United States Government Accountability Office

Report to the Ranking Member,
Committee on Homeland Security,
House of Representatives
September 2015

AMERICAN
RED CROSS
Disaster Assistance
Would Benefit from
Oversight through
Regular Federal
Evaluation

GAO-15-565

 September 2015

AMERICAN RED CROSS
Disaster Assistance Would Benefit from Oversight
through Regular Federal Evaluation
Highlights of GAO-15-565, a report to the
Ranking Member, Committee on Homeland
Security, House of Representatives

Why GAO Did This Study

What GAO Found

The Red Cross is the nation’s largest
nonprofit organization involved in
disaster relief. The organization
provides services such as sheltering
and food assistance, and it has a
leadership role in the federal disaster
response framework. However,
questions have been raised over its
ability to respond effectively to large
disasters. GAO was asked to examine
the organization’s disaster services.

Key factors affecting the nature and extent of the American Red Cross’s (Red
Cross) disaster assistance include its standard set of services and the unique
needs of affected communities. The Red Cross is involved in three phases of
emergency assistance: immediate response, longer-term recovery, and
preparedness. For response, it has a standardized set of services and
procedures which may be adjusted based on unique local needs or to avoid
duplicating other organizations’ work, according to Red Cross officials and
documents. In recovery and preparedness, officials said decision-making has
historically not been as standardized. In recovery in particular, the organization’s
services have been significantly influenced by the amount of donations received
following particular disasters. However, the Red Cross is implementing a more
standardized approach in both of these areas.

This report addresses (1) the key
factors affecting the nature and extent
of the Red Cross’s disaster services,
(2) how it coordinates with the federal
government on disaster assistance,
and (3) what external oversight exists
of its disaster services. GAO reviewed
relevant policy documents and federal
statutes and interviewed officials from
the Red Cross and FEMA; interviewed
staff involved in a nongeneralizable
sample of three disasters from 2012 to
2014 that varied in magnitude, type,
and location; and interviewed officials
from federal agencies with a role in
Red Cross oversight, six state attorney
general offices selected to achieve
diversity in their approaches to charity
oversight, and several nonprofit
organizations.

What GAO Recommends
Congress should consider establishing
a federal mechanism for regular,
external evaluations of the Red Cross’s
performance in domestic disasters. In
its comments, the Red Cross neither
agreed nor disagreed with GAO’s
matter for congressional consideration,
but noted it is open to participating in
additional evaluation activities
convened by FEMA or other
government partners.

View GAO-15-565. For more information,
contact Andrew Sherrill at (202) 512-7215 or
sherrilla@gao.gov.

The Red Cross and the federal government coordinate in disasters largely by
sharing information. For example, the Red Cross and the Federal Emergency
Management Agency (FEMA) share information on the resources available for
the response to major disasters, and on where assistance is needed during
recovery. While coordination in response to disasters is clearly established in
written agreements, the Red Cross’s role in recovery has not been as clearly
defined up to now. FEMA and the Red Cross’s 2010 memorandum of agreement
laid out 18 tasks for which the Red Cross was responsible, but only three related
to recovery, such as helping to create community-wide recovery strategies.
FEMA regional staff told us the agreement did not reflect other tasks the Red
Cross may perform during recovery, such as providing case management. The
two organizations signed a revised agreement with additional details on
coordination during recovery that was executed on July 28, 2015.
The federal government, states, and the nonprofit sector conduct oversight of the
Red Cross that is focused on governance and financial issues, not the
organization’s performance in disasters. Among federal agencies, the Internal
Revenue Service reviews data on expenditures, revenues, and governance that
the Red Cross is required to submit annually to maintain its tax exempt status;
the Department of Defense, as required by statute, reviews the organization’s
annual financial statement; and FEMA and the State Department monitor its
services in the rare cases when they fund those services. In addition, state
attorneys general have an important role in investigating fraud and
mismanagement at nonprofits, although according to one expert, states typically
focus on newer, less established nonprofits rather than the Red Cross. Finally, a
number of nonprofit watchdogs monitor the governance and financial practices of
charitable organizations, including the Red Cross, with the aim of informing
decisions about charitable giving. Despite these various forms of oversight, no
regular, independent evaluations are conducted of the impact or effectiveness of
the Red Cross’s disaster services. While not a federal agency, the Red Cross is
an instrumentality of the United States and has a critical role under the nation’s
disaster response system. Consistent with federal internal control standards on
analyzing and managing risks associated with achieving federal objectives, the
federal government has a clear stake in ensuring that proper oversight of the Red
Cross takes place.
United States Government Accountability Office

 Contents

Letter

1
Background
Key Factors That Drive Red Cross’s Disaster Assistance Include
Its Standard Set of Services and the Needs of Affected
Communities
The Red Cross’s Coordination with the Federal Government
Focuses Primarily on Information Sharing
Federal, State, and Nonprofit Oversight of the Red Cross Focuses
on Governance and Financial Practices Rather Than Disaster
Performance
Conclusions
Matter for Congressional Consideration
Agency Comments and Our Evaluation

3
12
17
24
37
38
38

Appendix I

Emergency Support Functions (ESF) and Recovery Support Functions
(RSF) that Include the Red Cross
41

Appendix II

Comments from the American Red Cross

43

Appendix III

Comments from the Federal Emergency Management Agency

48

Appendix IV

GAO Contact and Staff Acknowledgments

50

Related GAO Products

51

Figures
Figure 1: Red Cross’s Annual Expenditures on Domestic Disaster
Services, 2010-2014
Figure 2: How the Red Cross and Federal Emergency
Management Agency Work Together under Emergency
Support Function-6 to Lead Mass Care Services in Major
Disasters

Page i

5

18

GAO-15-565 American Red Cross

 Abbreviations
CDC
DHS
DOD
ESF
FEMA
GSA
HHS
IAA
IFRC
IG
IRS
NDRF
NGO
NRF
OFDA
USAID

Centers for Disease Control and Prevention
Department of Homeland Security
Department of Defense
Emergency Support Function
Federal Emergency Management Agency
General Services Administration
Department of Health and Human Services
Interagency Agreement
International Federation of Red Cross and Red Crescent
Societies
Inspector General
Internal Revenue Service
National Disaster Recovery Framework
Nongovernmental organization
National Response Framework
Office of U.S. Foreign Disaster Assistance
U.S. Agency for International Development

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GAO-15-565 American Red Cross

 Letter
Letter

441 G St. N.W.
Washington, DC 20548

September 9, 2015
The Honorable Bennie G. Thompson
Ranking Member
Committee on Homeland Security
House of Representatives
The American Red Cross (Red Cross) plays a key role in the nation’s
system for disaster relief. One of the organization’s purposes, as
established over a century ago by its federal charter, 1 is providing relief to
victims of domestic and international disasters. In part, the Red Cross’s
role in disaster relief is to provide direct services to victims of disasters,
such as sheltering or food assistance. In fulfilling this role, the
organization relies primarily on private donations and volunteers, with
only a small amount of funds coming from the federal government. In the
12 months that ended June 30, 2014, the organization spent about $360
million on domestic disaster relief and about $130 million on international
relief and development. In addition to this direct service role, the federal
government has also assigned the Red Cross critical responsibilities for
leading and coordinating other organizations’ disaster relief work. Under
the National Preparedness System, the Red Cross and the Federal
Emergency Management Agency (FEMA) are to work closely together in
managing the overall mass care effort in the immediate aftermath of
major disasters. 2
With its long history of providing disaster relief, statutorily designated
mission, and extensive resources, the Red Cross has a prominent
position among organizations involved in disaster response. At the same
time, some of its decisions and policies with national ramifications have
faced scrutiny over the years. For example, questions have been raised
about its ability to provide services efficiently following a large disaster

1
A federal charter is a statute that establishes a corporation and typically provides for its
basic characteristics such as name, purpose, governance structure, and means of public
accountability. Federal charters have been used to create a variety of corporate entities,
including banks, government-sponsored enterprises, commercial corporations, venture
capital funds, and patriotic, fraternal, and charitable organizations.
2

While the Red Cross is assigned other duties under its charter, in this report we focus on
the organization’s domestic disaster-related services.

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GAO-15-565 American Red Cross

 and to meet the needs of certain sub-populations, such as those with
disabilities. You asked us to examine the Red Cross’s involvement in
disaster relief. In this report we address (1) what key factors affect the
nature and extent of the Red Cross’s disaster-related services; (2) how
the Red Cross coordinates with the federal government on disaster
assistance; and (3) what external oversight exists of the Red Cross’s
disaster services.
To understand Red Cross’s general decision-making process about
disaster services and coordination with the federal government and other
stakeholders, we reviewed Red Cross policy, procedure, and financial
documents and its formal agreements with FEMA and other
organizations, and interviewed Red Cross headquarters officials. We did
not assess the effectiveness or sufficiency of Red Cross policies or
procedures. We also reviewed FEMA documents and interviewed officials
from FEMA, the General Services Administration (GSA), the State
Department, and the U.S. Agency for International Development (USAID),
agencies that coordinate with Red Cross on disaster relief. To understand
Red Cross decision-making and coordination in specific disasters, we
selected three events that both the Red Cross and the federal
government were involved with: Hurricane Sandy, which affected a
number of states on the east coast (October 2012); tornadoes that
affected several counties in Oklahoma (May 2013); and floods in northern
Florida (April 2014). We selected these events to achieve diversity in type
of disaster; magnitude of disaster, based on the scale of Red Cross’s
response; and geographic location. For each event, we interviewed Red
Cross divisional staff who managed the organization’s response and
FEMA regional staff, and, when available, reviewed FEMA and other
federal documents such as post-response evaluation reports. We did not
assess the effectiveness or efficiency of the Red Cross’s response to any
domestic or international disasters or of specific efforts such as the Red
Cross’s implementation of the Move-In Assistance Program following
Hurricane Sandy. In assessing how Red Cross works with the federal
government, we considered key features of effective interagency
coordination that have been previously identified by GAO. 3

3

GAO, Managing For Results: Key Considerations for Implementing Interagency
Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27, 2012).

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GAO-15-565 American Red Cross

 To understand the federal oversight of the Red Cross’s disaster
assistance, we reviewed documents and interviewed officials from the
Internal Revenue Service (IRS), the Department of Defense (DOD),
USAID, and FEMA, and interviewed officials from the State Department.
To understand states’ oversight of the Red Cross, we interviewed charity
regulation officials from three states (Colorado, Missouri, and New York)
and obtained information by e-mail from officials in three additional states
(Hawaii, Michigan, and Pennsylvania). We selected these six states
based on expert recommendations to achieve diversity in state
approaches to charity oversight. Finally, to understand the role of the
nonprofit sector in Red Cross oversight we interviewed officials and
reviewed websites from several organizations that monitor or set
standards for charities, such as Charity Navigator and BBB Wise Giving
Alliance. We did not assess or independently corroborate the findings of
these federal, state, or nonprofit organizations, or of any media or other
reports on the Red Cross’s performance in disasters. In reviewing the
existing oversight of the Red Cross, we identified criteria for effective
evaluation of disaster services that have been developed by
organizations such as the Urban Institute. 4 In addition, we used prior
GAO work and federal internal control standards as criteria. 5
We conducted this performance audit from February 2014 to September
2015 in accordance with 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 on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.

Background

Since its founding in 1881, the Red Cross has provided relief services
after disasters ranging from house fires to hurricanes and floods. Over the
past five years, the Red Cross’s annual expenditures on domestic
disaster relief services have generally been between about $250 million

4

H. Hatry, M. Abravanel, and S. Rossman, What Happens to Victims? A Research Guide
for Disaster Response Studies. Urban Institute (Washington, D.C.: Mar. 2006).
5

GAO, Tax-Exempt Sector: Governance, Transparency, and Oversight Are Critical for
Maintaining Public Trust, GAO-05-561T (Washington, D.C.: Apr. 20, 2005) and Standards
for Internal Control in the Federal Government, AIMD-00-21.3.1 (Washington, D.C.: Nov.
1999).

