1. FEMA Public Assistance Program
FEMA Region III – Philadelphia
Will Blair
Senior Emergency Management Program Specialist
(215)

2. FEMA Public Assistance Grant Program
Eligible Applicants:
State and Local governments
Certain Private Nonprofit entities
Grant award program to provide supplemental assistance to reimburse reasonable costs associated with completing eligible work.

3. CATEGORIES OF WORK Emergency – 6 Months Permanent – 18 Months
A - Debris Removal
B - Emergency Protective Measures
Permanent – 18 Months
C - Roads & Bridges
D - Water Control Facilities
E - Buildings & Contents
F - Utilities
G - Other (Parks, Recreation etc.)
Under Emergency Work, there are two (2) categories:
Category A Debris Removal
Category B Emergency Protective Measures
Work must be completed within six (6) months of the declaration date. Work PERFORMED to reduce or eliminate immediate threat to life, protect public health & safety, and to protect improved property.
Under Permanent work there are five (5) categories:
Category C Roads and Bridges
Category D Water Control Facilities
Category E Buildings and Equipment
Category F Utilities
Category G Parks, Recreation and Other
Permanent Work – Work required to restore a damaged facility to pre-disaster condition. Must be completed within 18 months of declaration.
PA Guide Pages 66-87
FEMA Public Assistance Eligibility & Grants Management

4. COST Types of Direct Costs: Force Account (your resources):
Labor
Equipment
Materials
Contract Costs (outside resources)
An area where there may be a large expense for reimbursement are:
DIRECT COSTS, which are:
Labor
Equipment
Materials
Contract Costs
PA Guide Page 40
FEMA Public Assistance Eligibility & Grants Management

5. CONTRACT ELIGIBILITY CONTRACTS eligibility: REASONABLE and NECESSARY
Competitively procured – follow VA Procurement Act and state, local, federal procurement procedures
NOT CONTINGENT on FEMA funding
Now let’s talk about FEMA’s procurement policies …
FEMA Public Assistance Eligibility & Grants Management

6. Process key elements: Cost Analysis
COST CONTRACTS
Process key elements:
Reasonable for clearly defined ‘Scope of Work’
Competitively Procured
Qualifications of proposers/bidders
Not contingent on FEMA funding
Comply w/Federal, State and Local procedures
Ex: VA Procurement Act
Cost Analysis
CONTRACTS eligibility:
REASONABLE and NECESSARY
Competitively procured – follow VA Procurement Act and state, local, federal procurement procedures
NOT CONTINGENT on FEMA funding
Now let’s talk about FEMA’s procurement policies …
FEMA Public Assistance Eligibility & Grants Management

7. DOCUMENTATION! To include: COST CONTRACTS Procurement Process
Rationale – Selections/Decisions
Processes, inspections, payment, etc.
CONTRACTS eligibility:
REASONABLE and NECESSARY
Competitively procured – follow VA Procurement Act and state, local, federal procurement procedures
NOT CONTINGENT on FEMA funding
Now let’s talk about FEMA’s procurement policies …
FEMA Public Assistance Eligibility & Grants Management

8. Full and Open Competition:
COST CONTRACTS
Full and Open Competition:
Requirement - Intended for all procurements
Stimulates better, lower prices
Pre-qualifying – non-emergency periods
Avoid restricting competition
ACCEPTABLE PROCUREMENT METHODS:
Reminder – Reasonable, competitive & comply w/laws, etc.
SMALL PURCHASE – informal method – not a large amount For FEMA < $100,000 – VA or your policy may be less
Obtain several bids
Ex: for services or supplies
SEALED BIDS – formal method – Publicly advertised and solicited – Contract awarded to lowest bidder
Ex: construction
COMPETITIVE PROPOSALS – similar to Sealed Bids – awarded on basis of QUALIFICATIONS
Ex: engineering
NONCOMPETITIVE PROPOSALS – Only one source bid
ONLY used when one of above is not feasible
When is noncompetitive proposals eligible…
PA Guide page
FEMA Public Assistance Eligibility & Grants Management

9. Cost or price analysis Required for ALL procurement actions
COST CONTRACTS
Cost or price analysis
Required for ALL procurement actions
Including amendments/change orders
Tests REASONABLENESS
Independent estimates
ACCEPTABLE PROCUREMENT METHODS:
Reminder – Reasonable, competitive & comply w/laws, etc.
SMALL PURCHASE – informal method – not a large amount For FEMA < $100,000 – VA or your policy may be less
Obtain several bids
Ex: for services or supplies
SEALED BIDS – formal method – Publicly advertised and solicited – Contract awarded to lowest bidder
Ex: construction
COMPETITIVE PROPOSALS – similar to Sealed Bids – awarded on basis of QUALIFICATIONS
Ex: engineering
NONCOMPETITIVE PROPOSALS – Only one source bid
ONLY used when one of above is not feasible
When is noncompetitive proposals eligible…
PA Guide page
FEMA Public Assistance Eligibility & Grants Management

