We recommend the FEMA Administrator ensure the EFSP National Board implements oversight measures to enforce the American Rescue Plan Act of 2021 Humanitarian Relief Funding and Application Guidance for future supplemental appropriations. Specifically, develop a risk-based methodology to review a sample of ongoing funding execution for future supplemental appropriations to ensure funds approved are: reviewed and reconciled for completeness and accuracy; and  supported with appropriate documentation, including rosters or other documentation for the number of people served.