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GAO-15-565 American Red Cross

 and $400 million (see fig. 1). 6 The Red Cross raises money for disaster
relief primarily from private donors—e.g., individuals, corporations, and
foundations—and responds to an average of 70,000 domestic disasters
annually. According to Red Cross officials, less than 1 percent of the
funds the organization spent for domestic disaster relief in fiscal year
2014 came from the federal government. Following especially large
disasters, the Red Cross may receive substantially increased levels of
donations. For example, the Red Cross reported that it spent over $300
million on Hurricane Sandy relief, including funds donated specifically for
this purpose and funds it opted to allocate for this purpose. The
organization that received the second largest amount of donations
following Hurricane Sandy was the Robin Hood Foundation, at $75
million. Additionally, in providing disaster assistance the Red Cross relies
largely on a volunteer workforce; Red Cross officials told us that about 90
percent of the Red Cross’s workforce in disasters is composed of
volunteers.

6

The Red Cross’s fiscal year runs from July 1 through June 30. In the fiscal year that
ended June 30, 2014, the Red Cross reported spending $364 million on domestic disaster
services, representing 11.9 percent of the organization’s total spending of $3.062 billion.
American Red Cross, Annual Report 2014 (Washington, D.C.: 2014).

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GAO-15-565 American Red Cross

 Figure 1: Red Cross’s Annual Expenditures on Domestic Disaster Services, 20102014

In the immediate response to disasters, the Red Cross provides services
such as sheltering, food assistance, and bulk distribution of relief supplies
to victims. During the recovery phase, which follows response and
includes actions to help individuals and communities return to normal, the
Red Cross may assist communities with recovery planning and provide
direct client assistance, such as covering the deposit for a victim’s new
rental unit. 7 It also has a number of preparedness programs including
mobile apps with information on what to do during a disaster, pre-disaster
planning, and public education initiatives on topics such as first aid and
child care. The American Red Cross is also active in international disaster

7
During the initial stage of recovery services, the focus is on restoring basic services such
as public health services and utilities, and getting displaced individuals into temporary
housing. In the longer term, the focus of recovery efforts shifts to redevelopment and
rebuilding of damaged areas, a process which can take years or even decades. For more
information see GAO, Disaster Recovery: FEMA’s Long-Term Assistance Was Helpful to
State and Local Governments but Had Some Limitations, GAO-10-404 (Washington, D.C.:
Mar. 30, 2010).

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GAO-15-565 American Red Cross

 assistance. Working with Red Cross and Red Crescent organizations
from other countries, the American Red Cross provides relief supplies,
financial assistance, and technical assistance via disaster response and
recovery specialists. In 2013, the American Red Cross reported that it
helped an estimated 1.3 million people affected by flooding, storms,
droughts, conflicts, and other disasters in 24 foreign countries. 8

Red Cross’s Federal
Charter

The Red Cross has had a federal charter since 1900. Although the
original charter was repealed and the subsequent charter has been
amended several times, most recently in 2007, the purposes and duties
assigned to the Red Cross in 1900 remain essentially the same today. 9
The charter states the Red Cross is to:
carry out a system of national and international relief in time of peace,
and to apply that system in mitigating the suffering caused by
pestilence, famine, fire, floods, and other great national calamities,
and to devise and carry out measures for preventing those calamities;
provide volunteer aid in time of war to sick and wounded members of
the Armed Forces in accord with the Geneva Conventions and any
other similar treaties, conventions, or protocols to which the United
States may agree, and to perform the duties of a national Red Cross
society; and
provide voluntary relief and act as a medium of communication
between the people of the United States and the Armed Forces of the
United States. 10

•

•

•

The most recent amendment to the charter was made by the American
National Red Cross Governance Modernization Act of 2007
(Modernization Act), 11 which modernized the Red Cross’s governance
structure. It defined the role of the Board of Governors as, among other

8

American Red Cross, Global Impact Report, Fiscal Year 2013 (Washington, D.C.: 2013).

9

The Red Cross charter is codified at 36 U.S.C. §§ 300101 – 300113.

10

Beyond the duties laid out in its charter, the Red Cross also is involved in several other
activities, the largest of which is its biomedical services business which collects, tests, and
distributes blood and blood components throughout the United States. According to the
Red Cross, it supplies more than 40 percent of the blood and blood products in the United
States. About two-thirds of its total spending is related to its blood supply work. Biomedical
services were outside of the scope of our work.

11

Pub. L. No. 110-26, 121 Stat. 103.

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 things, overseeing the management of the organization’s business and
affairs. It reduced the size of the Board from 50 members to between 12
and 20 members and provided for the election of members at the Red
Cross annual meeting. As with prior versions of the charter, the President
continues to have the authority to appoint the Board chairman. 12 As a
result of the Modernization Act, the President no longer appoints federal
officials to the Board of Governors; however, the act requires the
President to appoint federal officials as members of a separate advisory
council to the Board. 13 This advisory council, which has since been
termed the Cabinet Council, is required to meet at least annually with the
Board of Governors.
The act made several other notable changes to the Red Cross charter as
well. For example, it stated that it is in the national interest to confirm the
Red Cross’s status as an instrumentality of the United States and
amended the Red Cross’s charter to clearly reflect that designation, which

12
When the original charter was repealed in 1905, the new charter, stating that the
importance of the Red Cross’s work required government supervision, provided for a
governing committee of 18 members, with 6 including the chairman to be appointed by the
President. To further increase government supervision, the 1905 charter required the Red
Cross to submit an annual report of its proceedings, including an itemized report of
receipts and expenditures to the War Department, which was required to audit and
transmit to Congress. The current version of the charter assigns the audit to the Secretary
of Defense. 36 U.S.C. § 300110.
13
The advisory council is to consist of 8 to 10 members who are principal officers of the
executive departments or senior officers of the Armed Forces who are qualified to
contribute to carrying out the programs and purposes of the Red Cross. At least one but
not more than three members of the advisory council must be members of the Armed
Forces. 36 U.S. C. 300104(d).

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 confers certain tax and other advantages. 14 It also required the Red Cross
to establish an Office of the Ombudsman whose duties and
responsibilities are to be set by the Red Cross; this Office reports directly
to the Red Cross Chief Executive Officer and the Board of Governors.
The Ombudsman Office is required to report annually to Congress any
trends and systematic matters it has identified as confronting the
organization. 15 It provides consulting, coaching, mediation and facilitation
to help resolve issues identified by Red Cross employees, volunteers,
and the general public across several areas, including compensation and
benefits, career progression and supervision, peer relationships, safety
and health, administration, and service. The Ombudsman Office does not

14

36 U.S.C. § 300101(a).The Red Cross has long been recognized by the courts as an
instrumentality of the United States, but the determination of its legal status has varied
depending on the context of the examination. In 1966, in a case brought by the United
States and the Red Cross, the U. S. Supreme Court ruled that the Red Cross, as a virtual
“arm of the government,” was an instrumentality of the United States, and as such, was
immune from state taxation. As a result, the court held that Colorado could not impose
state unemployment taxes on the wages paid to Colorado-based employees of the Red
Cross. Department of Employment v. United States, 385 U.S. 355 (1966). And in a suit
brought by the United States against the City of Spokane, to preclude its collection of tax
on lawfully conducted gambling activities, the Court of Appeals for the Ninth Circuit
affirmed a District Court’s decision that the city could not impose a tax on the proceeds of
the bingo operations of a local chapter of the Red Cross because the bingo games were a
governmental function of an instrumentality of the United States. United States v. City of
th
Spokane, 918 F. 2d. 84 (9 Cr. 1990). The court distinguished an earlier case (Irwin
th
Memorial Blood Bank v. American Nat’l Red Cross, 640 F.2d 1051 (9 Cir. 1981)) where it
had held that the Red Cross was not subject to the Freedom of Information Act, pointing
out that its determination that the Red Cross was not an agency for purposes of that
statute, did not affect the determination that the Red Cross was an instrumentality of the
government. A number of federal courts have considered whether, as the Red Cross has
argued, that, as an instrumentality of the United States, the Red Cross is immune from
jury trials and or punitive damages. Although the courts have reached differing
conclusions, they have noted that the Red Cross performs a variety of governmental
functions and based their conclusions, in part, on whether the jury trials or punitive
damages would interfere with the Red Cross’s performance of those functions. See Tesfa
v. American Red Cross, 2013 WL 5707849 (S.D. Ohio) and cases cited therein.

15

36 U.S.C. § 300112(b)(1). Over the past two fiscal years (2013 and 2014), the
Ombudsman received contacts from, respectively, 979 and 1,036 people—including
members of the general public, staff, and volunteers—who raised, respectively, 1,406 and
1,374 issues. A total of 153 issues (11 percent) in 2013 related to the Red Cross unit
tasked with disaster relief; the greatest number of those issues involved service delivery.
In 2014, issues related to disaster assistance were included in the category of
humanitarian services, and according to Red Cross officials comprised 24 percent of the
521 issues in this category. Red Cross, Office of the Corporate Ombudsman, Fiscal Year
2013 Annual Report (Washington, D.C.: Feb. 2014), and Office of the Corporate
Ombudsman Fiscal Year 2014 Annual Report (Washington, D.C.: Jan. 2015).

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 have investigative authority. 16 The act also provides that the Comptroller
General of the United States, the head of the U.S. Government
Accountability Office, is authorized to review the corporation’s
involvement in any federal program or activity the government carries out
under law. 17
The United States has made land available to the Red Cross for use in its
work in cooperation with the federal government and its responsibilities
under its charter. Specifically, the Red Cross uses one parcel of land in
the District of Columbia, at no charge, and another parcel, also in the
District of Columbia, under a 99-year lease for which it paid one dollar. 18
On the first parcel, there are three buildings which it uses as its
headquarters and for ceremonial purposes. Although the buildings are
owned by the United States, the Red Cross is responsible for their care
and maintenance. On the second parcel, the Red Cross constructed and
owns a building that it uses for other headquarters purposes. For tax
purposes, the District of Columbia has assessed the combined value of
the two parcels of land on which the Red Cross buildings sit at $128
million. 19 Officials at GSA, which oversees federal property, told us they
are unaware of other nonprofit organizations with similar arrangements
with the federal government.

16

Red Cross officials told us the organization has an Office of Investigations, Compliance,
and Ethics which conducts investigations. They also told us they have an internal audit
office.

17

36 U.S.C. § 300111. GAO supports the Congress in its legislative and oversight
responsibilities by investigating the use of public funds and conducting audits and
evaluations of federal programs and activities as provided in its authorizing legislation. 31
U.S.C. 712, 717. GAO’s work extends to virtually every aspect of federal operations,
including grantee and contractor activities funded by the federal government. On
occasion, GAO has reviewed certain aspects of the Red Cross’s disaster operations in
response to congressional requests. For example, see GAO National Disaster Response:
FEMA Should Take Action to Improve Capacity and Coordination between Government
and Voluntary Sectors, GAO-08-369 (Washington, D.C: February 27, 2008); and
Voluntary Organizations: FEMA Should More Fully Assess Organizations’ Mass Care
Capabilities and Update the Red Cross Role in Catastrophic Events, GAO-08-823
(Washington, D.C.: Sept. 18, 2008).
18

36 U.S.C. § 300108 and Pub. L. No. 156, 61 Stat. 241 (1947), as amended by Pub. L.
No. 100-637, 102 Stat. 3325 (1988).

19

In March 2015, GSA officials provided the tax assessment value of the land at $63.6
million for the parcel on which the three buildings sit (colloquially called Red Cross
Square) and $64.4 million for the parcel of the fourth building. The value of the buildings is
not included in these amounts.

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 In 2010, to assist the Red Cross in carrying out the duties identified in its
federal charter, the Federal Supply Schedules Usage Act of 2010 20 gave
the Red Cross access to the Federal Supply Schedules Program.
Operated by GSA, the program is a means of buying goods and services
while using the government’s purchasing power and taking advantage of
overall purchasing volume, thereby reducing costs to customers, who are
typically federal agencies. 21 While this act also gave other qualified
disaster relief organizations—many of which also have non-relief
activities—access to the Federal Supply Schedules Program, it limits
them to using the program for emergency preparedness and disaster
relief. In contrast, the Red Cross is specifically authorized to use the
program for any purpose identified in its charter. 22

The Nation’s Disaster
Response System and
Red Cross’s Role

The Post-Katrina Emergency Management Reform Act of 2006 called for
the establishment of a National Preparedness System. 23 As part of that
system, FEMA has developed various disaster-related coordinating
documents, called Frameworks. Those providing a role for the Red Cross
are:
•

20

National Response Framework (NRF). 24 This document is a guide for
how public and private entities respond to all types of disasters and
emergencies. The NRF lays out roles for a variety of organizations
across 14 emergency support functions (ESF), which are intended to
bring together the capabilities of federal agencies and other partners.
Each ESF has a designated ESF coordinator, a federal agency that
coordinates the work of the ESF overall; one or more primary

Pub. L. No. 111-263, § 2, 124 Stat. 2787 (codified at 40 U.S.C. § 502(e)).

