F.R. § 200.337(a). The recipient did not furnish a complete set of requested records listed in FEMA’s Enhanced Monitoring Notification letters, impeding the ability of FEMA to perform the required transaction testing within the confines of the site-visit."

FEMA officials said the lack of compliance "undermines transparency and accountability" in federal fund management, and "constitutes a significant deficiency in meeting terms and conditions of the awards."

FEMA identified this issue as a repeat finding in FEMA monitoring visits, Single Audits, VAYGO reviews and the Premier Group Audit.

"This is a repeat finding from FY2024," FEMA said.

Finding #2026-05, Monitoring and Reporting Program Performance: "The GHS/OCD has been deficient in providing timely PPRs for their Emergency Management Performance Grants, Homeland Security Grant Program, and Nonprofit Security Grant Program awards. This is a repeat finding from FY2020, FY2024, and FY2025," FEMA said.

The same issue for financial reports was seen in Finding #2026-06, which is a repeat finding from fiscal years, 2020, 2022, 2024 and 2025.

FEMA also found that Guam missed the 120-day deadline to submit final reports required by federal awards for the conclusion of the period of performance.

"Guam has failed to meet required closeout deadlines for multiple federally funded awards," FEMA said, adding, "this is a repeat finding from FY2020 and FY2025."

Internal controls and emergency planning

FEMA identified two findings related to internal controls and spending including unauthorized staff signing off on Public Assistance SF-424s.

"In accordance with the FTAs, only a Governor’s Authorized Representative (GAR) or Alternate GAR are empowered to execute all necessary documents for federal assistance, including approval or subawards and certification of claims for Public Assistance," FEMA said.

Regarding planning, FEMA official said Guam needs to update it Emergency Operations Plan, "every two years."

"GHS/OCD has not submitted evidence of an updated EOP or CEMP since its last submission in December 2016. This is a repeat finding from FY2025," FEMA said.

Three FEMA findings were tied to subrecipient oversight for Public Assistance, Hazard Mitigation Grant Program and BRIC and required risk assessments.

"GHS/ODC provided no supporting documentation substantiating that it completed any subrecipient risk assessments for the awards listed above. This is a repeat finding from FY2018, FY2020, FY2022, and FY2025," FEMA said.

GHS-OCD outlines corrective steps

According to FEMA, GHS-OCD has 60 days from the Oct. 22 letter to appeal the findings, complete corrective actions or submit a Corrective Action Plan.

GHS-OCD said they are working to align operations with federal standards including the deployment of a "dedicated internal team" that focuses on formatting updates for quarterly financial reporting, grant closeout paperwork, document signature protocols, and an update to the island's Emergency Operations Plan.

“We appreciate FEMA's validation of our team's hard work, particularly the praise for our upgraded internal personnel accounting systems,” Aguigui said. “Addressing long-term, legacy administrative processes takes structured, sustained effort.”

GHS-OCD said its on track to submit 2025 fourth-quarter performance and financial reports by this week’s federal deadline.