21

The Federal Supply Schedules Usage Act of 2010 also authorized the use of the
program by state and local governments for goods or services for disaster related
preparedness and response. Id. at § 4, 124 Stat. 2788, codified at 40 U.S.C. § 502(d)(1).

22

GSA officials told us that they could not determine the extent to which the Red Cross
has used the program to date or the estimated savings to the Red Cross from using the
Schedules to date.

23

Pub. L. No. 109-295, § 644, 120 Stat. 1355, 1425 (2006), codified at 6 U.S.C. § 744.
The Post-Katrina Act was enacted as Title VI of the Department of Homeland Security
Appropriations Act, 2007.

24

U.S. Department of Homeland Security, National Response Framework, 2
(Washington, D.C.: May 2013). DHS published the first edition in 2008.

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GAO-15-565 American Red Cross

 •

agencies that have significant authorities, roles, and resources; and
multiple support agencies, that have specific capabilities or resources.
In recognition of its disaster relief responsibilities, the Red Cross is
identified as a primary agency—together with FEMA—for the mass
care component of the “mass care, emergency assistance, temporary
housing, and human services” function (ESF-6) under the NRF. 25 Red
Cross is the only nongovernmental organization designated as a
primary agency in the NRF. In addition to this role, Red Cross is
designated as a support agency for the emergency assistance,
temporary housing, and human services components of ESF-6 and, in
that role, is to provide disaster preparedness, response, and recovery
activities and services throughout the nation consistent with its federal
charter. It is also designated as a support agency for five other ESFs
under the NRF.
National Disaster Recovery Framework (NDRF). 26 This document,
released in 2011, provides a similar coordinating structure for postdisaster recovery efforts. Under the NDRF, recovery activities are
categorized under six recovery support functions (RSF), each with a
federal coordinating agency. The Red Cross is designated as a
“supporting organization” for three RSFs under the NDRF. (See app. I
for more information on the Red Cross’s roles under the NRF and
NDRF.)

The response and recovery frameworks apply to incidents that range from
those that can be managed at the local level to those requiring federal
support or leadership. When a significant event occurs and state and
local resources are overwhelmed, a heightened federal involvement is
triggered. During such significant events, FEMA and other federal
agencies provide coordination, technical assistance, and resource
support to states at their request. FEMA and the Red Cross provide
coordination for mass care activities. 27 In addition, certain federal
assistance programs for individuals, businesses, and the public sector

25

The NRF also designates FEMA as the coordinating agency for ESF-6, giving it
authority to coordinate and direct the operations of other federal agencies during
response.

26

FEMA, National Disaster Recovery Framework: Strengthening Disaster Recovery for
the Nation (Washington, D.C.: September 2011).

27

The Red Cross is not solely involved in incidents that require a national response. It
spends a significant portion of its resources responding to local incidents, such as singlefamily home fires.

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 may be activated. Non-federal support agencies are encouraged to
coordinate their assistance through the federal disaster relief structure.

Key Factors That
Drive Red Cross’s
Disaster Assistance
Include Its Standard
Set of Services and
the Needs of Affected
Communities
Domestic Disaster
Response Services Are
Largely Based on
Standardized Procedures

The Red Cross’s services in the immediate response to disasters are
standardized with the goal of providing individuals with services on an
equitable basis regardless of the type of disaster or location. One key
Red Cross policy document in the area of disaster response is the All
Hazards Plan (April 2012), which outlines its overall approach for
providing disaster relief. For example, it lays out five actions that form the
foundation of the organization’s immediate response to emergencies: (1)
sheltering, which includes physical and mental health services; (2)
feeding; (3) assigning staff to local and state emergency operation
centers; (4) reporting financial and other data related to the response; and
(5) reaching out to the public and the media about the Red Cross’s
response activities. Red Cross officials told us that bulk distribution of
relief items and family reunification are other key components of their
disaster services. The All Hazards Plan also prescribes time frames for
taking certain steps during response, such as providing staff to
emergency operations centers within 12 hours. Beyond its general
guidelines for all disasters, the Red Cross has separate documents with
instructions for responding to certain types of events, such as hurricanes,
transportation-related disasters, and pandemics. It also has procedure
manuals with more detailed directions on implementing specific
components of the response effort, such as the Sheltering Handbook and
the Bulk Distribution Handbook. Red Cross officials who managed the
response to the three disasters we studied all confirmed that they
generally provide a similar set of services when responding to events, as
outlined by the organization’s national policies.

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 While the Red Cross has a standardized program for immediate response
to disasters, officials told us there is some flexibility to adapt response
activities to address the unique needs of affected communities or as a
result of coordination with other service providers. For example, officials
involved in the 2014 northern Florida floods told us they channeled
considerable resources into distributing relief items—such as shovels for
removing mud from flooded homes—because that was the community’s
greatest need; but that their sheltering operation was fairly limited
because many victims were able to move in with nearby relatives. With
regard to coordination with other service providers, at the national level
the Red Cross has formal agreements with many other nonprofit
organizations about how they will work together in disasters and the
specific services each organization will provide. For example, the Red
Cross and the Southern Baptist Convention 28 have a statement of
understanding specifying that the Southern Baptist Convention will
prepare meals in mobile kitchens during joint disaster operations while
Red Cross will provide logistical support and deliver meals. 29 As an
example of coordination at the local level, Red Cross officials involved in
Hurricane Sandy said they worked with local governments and other
nonprofits in New Jersey to identify communities that needed food
assistance from external groups such as Red Cross. Decisions about
response services are not influenced by the amount of donations received
for particular disasters, according to officials at Red Cross headquarters
and those involved in the three disasters we studied. A senior
headquarters official told us the organization tries to be as consistent as
possible across disasters when providing services in the response phase,
but there may be differences in services due to unique local
circumstances or to avoid duplicating services provided by other groups.
To fund its immediate response to all disasters—including large events as

28

The Southern Baptist Convention is a religious organization whose mission includes
helping churches provide relief to victims of disasters.

29

As another example, the Red Cross has also entered into a memorandum of
understanding with the National Center for Missing and Exploited Children, which
operates the National Emergency Child Locater Center, established to facilitate the
identification and reunification of children with their families after a disaster under the
Post-Katrina Emergency Management Reform Act of 2006, Pub. L. No. 109-295, tit. VI, §
689b, 120 Stat. 1394, 1449, codified at 6 U.S.C. § 774. The law directed the Center to
enter into cooperative agreements with a variety of entities, including the Red Cross.
Under the memorandum of understanding, the Center and the Red Cross share
information on children who are missing after a disaster with the goal of reunifying them
with their families.

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 well as smaller ones that generate little media coverage or donations—
the organization relies primarily on donations it received prior to the
disaster that were not restricted to any particular disaster, but in some
instances uses restricted funds as well. 30

Domestic Disaster
Recovery and
Preparedness Have
Varied Based on Local
Needs and Funding, and
Red Cross is
Implementing a More
Standardized Approach

The Red Cross’s disaster recovery and preparedness programs have
historically been less standardized than its response program, with more
variation across disasters and locations, according to Red Cross officials.
In the area of recovery, officials told us that while the organization has
been active in this area in the past, until recently there has been a lack of
clarity about what services to provide; and that, in contrast to response,
the nature and scale of services has been significantly influenced by the
amount of donations received in connection with particular disasters. 31
For example, Red Cross officials who managed the Hurricane Sandy
recovery effort told us they lacked clear guidance from headquarters
about what services they should provide at a minimum, and what services
they could provide if funding permitted. They opted to use a portion of the
large amount of donations directed to Sandy for the Move-In Assistance
Program, which covered relocation expenses, furniture, mold removal,
and other costs associated with securing permanent housing. They also
awarded grants to other nonprofit organizations to provide services in
fields where they had more expertise. Similarly, Red Cross officials
involved in the 2013 Oklahoma tornadoes, which also generated a large
amount of donations, said at the time there was some ambiguity in the
organization’s policies on what services to provide during recovery. They
identified specific local needs and used their resources to address these
needs, such as assisting schools with rebuilding and mental health
counseling, and helping families cover the costs of repairing damaged
vehicles.
Similar to the recovery area, while the Red Cross has been involved with
preparedness in the past, these activities historically were not
standardized across the nation. A senior official responsible for

30

Donors have the option of restricting their contributions to the Red Cross for use in a
particular disaster. However, Red Cross states on its website that it reserves the right to
use these funds for other disasters if it receives more donations than it needs for the
disaster designated by a donor.

31

Such donations could include those that are restricted to a particular disaster as well
as—in some cases—non-restricted funds that are received following the event.

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 preparedness activities said these activities were historically led primarily
by the individual regions and chapters, with little centralized direction or
guidance. Also, similar to recovery, the scale of preparedness activities
may be influenced by the level of donations received. After the 2013
Oklahoma tornadoes, for example, the Red Cross was able to use a
portion of its donations to support the construction of safe rooms in
homes throughout the affected region, to help families survive future
tornadoes.
The Red Cross is implementing a more consistent, standardized
approach to both recovery and preparedness. In terms of recovery, in
2014 it issued guidance to its staff on what services to provide and how to
manage these services. This new guidance lays out minimum services
that should be provided following all disasters, and additional services
that may be provided if funding permits. It also requires that an Executive
Director for Recovery Operations be assigned in a large disaster. 32
Officials said this guidance partly came from lessons learned from the
organization’s experiences with recent large events, including Hurricane
Sandy. In terms of preparedness, officials said headquarters develops
nationwide preparedness initiatives that all regions are to implement,
such as its recent effort to install more smoke alarms in private homes,
and provides various preparedness tools for local staff to draw on. 33
Based on our interviews with Red Cross officials involved with recent
recovery and preparedness efforts, it appears that the new policies are
influencing procedures on the ground. For example, the 2014 Florida
floods were one of the first disasters in which the Red Cross’s recovery
effort was guided by the policies set forth in the new guidance. Red Cross
officials involved in this event told us that as a result of these new
policies, they treated recovery as a distinct phase and assigned staff
specifically to manage it, which they said contributed to a more focused,
proactive approach. Also, Red Cross officials involved in events we
studied told us they implement preparedness campaigns and initiatives
generated by headquarters, with some adjustments made to address

32
American Red Cross, Recovery Framework: Disaster Cycle Services Frameworks
(Washington, D.C.: January 2014) and Concept of Operations: Disaster Cycle Services
Program Essentials (Washington, D.C.: October 2014).
33

American Red Cross, Disaster Cycle Services: Preparedness Companion to the
Disaster Capacity and Readiness Framework (January 2014).

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 local needs. For example, officials in the New York metropolitan area said
they deliver training and outreach materials developed by headquarters
but customize their efforts by targeting the most vulnerable communities
and by providing messages in multiple languages.

International Disaster
Assistance Is Driven by
Factors Such as Other
Nations’ Needs and the
American Red Cross’s
Specific Areas of Expertise

Some of the same factors that inform decisions about domestic disaster
assistance—local needs, coordination with governments and other
stakeholders, and amount of donations received—inform the American
Red Cross’s decisions about international disaster assistance. There are
also key differences, according to senior American Red Cross officials.
Unlike with domestic assistance, the American Red Cross does not
automatically get involved with all major international disasters. Rather, it
assesses each appeal for assistance that is issued by the International
Federation of Red Cross and Red Crescent Societies (IFRC)—an
international body representing national Red Cross and Red Crescent
societies—based on a request from a nation’s Red Cross or Red
Crescent society. In deciding whether to respond to the appeal, American
Red Cross managers consider several factors, including the scale of the
humanitarian need, the capacity of the national Red Cross or Red
Crescent society, and the American Red Cross’s capacity to respond in
terms of its expertise and resources.
The specific services or types of assistance the American Red Cross
provides for each international disaster also depend on several factors,
according to senior officials from the organization. One key factor is the
American Red Cross’s particular area of expertise. For example, the
American Red Cross has expertise in bulk distribution of relief items, so
when multiple nations’ Red Cross or Red Crescent societies assist with
an international disaster the American Red Cross typically takes the lead
in this area, while other nations’ societies take the lead in areas such as
public health or logistics. Another factor is input from the Red Cross or
Red Crescent society in the affected nation about what assistance is
needed. For example, the society may tell the American Red Cross that it
needs funds rather than technical assistance. A third key factor is the
amount of donations received, as the organization’s international
assistance is primarily supported by funds that donors have indicated
should be used only for a particular disaster. Finally, certain non-binding
standards and guidelines regarding international disaster relief inform the
American Red Cross’s decisions about their services. One key set of
standards is the Code of Conduct for the International Red Cross and
Red Crescent Movement and Non-Governmental Organizations (NGOs)
in Disaster Relief. This document lays out general principles for how to

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 assist with disasters in other countries, including that assistance should
be provided to all victims without regard to race, religion, or nationality,
and that international organizations should try to build local capacity by
employing local staff and purchasing local materials.

The Red Cross’s
Coordination with the
Federal Government
Focuses Primarily on
Information Sharing
The Red Cross
Coordinates with FEMA
and Other Federal
Agencies Primarily by
Sharing Information on
Services and Resources

Consistent with the structure established by the emergency support
function that covers mass care (ESF-6), the Red Cross works closely with
FEMA in leading the response to major events. According to officials from
both FEMA and the Red Cross, this coordination often involves Red
Cross sharing information with FEMA—for example, through conference
calls or through liaisons assigned to FEMA offices—about victims’ needs
and the resources it and other nonprofit organizations can bring to the
response effort. Officials told us this may help FEMA, as the coordinating
agency for ESF-6, to identify gaps and direct federal resources more
efficiently. During the response to Hurricane Sandy, for example, Red
Cross shared data with FEMA on the number of shelters opened, the
availability of relief supplies such as blankets, and the likely number of
victims who would require help getting access to food. During the
response to the 2013 Oklahoma tornadoes, Red Cross shared expertise
with FEMA on sheltering, and FEMA officials said this helped them think
through alternative approaches to meeting victims’ needs. Conversely
Red Cross officials said they may take information received from FEMA
during a disaster response—such as a state’s request for a particular type
of assistance—into account when determining how to use their resources.
Red Cross officials told us that in addition to sharing information, the Red
Cross and FEMA also coordinate in other ways such as through
exercises, planning, and education and training. (See fig. 2 for an outline
of how the Red Cross and FEMA work together under ESF-6 to lead the
provision of mass care services in major disasters.)

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 Figure 2: How the Red Cross and Federal Emergency Management Agency Work
Together under Emergency Support Function-6 to Lead Mass Care Services in
Major Disasters

Additionally, while officials from both organizations agreed that FEMA
cannot direct the Red Cross to use its own resources in particular ways,
FEMA may use federal funds to procure services from the Red Cross
through an Interagency Agreement (IAA) originally signed in 2012.
According to FEMA officials, this IAA enables FEMA to quickly procure
Red Cross goods and services in cases in which this is more cost
effective than doing so through another federal agency. FEMA officials
said they can use this mechanism because the Red Cross is an
instrumentality of the United States. The IAA has only been used a few

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 times, but the organizations renewed it in May 2015 and FEMA officials
said it could be employed more often in the future. 34, 35
Red Cross and FEMA officials also cited examples of coordination on
disaster recovery and preparedness, and described how this coordination
may influence their service delivery decisions. For example, following the
2014 floods in northern Florida, according to Red Cross officials, FEMA
influenced their decisions about which communities to focus their
recovery efforts on by providing information on areas that were not
covered by other service providers. In addition, FEMA regional officials
involved in the recovery effort following the 2013 Oklahoma tornadoes
said Red Cross provided FEMA with its database of available housing in
the area, which helped FEMA move victims out of shelters and into
permanent housing. In terms of preparedness, Red Cross officials told us
the organizations coordinate at the headquarters level to ensure
consistency in the messages conveyed by their public outreach
campaigns. Red Cross has FEMA experts review its preparedness
materials, such as its mobile applications, to ensure they are scientifically
accurate and consistent with materials developed by FEMA. At the local
level, the two organizations have sometimes coordinated to promote and
distribute each other’s preparedness materials to the public. In addition,

34

For example, FEMA paid the Red Cross about $400,000 under the IAA to provide case
management assistance to victims of a flood in Illinois, because the Red Cross already
had case workers in the area, according to FEMA officials. In addition, between 2008 and
2012, before the IAA was developed, FEMA contracted with the Red Cross to obtain
technical expertise on mass care (through 14 Red Cross staff assigned to FEMA offices).
In fiscal year 2012, the Red Cross received $1.2 million under this contract.

35

Separate from the IAA, the federal government has also reimbursed the Red Cross for
certain disaster assistance activities in previous years. In 2004 the Red Cross was
authorized by law to receive up to $70 million in federal funds to reimburse it for
expenditures associated with Hurricanes Charley, Frances, Ivan, and Jeanne. Military
Construction Appropriations and Emergency Hurricane Supplemental Appropriations Act,
2005, Pub. L. No. 108-324, 118 Stat. 1220, 1251-1252. In May 2006, GAO reported that
the Red Cross had requested reimbursement of $28.1 million. GAO, Disaster Relief:
Reimbursement to American Red Cross for Hurricanes Charley, Frances, Ivan and
Jeanne, GAO-06-518 (Washington, DC: May 30, 2006). Additionally, in 2008, the Red
Cross was authorized by law to receive up to $100 million in federal funds for
reimbursement of expenditures associated with hurricanes, floods, and other natural
disasters occurring that year for which the President declared a major disaster.
Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009,
Pub. L. No. 110-329, § 10502, 122 Stat. 3574, 3593. In September 2012, GAO reported
that the Red Cross was reimbursed in the amount of $78.1 million. GAO, Disaster Relief:
Reimbursements to the American Red Cross for Certain 2008 Disaster Assistance,
GAO-12-877 (Washington, DC: Sep. 14, 2012).

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 Red Cross officials said the organization is part of the Emergency
Support Function Leadership Group and the Recovery Support Function
Leadership Group, both of which meet on a monthly basis to address
critical areas of support and coordination.
In addition to coordinating with FEMA on mass care, the Red Cross also
works to a lesser extent with some other federal agencies during disaster
response. For example, in the area of public health, the Red Cross
transmits data to the Centers for Disease Control and Prevention
(CDC)—located within the Department of Health and Human Services
(HHS), on health issues among disaster victims receiving its assistance. 36
CDC analyzes these data and submits reports back to the Red Cross.
The Red Cross and CDC signed a memorandum of agreement in 2010
outlining their respective roles and responsibilities. In the area of logistics,
Red Cross routinely works with GSA. GSA is the co-primary agency for
the logistics emergency support function, along with FEMA. 37 GSA
officials told us the Red Cross is an active participant in planning
meetings, exercises, and trainings related to this emergency support
function. During disasters, according to officials from both organizations,
the Red Cross shares information with GSA on its efforts to assist victims
and available resources. It may also indirectly obtain relief supplies from
GSA, when a state government formally requests assistance from FEMA.
In such cases, FEMA tasks GSA to provide commodity or services
support to the state, which then turns this support over to the Red Cross,
according to GSA officials.
Finally, the American Red Cross and the federal government coordinate
on international disaster assistance in several ways, including the use of

36
We have previously reported that the federal coordinating agencies for the emergency
support functions are inconsistently carrying out their emergency preparedness activities.
For example, FEMA, in its role as coordinating agency for mass care, had coordinated
with the mass care support agencies through a variety of mechanisms, produced a
planning document, and completed a capability assessment. In contrast, HHS, in its role
as coordinating agency for the public health and medical services emergency support
function, had conducted no preparedness coordination specific to this emergency support
function, and had not completed its planning document. See GAO, Emergency
Preparedness: Opportunities Exist to Strengthen Interagency Assessments and
Accountability for Closing Capability Gaps, GAO-15-20 (Washington, D.C.: Dec. 4, 2014).
37

The logistics emergency support function covers, among other things, acquisition of
resources; delivery of supplies, equipment, and services; and coordination of
transportation.

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 federal grants to support American Red Cross relief efforts. Officials from
the Office of U.S. Foreign Disaster Assistance (OFDA) within USAID told
us they maintain contact with major international disaster assistance
organizations, including the American Red Cross, to identify the disaster
response capabilities they possess that could be drawn upon in the event
of an international disaster. This coordination enables OFDA to quickly
identify potential service providers when a need arises in particular
geographical areas. For example, OFDA has frequently interacted with
the American Red Cross on disaster assistance in Indonesia, because
the American Red Cross was actively involved in providing relief there. In
some cases, the federal government may provide federal funds to the
American Red Cross to support specific international assistance projects.
The American Red Cross told us it used about $3.5 million in grants from
USAID during fiscal years 2012 and 2013 for assistance projects in
Indonesia and other countries. OFDA officials said they typically provide
grants to the American Red Cross for disaster risk reduction and
preparedness programs, such as hazard mapping and working with
communities to establish evacuation routes. During this same time period,
the American Red Cross said it used about $1.6 million in grants from the
Bureau of Population, Refugees, and Migration within the State
Department. 38 These grants supported emergency services to refugees in
Tanzania and Panama, such as providing safe drinking water and
mosquito nets.

Coordination with FEMA Is
Consistent with Several
Best Practices

The coordination between the Red Cross and FEMA during disaster
response exhibits a number of features that GAO has previously identified
as benefiting coordination efforts: 39
•

Written guidance and agreements. Besides the IAA, Red Cross and
FEMA have developed several other documents that determine how
they work together on disaster response. For example, they signed a
memorandum of agreement in 2010 to outline how they should
cooperate and mutually support each other when conducting mass
care activities. Also, the two organizations played lead roles in

38

Technically, the State Department uses the term cooperative agreement to describe the
mechanism by which it awards funds to the American Red Cross.

39
See GAO-12-1022 for a complete list and explanation of these features. This report is
part of a body of GAO work related to collaboration across government agencies,
nonprofits, and the private sector.

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 •

•

•

•

developing a National Mass Care Strategy document in 2012. This
document integrates the perspectives of FEMA, the Red Cross, and a
number of other groups involved in disaster response, and
recommends general best practices for mass care service delivery.
Common outcomes and goals. The National Mass Care Strategy lays
out strategic goals and sub-goals for disaster response that are
shared by FEMA and the Red Cross, as well as other disaster
response organizations. These shared goals include making sure that
service delivery is flexible and scalable to meet requirements and
creating the opportunity for improved whole community coordination
and participation. Examples of more detailed sub-goals include
removing barriers to volunteer, faith-based, community-based, and
private sector involvement in disaster response and implementing a
standardized mass care incident management training program. Red
Cross officials told us they particularly share common goals with
FEMA in the area of mass care.
Clearly defined roles and responsibilities. FEMA and Red Cross have
defined their roles and responsibilities during disaster response,
especially through the memorandum of agreement. The 2010
agreement laid out a number of specific responsibilities for each
organization, including 11 that are specific to FEMA (e.g., directing
and coordinating federal assets during response operations); 18 that
are specific to Red Cross (e.g., fostering joint training, terminology,
standards, and strategies for mass care among states and other
nonprofits); and 10 that are shared by both organizations (e.g.,
assisting states with planning and executing mass care services).
Representatives with the ability to commit agency resources. In the
three disasters we studied, FEMA regional officials said they
interacted with Red Cross staff who had the appropriate level of
decision-making authority. For example, the Red Cross assigned a
higher-level manager to work directly with FEMA following Hurricane
Sandy, when more complex decisions had to be made. Similarly, Red
Cross officials told us they have consistent access to FEMA program
staff and senior leaders, both at headquarters and regional levels.
Compatible technological systems. Through its National Shelter
System, the Red Cross transmits data to FEMA’s shelter database on
the shelters it operates, such as their location and capacity. FEMA
regional officials we interviewed said this technology provides FEMA
with valuable data.

The organizations’ roles and responsibilities in the area of recovery were
not clearly defined in the 2010 memorandum of agreement which laid out
how the Red Cross and FEMA work together during major disasters. Of
the 18 responsibilities assigned specifically to the Red Cross in its

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 memorandum of agreement with FEMA, nine related to the area of mass
care and disaster response, while only three touched on disaster
recovery. 40 These included helping to create community-wide recovery
strategies and encouraging other partners to share information on their
recovery activities with FEMA. Both FEMA and Red Cross headquarters
officials recognized the agreement is primarily focused on response and
provides few details on recovery. Furthermore, several FEMA regional
staff told us the agreement was not sufficiently clear in the area of
recovery. FEMA staff involved with Hurricane Sandy said the Red Cross
played a more significant and proactive role in the recovery phase of that
disaster than it has in the past. They told us that while their wellestablished personal relationships with Red Cross staff enabled them to
keep abreast of and understand the organization’s evolving role,
additional clarity in formal documents about Red Cross’s role in recovery
would be helpful. Similarly, a FEMA official involved in the 2014 Florida
floods said that adding details about the Red Cross’s role in recovery to
the memorandum of agreement would help FEMA and Red Cross staff
work together more effectively. The official said the document should
describe other potential Red Cross roles beyond organizing community
recovery efforts, such as providing financial assistance or case
management services to disaster victims. 41
In prior work we have emphasized that written agreements are most
effective when they are regularly updated and monitored. 42 Red Cross
and FEMA signed a revised memorandum of agreement that was
executed on July 28, 2015 that includes additional details about how the
organizations will work together in recovery. For example, Red Cross
(along with FEMA) is now tasked with supporting Long-Term Recovery
Groups that will address unmet needs of people affected by disasters.
The new agreement will remain in effect until 2020.

40

The remaining responsibilities cover preparedness activities, among other things.

41

Establishing clear guidelines and effectively coordinating with key partners in long-term
recovery have been challenges for FEMA over the years. We reported previously that,
prior to the development of the NDRF, FEMA faced challenges in coordinating with state
and local governments on recovery. For example, the criteria for activating ESF-14—
which supported long-term recovery—for specific disasters were vague, resulting in
uncertainty among states and other federal agencies. Also, FEMA in some cases did not
coordinate well with state and local governments on the timing of recovery efforts, getting
involved before states and locals were ready for assistance. See GAO-10-404.

42

GAO-12-1022.

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 Federal, State, and
Nonprofit Oversight of
the Red Cross
Focuses on
Governance and
Financial Practices
Rather Than Disaster
Performance
Federal Agencies Have
Oversight Responsibilities
Related Primarily to Red
Cross’s Financial
Practices and Use of
Federal Funds

Although the Red Cross plays a significant role in domestic disaster relief,
the federal government does not conduct regular ongoing evaluation of its
disaster-related services. The activities of several federal agencies are
targeted to specific aspects of the Red Cross’s governance and financial
practices. Specifically, those agencies are the IRS, which enforces tax
exemption requirements; DOD, which reviews Red Cross’s financial
statement; and FEMA, the State Department, and USAID, which monitor
the Red Cross’s use of funds provided under grants and an interagency
agreement.

IRS

The Red Cross, as an Internal Revenue Code section 501(c)(3) tax
exempt charitable organization, is required to annually file with the IRS a
Form 990 43 containing data on revenues, expenditures, and governance.
A key result of IRS oversight of the Red Cross is that the agency makes
these forms available to the public. The most recent Red Cross Form 990
has information on the broad range of Red Cross programs and services.
Specific information for domestic disaster services includes the total
amount spent and the types and number of disasters to which the
organization responded during the past year. The form does not call for
the specific amount of gifts, grants, and contributions received for disaster
services to be reported. The information that the Red Cross supplies
about its governance includes the names of board members and officers,
the officers’ compensation, and how they have certified their compliance

43

Return of Organization Exempt from Income Tax.

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 with the organization’s code of business ethics and conduct. Based on its
review of a nonprofit’s 990 submission, IRS may conduct a more in-depth
examination to determine if that nonprofit is in compliance with
requirements related to its tax-exempt status. 44 IRS investigates a small
fraction of charities each year. 45 For example, IRS might conduct a more
in-depth examination if a Form 990 indicated a significant diversion of
resources to an official, such as an unreasonable amount of
compensation, or loans to officers at below-market interest rates. If IRS
determines that an entity operated in a manner that is materially different
from its stated exempt purpose or engaged in a prohibited transaction, it
could impose certain sanctions, including revoking the entity’s tax
exemption. 46 As we have reported previously, in fiscal year 2013, IRS
examined 5,426 Form 990 returns filed during fiscal year 2012, meaning it
examined 0.71 percent of the approximately 763,000 tax-exempt charities
that filed. 47

DOD

DOD’s Army Audit Agency conducts a high-level annual review of the
Red Cross’s consolidated financial statements and submits a report of its
review to Congress. 48 Specifically, the agency reviews the results of an

44

The Internal Revenue Code requires that an organization adhere to certain accepted
charitable, religious, educational, scientific, or literary purposes to qualify for 501(c)(3) taxexempt status. The Code also prohibits charitable organizations from undertaking certain
activities—no earnings of the organization may benefit individual or private shareholders,
no substantial attempt may be made to spread propaganda or influence legislation, and no
effort may be made to campaign for or against a candidate for public office. 26 U.S.C. §
501(c)(3) and 26 C.F.R. § 1.501(c)(3).

45

IRS conducts (1) compliance checks, in which it asks an organization to explain
something on the Form 990 that appears potentially questionable, and (2) examinations,
in which organizations are required to provide their records to IRS, which in turn attempts
to verify the supporting documentation behind the Form 990 entries.

46

IRS officials told us that revocation of tax-exempt status is a last resort. Rather, IRS
tries to work with organizations that have compliance problems to resolve them before
starting a revocation action. For example, IRS can issue a corrective letter to an
organization listing corrections needed to comply with tax law. If the organization
complies, no further enforcement action is taken.

47
GAO, Tax Exempt Organizations: Better Compliance Indicators and Data, and More
Collaboration with State Regulators, Would Strengthen Oversight of Charitable
Organizations, GAO-15-164 (Washington, D.C.: Dec. 17, 2014).
48

The charter requires the Red Cross to submit an annual report to the Secretary of
Defense on its activities during the previous fiscal year, including a complete itemized
report of all receipts and expenditures. The Secretary is required to audit that report and
submit a copy to Congress. 36 U.S.C. §§ 300110.

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 independent audit of the Red Cross’s financial statements conducted by a
certified public accounting firm engaged by the Red Cross, and issues a
letter presenting the results of its review. The letter notes that the Army
Audit Agency takes this approach in order to avoid duplication and
unnecessary expense. The agency most recently reviewed KPMG LLP’s
audit of the Red Cross’s consolidated financial statements for the fiscal
year ended June 30, 2014. To determine the reliability of KPMG’s work,
the agency reviewed, among other things, KPMG’s audit approach, the
qualifications and independence of the audit staff, selected audit plans,
Red Cross’s consolidated financial statements, and KPMG’s report
evaluating Red Cross’s conformance with U.S. generally accepted
accounting principles. The agency stated it found nothing inappropriate or
unreliable in KPMG’s opinion that Red Cross’s fiscal year 2014 financial
statements were fairly presented. 49 We also reviewed the agency’s letters
describing the results of its work on the fiscal year 2012 and 2013
financial statements, which reached similar conclusions, e.g., that there
were no issues with KPMG’s opinion that Red Cross’s financial
statements were fairly presented for those years. 50 Red Cross officials
indicated that when performing the annual financial statement audit,
KPMG tests a wide array of systems and procedures across the
organization’s various lines of service. Specifically for disaster-related
work, KPMG conducts testing to ensure that eligibility criteria for disasterrelated financial assistance are applied correctly and that systems used to
process and record disaster revenues and expenses are reliable, among
other things.

FEMA, USAID, and State
Department

When the Red Cross receives funds from FEMA through the IAA, or from
USAID or the State Department through grants, officials of these entities
told us they oversee Red Cross’s use of these funds by monitoring its
compliance with the terms of the IAA or the grant. For example, FEMA
oversees its IAA with Red Cross through its procurement office, which
monitors invoices submitted by the Red Cross and ensures that it
delivered the services and goods required under the IAA. USAID officials
told us they review quarterly reports submitted by the Red Cross for

49

Department of the Army, U.S. Army Audit Agency Review of the Independent Auditor’s
Report, A-2015-0010-FMF, (Nov. 21, 2014).

50

DOD and Red Cross officials told us that in addition to reviewing KPMG’s financial
audit, Army Audit Agency staff attend every meeting of the Red Cross Board of
Governors’ audit committee. DOD officials said Army Audit Agency staff attend these
meetings primarily as observers.

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 financial and programmatic monitoring purposes, with the latter focusing
on reporting against required indicators and outputs. USAID officials
explained that specific monitoring requirements are included in the
proposal agreement associated with each grant the agency awards for
international disaster assistance. Similarly, the State Department’s
Bureau of Population, Refugees, and Migration monitors the small
number of grants it awards the Red Cross for international disaster
assistance. Bureau officials said its overseas representatives monitor and
evaluate the general performance of operations under any awarded
agreement to ensure that the established objectives are being
successfully met, and provide the Bureau reports on whether the
performance is in compliance with the terms of this agreement.
Additionally, they said the Bureau’s monitoring report includes an on-site
assessment of activities and written evaluation, and provides a record
and assessment of performance, coordination, financial or management
issues.

States’ Oversight Focuses
on Preventing Fraud and
Mismanagement, but
Some States See Their
Authority as Limited by
Red Cross’s Status as a
U.S. Instrumentality

State attorneys general have the authority to investigate and take action
on any allegations about nonprofits, such as fraud or misuse of donated
funds. According to officials in several states and an expert we
interviewed, state attorneys general typically investigate nonprofits when
they receive some indication of potential mismanagement of charitable
assets or fraud in soliciting or using funds, such as when they receive a
complaint about a nonprofit from a donor or a whistleblower. We were
unable to identify the total number of state attorney general investigations
of Red Cross nationally in recent years. According to state attorneys
general officials, investigations are typically made public only when they
take formal, legal action against a nonprofit. Furthermore, information that
is publicly available from all 50 states is not centrally located. According
to an expert in the field, state attorneys general are unlikely to investigate
the Red Cross because, with limited resources, these offices prioritize
investigations of newer, less established organizations. Officials at two of
the three state attorney general offices we interviewed in depth said Red
Cross had not been a focus of investigations within their states. An official
of one of the states told us that with limited resources, the state focuses
on the most egregious offenders, such as scammers who raise money
after disasters for non-charitable, illegitimate purposes.
In one of the three states, New York, the Charities Bureau of the Office of
the Attorney General has full time staff dedicated to oversight. In 2014, it
produced a report examining the Red Cross’s use of funds donated for
Hurricane Sandy recovery, as part of a Charities Bureau project that

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 asked about 90 nonprofits that received donations to disclose information
on the amounts received and how they were being spent. The Red Cross
received the largest amount of donations. Part of the purpose of this effort
was to ensure that funds raised in the name of Hurricane Sandy relief
were used for that purpose. The Charities Bureau reached an agreement
with Red Cross intended to provide additional relief for Sandy victims and
further promote transparency for donors. The Red Cross agreed to
allocate an additional $6 million for Sandy relief efforts. It also agreed to
make several changes to its processes for online solicitation, such as
omitting any reference to a specific disaster on the online donation page
and informing potential online donors that they may restrict their
donations to a specific disaster by completing a form and mailing a check.
Although states may investigate the Red Cross when potential issues
arise, officials in several of the states we contacted said their oversight is
limited to some degree because of Red Cross’s close connections to the
federal government. Many states require certain nonprofits to register with
their attorney general’s office. In the six states we contacted, we were told
that registered nonprofits must submit information such as annual
financial statements, data on how professional fundraisers are used, and
compensation amounts. However, all six states exempt Red Cross from
these requirements, and officials from several of those states and an
expert on state oversight of nonprofits told us this is generally the case. 51
Officials in five of the six states we contacted told us the Red Cross is
exempted because of its status as a federal instrumentality or because it
is already subject to oversight by the federal government, such as the
requirement that it submit financial records to DOD. 52
State officials expressed mixed opinions about the consequences of Red
Cross’s exemption for their ability to monitor the organization. Some said
they now have access through the Internet to most of the information Red
Cross would submit if it were subject to registration requirements; one
said his state primarily relies on complaints or media attention to identify
issues for investigation, rather than information that registered charities
are required to submit. But some officials said the exemption impedes

51

A Red Cross official told us Red Cross’s long-standing position is that it is exempt from
state charity registration requirements.
52

An official in the sixth state we contacted told us his state exempts all nonprofits that
are classified as tax-exempt by the IRS, which includes the Red Cross.

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 their ability to identify issues at the Red Cross. For example, a Colorado
official said that as a result of the exemption, there is no opportunity for
the state to request and review clarification of any information in the light
of whistleblower allegations or stories by investigative journalists, nor to
compare data submitted in the Form 990 to data submitted directly to the
state, as it is with other nonprofits. Similarly, a Michigan official told us
that reviews of documents submitted by registered nonprofits may identify
potentially false statements, and this can lead to withholding of
registration or more aggressive enforcement actions; but such reviews
are not conducted for nonprofits that are exempt from registration
requirements, such as the Red Cross.

Nonprofit Watchdogs
Monitor Red Cross’s
Governance and Finances
as Guides for Donors

A number of nonprofit watchdogs monitor charitable organizations
generally, including disaster relief organizations such as Red Cross, and
focus on governance, transparency, and financial practices. For example,
two prominent watchdogs in this category—Charity Navigator and the
BBB Wise Giving Alliance—have recently given the Red Cross strong
ratings in these areas. In its rating for the fiscal year ending June 2014,
Charity Navigator gave the Red Cross three stars out of a maximum of
four, indicating it “exceeds or meets industry standards and performs as
well as or better than most charities in its Cause.” 53 The Red Cross met
all but one of Charity Navigator’s accountability and transparency
requirements, but its scores in both Financial Performance and
Accountability and Transparency declined slightly from the prior year. In
addition, in November 2014 Charity Navigator put the Red Cross on its
watchlist due to concerns expressed by two members of Congress and

53

Charity Navigator rates nonprofits on financial performance (e.g., the proportion of
spending for program services, administration, and fund-raising) and accountability and
transparency (e.g., whether the organization has independent voting board members, and
whether certain governance and financial information is available on the organization’s
website).

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 recent media reports about the Red Cross. 54 Further, despite its overall
strong rating for the Red Cross in the area of transparency, in November
2013, after Typhoon Haiyan struck the Philippines, Charity Navigator
issued an advisory noting that some nonprofits—including Red Cross—
had not clearly communicated on their websites whether funds donors
intended for Haiyan relief would, in fact, be used exclusively for that
disaster. In the BBB Wise Giving Alliance’s January 2015 rating, the Red
Cross met all 20 standards the group uses to assess nonprofits; these
cover areas including governance, effectiveness, and finances. 55 Both
groups said in making their assessments, they rely on charities’ annual
Form 990 submissions as well as other information they collect from
charities. Charity Navigator officials said because of uncertainty regarding
the accuracy of nonprofits’ self-reported responses to questions on the
Form 990 it has started to request additional documents from nonprofits
as corroboration.
The Center for Disaster Philanthropy and the Disaster Accountability
Project are organizations that provide information to donors and the
public about disaster assistance. The Center for Disaster Philanthropy
works with individual donors, foundations, and corporations to inform their
decisions about supporting disaster relief organizations, with a particular
focus on promoting support for longer-term recovery efforts. It works with
clients to help them understand the specific needs associated with
different disasters and inform their decisions about charitable donations.
Another group, the Disaster Accountability Project, shares information
with the public on disaster relief services and promotes greater

54

Charity Navigator’s website says that it puts organizations on its watchlist when it
“become[s] aware of conduct that may affect a donor’s decision to support that charity.”
Charity Navigator takes no position on allegations or issues raised by third parties, and
does not confirm or verify allegations raised by third parties, but it has determined that the
nature of these issues warrants highlighting the information for donors. The Red Cross
has responded to some of the media reports cited by Charity Navigator, for example in
press releases dated October 28, 2014 (American Red Cross Comments on ProPublica
Report) and December 11, 2014 (American Red Cross Response to Latest ProPublica
Allegations). In addition, an organization called Charity Defense Council responded to
certain press reports on August 6, 2015 (Media Malpractice—How the Press Has Tried to
Kill the Red Cross’ Haitian Relief Effort).
55

The BBB Wise Giving Alliance assesses whether nonprofits meet 20 standards in the
areas of governance (e.g., board meets at least three times per year), effectiveness (e.g.,
organization has a policy to measure its effectiveness), finances (e.g., proportion of
spending on program services), and fundraising and other information (e.g., fundraising
appeals are truthful and not misleading).

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 transparency by relief organizations. For example, it coordinates a hotline
for members of the public to report gaps in services after a disaster,
operates an online forum for sharing disaster policy recommendations,
and issued a report evaluating the transparency of information that Red
Cross and other organizations provided about their response to the 2010
earthquake in Haiti. This report concluded that almost all of the 195
organizations examined (including the Red Cross) did not provide an
acceptable level of transparency on their websites. 56

No Regular External
Evaluations are
Conducted of the Red
Cross’s Performance in
Disasters, although
Metrics Exist for Doing So

Despite the Red Cross’s significant role in responding to the nation’s
disasters, none of the government or nonprofit organizations we identified
as having a role in overseeing the Red Cross conducts regular, ongoing
evaluations of its performance providing disaster services. 57 Among
federal agencies, IRS and DOD do not focus on delivery of disaster
services. While FEMA is directly involved with disaster services, FEMA
and Red Cross officials told us that FEMA generally has no formal role in
overseeing or evaluating the Red Cross’s—or any other nonprofit’s—
performance in disasters. FEMA develops after-action reports following
major disasters, but these are assessments of FEMA and the disaster
response system overall. For example, in its after-action report on the
response to Hurricane Sandy, FEMA assessed the strengths of the
response FEMA coordinated across all organizations involved, as well as
the difficulties, and suggested improvements for future events. 58 The
report did not evaluate the performance of any one particular
organization; rather, it described participating organizations’ contributions,
including those of Red Cross. While FEMA does monitor the Red Cross’s
use of federal funds that it provides the organization through their IAA,
FEMA funds represent a very small fraction of the Red Cross’s overall
spending on disaster assistance.

56

Disaster Accountability Project, One Year Follow Up Report on the Transparency of
Relief Organizations Responding to the 2010 Haiti Earthquake (Dec. 2010/Jan. 2011).

57

Red Cross officials told us the organization has a number of activities in place to
evaluate its performance in disasters and make improvements, such as after action
reviews and surveys of staff, clients, local and state emergency managers, and other
stakeholders. They also said the results of internal evaluations such as after action
reviews are typically not made available to the general public.

58

FEMA, Hurricane Sandy FEMA After-Action Report (Washington, D.C., July 1, 2013).

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 Meanwhile, oversight conducted by state governments is generally
focused on issues such as possible fraud or failure to act in accordance
with donor intent, rather than the effectiveness of services provided.
Evidence suggests there is no routine or regular state government
oversight of the Red Cross. Furthermore, even if states did not exempt
the Red Cross from registration requirements, they would not necessarily
be better positioned to evaluate the organization’s delivery of disaster
assistance. Similarly, nonprofit watchdog groups are also generally
focused on issues other than the impact or effectiveness of charitable
services. For example, an official from the BBB Wise Giving Alliance said
his organization lacks expertise to evaluate a nonprofit’s performance in a
disaster and does not see this as its role. 59 The Disaster Accountability
Project has raised issues with the Red Cross’s performance in disaster
response, but its primary activities are to compile complaints about
service gaps and maintain a website that lists policy recommendations
related to disaster response—not to conduct formal studies of
effectiveness or efficiency.
Officials from several organizations told us it can be challenging to assess
the effectiveness or impact of disaster assistance. For example, Urban
Institute officials cautioned that it is difficult to develop a single set of
performance measures for all disasters because disasters and expected
outcomes for victims vary widely. An official from the Center for Disaster
Philanthropy told us there is a lack of clarity on what exactly should be
measured, with possible metrics including how quickly services were
delivered, how efficiently services were delivered, and how quickly
communities recovered after a disaster. USAID officials told us that
evaluating how well organizations perform during international disasters
can be challenging, as it is sometimes difficult for USAID staff to
physically access the projects to monitor or evaluate them. Furthermore,
due to the unpredictability of disasters, these officials told us it is difficult
to collect baseline data before a disaster strikes.
Even in light of the challenges, there are benefits to evaluating disaster
assistance, including to (1) help relief organizations identify needed
improvements, and (2) promote transparency for the donating public.
First, the Urban Institute has noted that the benefits of evaluating disaster

59

The BBB Wise Giving Alliance has standards related to effectiveness of charitable
activities, which require nonprofits to have a policy in place for assessing their own
effectiveness.

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 response activities include helping service providers and government
agencies identify improvements needed in the provision of services, and
identifying the types of services most likely to be helpful to particular
demographic subgroups. Second, GAO and others have also emphasized
the importance of transparency and making information available to the
donating public about nonprofits’ activities and performance. For
example, GAO has noted in prior work that such information can enhance
incentives for ethical and effective operations. 60 In addition, a panel of
experts and representatives of the nonprofit sector examined, at the
encouragement of the Senate Finance Committee, various practices in
that sector and noted that the public must have accurate, clear, timely
and adequate information about the programs, activities, and finances of
charitable organizations, in order to encourage participation and
confidence in that sector. Information on an organization’s results and
how they are measured could be an especially valuable way to explain to
donors and the general public the organization’s work and how it
evaluates the results of its work. 61
With respect to performance evaluation specifically, evaluators who are
external to and independent from the organizations they examine can
play an important role. For example, the IFRC’s evaluation standards for
its members—including the American Red Cross—emphasize the
importance of disaster relief organizations having external evaluations
and disseminating the results publicly. Such evaluations ensure that
stakeholders, including funding agencies and private donors, have access
to independent information on projects’ effectiveness and efficiency. 62
Similarly, GAO’s standards for auditing the performance of federal
agencies require auditors to be independent, defined as being free of
influences that compromise professional judgment and able to exercise
objectivity and professional skepticism. 63 In addition, external evaluation

60

GAO-05-561T.

61

Independent Sector, Panel on the Nonprofit Sector, Strengthening Transparency,
Governance, and Accountability of Charitable Organizations (Washington, D.C.: June
2005), and Principles for Good Governance and Ethical Practice: A Guide for Charities
and Foundations (Washington, D.C.: Oct. 2007).

62

International Federation of Red Cross and Red Crescent Societies, IFRC Framework
for Evaluation (Geneva, Switzerland: Feb. 2011).

63

GAO, Government Auditing Standards, GAO-12-331G (Washington, D.C.: December
2011).

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 of the Red Cross’s performance in disasters may be especially important
given its critical role in the nation’s disaster response system. Federal
internal control standards state that federal agencies should identify and
analyze the relevant risks associated with achieving their objectives and
form a basis for determining how risks should be managed. 64 Federal
agencies, in particular FEMA, are responsible for coordinating and
supporting the response to major disasters and rely significantly on the
Red Cross to ensure the well-being of citizens.
The public’s and the federal government’s need for independent
evaluation of the Red Cross’s performance in providing disaster
assistance takes on added significance given previous questions raised
by members of Congress, GAO, and others about the organization’s
ability to respond effectively to large disasters. Following Hurricane
Katrina and Hurricane Rita in 2005 along the Gulf Coast, a congressional
investigation and several GAO reports identified a range of issues with
Red Cross’s response to the disaster. 65 One concern was that the Red
Cross was not prepared to meet the disasters’ unprecedented sheltering
needs, in part because some areas—particularly rural areas—lacked
local chapters or the Red Cross was not offering services in those areas.
Furthermore, the Red Cross was criticized for having weak relationships
with faith-based and other community groups that stepped in during the
hurricanes to help disaster victims, and there were concerns that the Red
Cross’s assistance was late in arriving for certain subpopulations, such as
people with disabilities. Additionally, disaster relief personnel from other
countries who worked in the affected areas during the early weeks of the
Katrina response said many Red Cross volunteers were given relief
duties for which they were not trained or certified. 66 More recently, after
Hurricane Sandy struck a number of states on the east coast in 2012,
64

AIMD-00-21.3.1.

65

GAO, Catastrophic Disasters: Enhanced Leadership, Capabilities, and Accountability
Controls Will Improve the Effectiveness of the Nation’s Preparedness, Response, and
Recovery System, GAO-06-618 (Washington, D.C.: Sept. 6, 2006); GAO-06-712;
GAO-08-369; GAO-08-823; and Emergency Management: Actions to Implement Select
Provisions of the Post-Katrina Emergency Management Reform Act, GAO-09-433T
(Washington, D.C.: Mar. 17, 2009). United States Senate Committee on Homeland
Security and Governmental Affairs, Hurricane Katrina: A Nation Still Unprepared
(Washington, D.C.: 2006).
66

M. Goodhand, “Mission Report, Hurricane Katrina, 2005,” British Red Cross (Sept. 14,
2005) and Thomas Riess, “Mission Report Montgomery + Mobile Alabama – Hurricane
Katrina,” International Committee of the Red Cross (Sept. 28, 2005).

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 media reports raised concerns about the efficiency of the Red Cross’s
response. 67
Metrics exist for assessing disaster assistance performance. For
example, the Urban Institute has a set of potential indicators that service
providers and researchers can use when evaluating disaster response
activities. 68 These include indicators of the outcomes for disaster victims,
such as the percentage experiencing a shortage of medicine, and
indicators of the quality of services, such as the amount of time elapsed
until a service is provided. In addition, the Sphere Project, an initiative of
humanitarian nongovernmental organizations and the International Red
Cross and Red Crescent Movement, has developed a set of detailed
standards for the provision of disaster assistance. 69 These cover, for
example, the minimum amount of water that populations should be
provided daily and the maximum distance from food supplies. They are
designed to assist nonprofits in planning, implementing, monitoring, and
evaluating their disaster response services. Finally, the IFRC’s evaluation
guide for evaluating humanitarian assistance includes measures such as
effectiveness, defined as the extent to which the project met its objectives
in areas such as timeliness of service delivery and coordination with other
agencies and groups; efficiency, defined as the cost effectiveness of
service delivery; and impact, defined as the longer-term positive and
negative changes resulting from the project.
The Inspector General at the Department of Homeland Security (DHS)
has conducted performance audits of FEMA’s response to specific

67

David Halbfinger, “Anger Grows at Response by Red Cross,” The New York Times,
Nov. 2, 2012. David Caruso and Jennifer Peltz, “Red Cross: Over $100 million in Sandy
Aid Still Unspent,” Associated Press, appearing in the Christian Science Monitor, May 28,
2013. Justin Elliott, Jesse Eisinger, and Laura Sullivan, The Red Cross’ Secret Disaster,
ProPublica and National Public Radio, Oct. 29, 2014, and The Red Cross CEO Has Been
Serially Misleading About Where Donors’ Dollars Are Going, ProPublica and National
Public Radio, Dec. 4, 2014. The Red Cross has responded to ProPublica’s reports, for
example in press releases dated October 28, 2014 (American Red Cross Comments on
ProPublica Report) and December 11, 2014 (American Red Cross Response to Latest
ProPublica Allegations).

68

H. Hatry, M. Abravanel, and S. Rossman, What Happens to Victims? A Research Guide
for Disaster Response Studies. Urban Institute (Washington, D.C.: Mar. 2006).

69

The Sphere Project, Humanitarian Charter and Minimum Standards in Humanitarian
Response (Rugby, U.K.: 2011). The Movement includes both the IFRC and the
International Committee of the Red Cross.

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 disasters, providing concrete examples of how disaster assistance can be
evaluated. 70 Several audits conducted in recent years have assessed the
effectiveness, efficiency, or appropriateness of FEMA’s response efforts,
and in at least one case their impact on disaster victims. The audits have
relied on methods such as interviews with FEMA and local officials and
observations of FEMA activities or the affected areas. For example, the
IG issued an audit of FEMA’s response to Hurricane Sandy in New York
that found, among other things, that the agency effectively prepared for
the storm by proactively deploying staff to regional operation centers, and
effectively met victims’ housing needs in an area with scarce traditional
shelters through alternative options. 71 In an audit of FEMA’s response to
floods in Galena, Alaska, the IG found that the agency’s decision to
construct permanent housing for victims was appropriate given the
circumstances, but that FEMA delayed providing other types of
assistance which had an adverse effect on victims in the remote areas
affected by the disaster. 72 The DHS IG’s mission is limited to auditing and
investigating DHS’s programs and operations, and generally does not
include auditing the Red Cross’s performance in disasters. However,
GAO has noted in prior work that while significant federal programs and
agencies should be subject to oversight by their own independent IG
offices, it may be appropriate and cost effective for smaller agencies to
obtain oversight from another agency’s IG when the missions of the two

70

IGs have investigative and audit authority and can recommend policies to promote
economy, efficiency, and effectiveness, and to prevent and detect fraud and abuse. GAO,
Inspectors General: Reporting on Independence, Effectiveness, and Expertise,
GAO-11-770 (Washington, D.C.: Sept. 21, 2011).

71

Department of Homeland Security Office of Inspector General, FEMA’s Initial Response
in New York to Hurricane Sandy, OIG-13-124 (Washington, D.C.: Sept. 26, 2013).

72

Department of Homeland Security Office of Inspector General, FEMA’s Response to
the Disaster in Galena, Alaska, OIG-14-106-D (Washington, D.C.: June 17, 2014).

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 agencies are similar. 73 Furthermore, certain organizations that rely on a
mix of federal and private funding sources are subject to IG oversight. 74

Conclusions

The nation’s disaster response system relies to a significant extent on the
nonprofit sector, which harnesses the public’s generosity to provide
funding for disaster response and recovery efforts. This approach can
support the nation’s efforts to assist disaster victims, but it also has
limited accountability for disaster assistance. The Red Cross, the
organization most responsible for providing shelter and other mass care
services to disaster victims, exemplifies this tension. It has been
designated by law as an instrumentality of the United States and has a
critical, formalized role in coordinating and providing disaster response
services across the nation. At the same time it remains a nonprofit
organization that generally makes its own decisions about what services
to provide. This reliance on an independent organization can be effective
if government and the donating public have confidence that Red Cross is
providing the services that are most needed in an effective and efficient
manner. Further, in disasters in which the federal government is involved,
the extent and effectiveness of the Red Cross’s activities could have a
direct impact on the nature and scope of the federal government’s
activities.
With regard to oversight, while the Red Cross has some internal
evaluation processes in place, such as after action reviews and surveys
of state emergency managers and other stakeholders, Red Cross officials
told us that the results of their internal evaluations are typically not made
available to the general public. The absence of regular, external
evaluations of its disaster services that are publicly disseminated could
affect the confidence of both the donating public and the federal agencies
that rely on the Red Cross. This is especially true in light of questions
73

For example, the Environmental Protection Agency’s IG has provided oversight of the
Chemical Safety and Hazard Investigation Board since 2004. GAO, Inspectors General:
Oversight of Small Federal Agencies and the Role of the Inspectors General,
GAO-14-503T (Washington, D.C.: Apr. 10, 2014).

74

Examples include the Denali Commission, which provides economic development
services in rural Alaska and is funded by, among other things, annual appropriations to the
commission and gifts and donations from non-federal entities; and the Smithsonian
Institution, which relies on private funding sources and business activities for about onethird of its annual budget. See GAO-11-770 for listings of federal departments, agencies,
and offices with an IG.

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 raised by the federal government and others in recent years about the
organization’s performance in disasters. Given the Red Cross’s status as
an instrumentality of the United States and the critical responsibilities
assigned to it by its federal charter and by federal policies, the federal
government has a clear stake and role in ensuring that proper oversight
takes place.

Matter for
Congressional
Consideration

To maintain governmental and public confidence in the Red Cross,
Congress should consider establishing a federal mechanism for
conducting regular, external, independent, and publicly disseminated
evaluations of the Red Cross’s disaster assistance services in domestic
disasters in which the federal government provides leadership or support.
This mechanism might involve annual evaluations of whether the services
achieved their objectives or of their impact on disaster victims. This
evaluation could be performed, for example, by a federal agency such as
DHS, by an IG office such as the DHS IG, or by a private research firm
under contract to a federal agency.

Agency Comments
and Our Evaluation

We provided a draft of this report to the Red Cross and FEMA for review
and comment, and provided relevant excerpts to DOD, GSA, IRS, the
State Department, and USAID. See appendix II for the Red Cross’s
written comments and appendix III for FEMA’s written comments. We
also received technical comments from the Red Cross, FEMA, GSA, IRS,
the State Department, and USAID, and made changes to the report as
appropriate.
In its written comments, the Red Cross said it agrees there is value in
systematic evaluation of its service delivery in domestic disasters where
the federal government provides leadership or support. The Red Cross
also said it is open to participating in additional reviews or evaluation
activities convened by FEMA or other government partners. However, it
emphasized its status as a private, nonprofit organization that is
independent from the federal government, and stated that it believes its
existing governance structure and evaluation mechanisms are
appropriate given its nonprofit status. The Red Cross noted, for example,
that the American National Red Cross Governance Modernization Act of
2007 made changes to its governance structure intended to reflect
modern standards for nonprofit governance; that it has internal evaluation
procedures in place such as surveying clients and other stakeholders and

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 conducting after action reviews; and that it shares information about its
disaster services with Members of Congress and their staff.
We recognize that the Red Cross relies on private donations rather than
federal funds to support the vast majority of its disaster services, and that
its governance and internal evaluation efforts may identify and address
some service delivery issues. However, the federal government has a
unique interest in ensuring the Red Cross assists disaster victims
effectively and efficiently, given the disaster relief duties assigned by its
federal charter and its special role in the nation’s disaster response
system. Only performance evaluations that are independent, federally led
or supported, and publicly disseminated can give the federal government
and donors assurance that the Red Cross is fulfilling its mission
effectively and efficiently and addressing any service delivery challenges.
Our draft report contained a recommendation to the Administrator of
FEMA to work with the Red Cross to revise their 2010 memorandum of
agreement so that it clearly defines the Red Cross’s roles and
responsibilities in the recovery phase of disaster relief. In its comments,
FEMA agreed with this recommendation and said it expected the updated
agreement to be finalized by Sept. 30, 2015. FEMA subsequently
informed us that the updated agreement was signed in July and provided
us with a copy of the updated agreement. We reviewed the updated
agreement and determined that it addresses Red Cross’s roles and
responsibilities in the recovery phase as envisioned by our
recommendation. As a result, we deleted the recommendation from our
final report.
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies of this report to appropriate
congressional committees, the President and Chief Executive Officer of
the Red Cross, the Administrator of FEMA, and other interested parties.
In addition, this report will also be available at no charge on GAO’s
website at http://www.gao.gov.

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GAO-15-565 American Red Cross

 If you or your staff have any questions about this report, please contact
me at (202) 512-7215 or sherrilla@gao.gov. Contact points for our Offices
of Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff members who made key contributions to
this report are listed in appendix IV.

Andrew Sherrill
Director, Education, Workforce, and Income Security Issues

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GAO-15-565 American Red Cross

 Appendix I: Emergency Support Functions
(ESF) and Recovery Support Functions
(RSF) that Include the Red Cross
Appendix I: Emergency Support
Functions (ESF) and Recovery
Support Functions (RSF) that
Include the Red Cross

ESFs for which the Red Cross is included
ESF Annex Number, Name, and Lead Entities

Red Cross’s Key Designated Functions

ESF #5 – Information and Planning
Coordinator: Federal Emergency Management Agency (FEMA)
Primary Agency: FEMA

As a support agency, the Red Cross (along with all
departments and other agencies) is to share critical
incident information and participate in planning efforts.

ESF #6 – Mass Care, Emergency Assistance, Temporary Housing,
and Human Services
Coordinator: FEMA
Primary Agencies:
FEMA and Red Cross

Acts as both co-lead for the mass care component of this
ESF and a support agency for the other components of the
ESF. As co-lead, Red Cross:
— Works with FEMA to identify mass care capacity,
anticipate mass care needs, and establish strategies to
address gaps in coordination with government agencies at
all levels, NGOs, and private sector partners.
— Serves as FEMA’s principal mass care subject matter
expert and provides mass care technical assistance.
— Provides disaster relief and preparedness information to
the public.
As a support agency and service provider, Red Cross
works with government, NGO, and private sector entities to
provide services to disaster survivors, including sheltering,
feeding, and distribution of emergency supplies.

ESF #7 – Logistics
Coordinators: General Services Administration (GSA) and FEMA
Primary Agencies: GSA and FEMA

As a support agency, the Red Cross provides support to
develop a logistics supply chain across the whole affected
community by synchronizing pre-disaster planning
activities and coordinating during responses to major
disasters.

ESF #8 – Public Health and Medical Services
Coordinator: Department of Health and Human Services (HHS)
Primary Agency: HHS

As a support agency, the Red Cross:
— Provides for disaster-related health and behavior health
needs through direct services and/or referrals.
— Supplies information to requesting agencies, including
mortality and morbidity and behavioral health trends.
— Provides services and personnel for evacuation efforts,
health facilities, nursing homes, and morgues.
— Coordinates, as HHS requests, blood and services
through regional blood centers.

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GAO-15-565 American Red Cross

 Appendix I: Emergency Support
Functions (ESF) and Recovery
Support Functions (RSF) that
Include the Red Cross

ESF #11 – Agriculture and Natural Resources
Coordinator: Department of Agriculture
Primary Agencies: Departments of Agriculture and Interior

As a support agency, the Red Cross:
— Identifies and assesses requirements for food and
distribution immediately after a disaster and longer-term
needs.
— Coordinates with other voluntary organizations in the
distribution of food.
— Coordinates with organizations providing emergency
animal sheltering so people can help care for their own
animals.
— Provides feeding and other mass care support to
animal and agricultural responders when requested.

ESF # 15 – External Affairs
Coordinator: Department of Homeland Security (DHS)
Primary Agency: FEMA

As a support agency, Red Cross coordinates disaster
messaging with federal communicators and provides
disaster relief and preparedness information to the public
through proactive media outreach, its website, and social
media.

RSFs for which the Red Cross is included
RSF Annex Number, Name, and Lead Entities

Red Cross’s Key Designated Functions

Health and Social Services
Coordinator: HHS
Primary Agencies: Corporation for National and Community Service,
FEMA, and Departments of Interior, Justice, Labor, Education, and
Veterans Affairs

As a supporting organization, the Red Cross is to work
with the primary organizations and other supporting
organizations to help support the recovery of public health,
health care, and social services infrastructure.

Housing
Coordinator: Department of Housing and Urban Development (HUD)
Primary Agencies: FEMA, Departments of Justice, HUD, and
Agriculture.

As a supporting organization, the Red Cross is to work
with the primary organizations and other supporting
organizations to help disaster survivors and others who
choose to live in recovering communities transition from
shelters or other areas into permanent housing.

Source: FEMA.   GAO-15-565

Note: The Red Cross is also included as a supporting organization under the Community Planning
Capacity Building RSF. However, a formal document laying out the key functions of the partner
organizations had not been finalized at the time of our review.

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GAO-15-565 American Red Cross

 Appendix II: Comments from the American
Red Cross
Appendix II: Comments from the American Red
Cross

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GAO-15-565 American Red Cross

  

Appendix II: Comments from the American Red
Cross

 

 

 

Page 2 of 5
Mr. Andrew Sherrill
July 10, 2015

respond to disasters and has been identi?ed as a federal instrumentality, we remain
independent and autonomous in accordance with the fundamental principles of the Red Cross
Red Crescent Movement to which the U.S. Government has ascribed for ?fty years.

Coordination with the Federal Government on Domestic Disasters

The American Red Cross works closely with local, state, and federal government
agencies and of?cials to plan, prepare for and respond to disasters. We have an extensive
network of chapters and disaster personnel that coordinate with state and local emergency
management and public health agencies, among others, to identify the community?s disaster-
related needs and make plans to ensure the needed services and resources are available.

At the federal level, the Red Cross?s coordination with FEMA and other federal
agencies is extensive and effective with reSpect to disaster responsc and, of special note, with
respect to recovery as well. The framework for this Red Cross coordination is described in
federal planning documents, including:

the National Response Framework,

- the Emergency Support Function Annexes (in particular ESF 6, which details
the Red Cross?s leadership role in mass care in a Presidentially?declared
disaster),

0 the National Disaster Recovery Framework,

0 the Recovery Support Function Annexes, and

the Federal Interagency Operational Plans.

The framework for the Red Cross?s coordination with FEMA is also described in a
Memorandum of Agreement. A new, updated version of the Memorandum of Agreement,
which elaborates on how the Red Cross and FEMA coordinate in a disaster?s recovery phase,
will go into effect when the 2010 version expires on July 31, 2015.

The Red Cross?s coordination with FEMA and other federal agencies is not simply a
function of written agreements, however. More important is the way we work together every
day. The Red Cross and FEMA maintain excellent communication at all levels to ensure that
the activities of the Red Cross and FEMA are in alignment and in the best interest of the
American people. For example:

0 The Red Cross is an integral part of the Emergency Support Function
Leadership Group and Recovery Support Function Leadership Group, both of
which meet on a basis to conduct exercises and address critical areas
of support and coordination.

0 During a disaster response the Red Cross assigns liaison of?cers to all federal
operations centers to coordinate with the ESFs and RSFs,

 

Page 44 GAO-15-565 American Red Cross

 

 

Appendix II: Comments from the American Red
Cross

 

 

 

Page 3 of 5
Mr. Andrew Sherrill
July 10, 2015

0 Red Cross and FEMA share shelter information and other service delivery
data.

Evaluation of Red Cross?s Disaster Assistance Services in Domestic Disasters

The Red Cross agrees with the GAO that a systematic approach to evaluating our
service delivery in domestic disasters where the federal government provides leadership or
support can help us to improve such services. In fact, during the past few years the Red Cross
has revamped its evaluation process to generate more meaningful, metrics~based, and regular
information about our domestic disaster services. Performance evaluation and improvement
mechanisms are embedded in the organization design. The Red Cross also does the
following:

conducts surveys of the people we help, Red Cross workers (including
volunteers), and government and non- government partners, such as state and
local emergency management agencies;

0 conducts after-action reviews; and

participates in after?action reviews convened by government partners.

We are always open to suggestions about how to make our evaluations more robust, relevant,
and constructive. We would welcome additional opportunities to participate in assessments
and after?action reviews conducted by our state and federal partners.

The Red Cross has a long-standing practice of sharing information about our disaster
services with Members of Congress and their staff throughout all phases of the disaster cycle,
and we intend to continue this practice. We engage with Congress by providing brie?ngs and
written reports on our activities, assisting with services for constituents as requested by
Congressional offices, testifying before Congressional committees when requested, and
meeting with individual Members of Congress and their staff in Washington, DC. and in their
home states and districts. During a disaster response we provide Members of Congress with
regular updates about our operations in their communities.

The Red Cross governance structure is designed to ensure that the organization uses its
donated resources to effectively and ef?ciently accomplish its mission. In 2007 Congress
passed the American Red Cross Modernization Act which made signi?cant changes to the
Red Cross Charter to re?ect modern standards for the governance of non-pro?t corporations.
As noted in the House of Representatives? Foreign Affairs Committee report accompanying
the Modernization Act, the changes brought about by the Act ?will undoubtedly help promote
the kind of leadership necessary to make Red Cross management and [disaster response]

 

Page 45 GAO-15-565 American Red Cross

 

 

Appendix II: Comments from the American Red
Cross

 

 

 

Page 4 of 5
Mr. Andrew Sherrill
July 10, 2015

operations run more smoothly.?2 Among other things, the 2007 Modernization Act:

I rede?ned the role of the Board of Governors, so that the Board of Governors is
responsible for overseeing the management of the corporation;
0 created the Of?ce of the Ombudsman, which reports directly to the Chief Executive
Of?cer and submits an annual report to 10 Congressional committees:
0 Senate Committee on Finance;
Senate Committee on Foreign Relations;
Senate Committee on Health, Education, Labor, and Pensions;
Senate Committee on Homeland Security and Governmental Affairs;
Senate Committee on the Judiciary;
House Committee on Energy and Commerce;
House Committee on Foreign Affairs;
HOuse Committee on Homeland Security;
House Committee on the Judiciary;
0 House Committee on Ways and Means; and
0 established that the GAO may review the Red Cross?s involvement in any federal
program or activity the Government carries out under law.



Other important elements of Red Cross governance include:

0 Board of Governors that, under the Bylaws, is comprised entirely of independent
members;

a Board of Governors Audit and Risk Management Committee;

annual audit by an external auditor (currently 

review of the annual audit by the Department of Defense;

Red Cross?s Internal Audit Department, led by the Chief Audit Executive;

0 Red Cross?s Of?ce of Investigations, Compliance and Ethics; and

- annual submission of a 990 tax return to the Internal Revenue Service.

Detailed information about the Red Cross?s governance (including copies of our
Congressional Charter, Bylaws, annual financial statements, 990 tax returns, and Ombudsman
reports) is available on our website, Also available on our website are
publications about our activities in major disasters, how we spend donations, and other topics.

We believe the Red Cross?s existing governance structure and evaluation mechanisms
are appropriate for a private, 501(c)(3) charitable organization. At the same time, we would
be happy to participate in additional reviews and evaluation activities convened by FEMA and
other government partners.

 

2 House Report 110-87 (April 16, 2007)

 

Page 46 GAO-15-565 American Red Cross

 

 

Appendix II: Comments from the American Red
Cross

 

 

 

Page 5 of 5
Mr. Andrew Sherrill
July 10, 2015

We hope that these comments provide helpful context for the ?ndings and
recommendations.

Sincerely,

b? w! Pmrok

Lori Polacheck
Associate General Counsel

 

Page 47 GAO-15-565 American Red Cross

 

Appendix III: Comments from the Federal
Emergency Management Agency
Appendix III: Comments from the Federal
Emergency Management Agency

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GAO-15-565 American Red Cross

 Appendix III: Comments from the Federal
Emergency Management Agency

Page 49

GAO-15-565 American Red Cross

 Appendix IV: GAO Contact and Staff
Acknowledgments
Appendix IV: GAO Contact and Staff
Acknowledgments

GAO Contact

Andrew Sherrill (202) 512-7215 or sherrilla@gao.gov

Staff
Acknowledgments

In addition to the contact named above, Scott Spicer (Assistant Director),
Lorin Obler (Analyst-in-Charge), Jessica Botsford, Peter Del Toro, Helen
Desaulniers, Holly Dye, Charles Fox, Amanda Goolden, Leslie Holen,
Kathy Leslie, David Lysy, Sheila McCoy, Walter Vance, Sarah Veale, and
Paul Wright made key contributions to this report.

Page 50

GAO-15-565 American Red Cross

 Related GAO Products
Related GAO Products

Tax-Exempt Organizations: Better Compliance Indicators and Data, and
More Collaboration with State Regulators, Would Strengthen Oversight of
Charitable Organizations, GAO-15-164 (Washington, D.C.: Dec. 17,
2014).
Emergency Preparedness: Opportunities Exist to Strengthen Interagency
Assessments and Accountability for Closing Capability Gaps, GAO-15-20
(Washington, D.C.: Dec. 4, 2014).
Inspectors General: Oversight of Small Federal Agencies and the Role of
the Inspectors General, GAO-14-503T (Washington, D.C.: Apr. 10, 2014).
Managing for Results: Key Considerations for Implementing Interagency
Collaborative Mechanisms, GAO-12-1022 (Washington, D.C.: Sept. 27,
2012).
Disaster Relief: Reimbursements to the American Red Cross for Certain
2008 Disaster Assistance, GAO-12-877 (Washington, D.C.: Sept. 14,
2012).
Inspectors General: Reporting on Independence, Effectiveness, and
Expertise, GAO-11-770 (Washington, D.C.: Sept. 21, 2011).
Hurricane Recovery: Federal Government Provided a Range of
Assistance to Nonprofits following Hurricanes Katrina and Rita,
GAO-10-800 (Washington, D.C.: July 30, 2010).
Disaster Recovery: FEMA’s Long-term Assistance Was Helpful to State
and Local Governments but Had Some Limitations, GAO-10-404
(Washington, D.C.: Mar. 30, 2010).
Emergency Management: Actions to Implement Select Provisions of the
Post-Katrina Emergency Management Reform Act, GAO-09-433T
(Washington, D.C.: Mar. 17, 2009).
Voluntary Organizations: FEMA Should More Fully Assess Organizations’
Mass Care Capacities and Update the Red Cross Role in Catastrophic
Events, GAO-08-823 (Washington, D.C.: Sept. 18, 2008).
National Disaster Response: FEMA Should Take Action to Improve
Capacity and Coordination between Government and Voluntary Sectors,
GAO-08-369 (Washington, D.C.: Feb. 27, 2008).

Page 51

GAO-15-565 American Red Cross

 Related GAO Products

Hurricanes Katrina and Rita: Coordination between FEMA and the Red
Cross Should Be Improved for the 2006 Hurricane Season, GAO-06-712
(Washington, D.C.: June 8, 2006).
Catastrophic Disasters: Enhanced Leadership, Capabilities, and
Accountability Controls Will Improve the Effectiveness of the Nation’s
Preparedness, Response, and Recovery System, GAO-06-618
(Washington, D.C.: Sept. 6, 2006).
Disaster Relief: Reimbursements to American Red Cross for Hurricanes
Charley, Frances, Ivan, and Jeanne, GAO-06-518 (Washington, D.C.:
May 30, 2006).

(131297)

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GAO-15-565 American Red Cross

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