10. Accepted Procurement Methods:
COST CONTRACTS
Accepted Procurement Methods:
Small Purchase
Sealed Bid
Competitive proposals
Non-competitive proposals
ACCEPTABLE PROCUREMENT METHODS:
Reminder – Reasonable, competitive & comply w/laws, etc.
SMALL PURCHASE – informal method – not a large amount For FEMA < $100,000 – VA or your policy may be less
Obtain several bids
Ex: for services or supplies
SEALED BIDS – formal method – Publicly advertised and solicited – Contract awarded to lowest bidder
Ex: construction
COMPETITIVE PROPOSALS – similar to Sealed Bids – awarded on basis of QUALIFICATIONS
Ex: engineering
NONCOMPETITIVE PROPOSALS – Only one source bid
ONLY used when one of above is not feasible
When is noncompetitive proposals eligible…
PA Guide page
FEMA Public Assistance Eligibility & Grants Management

11. Accepted Procurement Methods (cont’d):
COST CONTRACTS
Accepted Procurement Methods (cont’d):
Non-competitive proposals:
Item available only from a single source
Emergency requirement which will not permit a delay – Very Limited in duration
FEMA authorizes a noncompetitive proposal
Solicitations attempted - Competition is determined inadequate
When acceptable:
Only one source available
FEMA authorizes noncompetitive proposal
Emergency requirement – delay not permitted
Contacted various sources – but no response
PIGGYBACK contracting – concept of expanding a previously awarded contract
- Typically not eligible – does not meet 44 CFR requirements
This is not competitive and price structure may be inappropriate
BE CAREFUL – ENSURE FEMA ELIGIBLE
PA Guide page 23
FEMA Public Assistance Eligibility & Grants Management

12. COST Procurement of Contracts
3 Types of Contracts FEMA will reimburse:
Lump Sum - defined scope
Unit Price – itemized work
Cost plus fixed fee – lump sum or unit price WITH a fixed contractor fee
THREE types of CONTRACTS:
LUMP SUM – work within a prescribed boundary
Clearly defined Scope of Work and a TOTAL PRICE
UNIT PRICE – Work done on an item-by-item basis with cost determined per unit
COST PLUS FIXED FEE – Either Lump Sum OR Unit Price Contract WITH A Fixed contractor fee added into price
NOT ELIGIBLE
Cost plus a percentage of cost
PA Guide page 53
FEMA Public Assistance Eligibility & Grants Management

13. COST Procurement of Contracts
NOT ELIGIBLE
Cost plus a percentage of contracts
Piggyback Contracting – not competitive / price structure may vary
Contingency
THREE types of CONTRACTS:
LUMP SUM – work within a prescribed boundary
Clearly defined Scope of Work and a TOTAL PRICE
UNIT PRICE – Work done on an item-by-item basis with cost determined per unit
COST PLUS FIXED FEE – Either Lump Sum OR Unit Price Contract WITH A Fixed contractor fee added into price
NOT ELIGIBLE
Cost plus a percentage of cost
PA Guide page
FEMA Public Assistance Eligibility & Grants Management

14. COST Procurement of Contracts
Time and Materials
SHOULD BE AVOIDED
Emergency Work ONLY
Typically not more than 70 hours - immediately following a disaster
Must be Reasonable
Must contact State for guidelines
TIME and MATERIALS
Should be avoided
LIMITED PERIOD typically - < 70 hours – during incident period – right after event
MUST BE:
Monitored closely
Clearly defined SCOPE of WORK
Included with a Cost Ceiling – ‘NOT TO EXCEED’ clause
Example: Removing tree hangers
BUT only if UNIT PRICE contract not available
If used applicant – should contact State to ensure proper guidelines are met
PA Guide page 53
FEMA Public Assistance Eligibility & Grants Management

15. COST Procurement of Contracts
Time and Materials
Must:
Include a ‘Scope of Work’
Note: As good as can be developed at the time
Be DOCUMENTED
Be closely monitored
Include a Cost Ceiling
– ‘Not to exceed’ clause must be included
TIME and MATERIALS
Should be avoided
LIMITED PERIOD typically - < 70 hours – during incident period – right after event
MUST BE:
Monitored closely
Clearly defined SCOPE of WORK
Included with a Cost Ceiling – ‘NOT TO EXCEED’ clause
Example: Removing tree hangers
BUT only if UNIT PRICE contract not available
If used applicant – should contact State to ensure proper guidelines are met
PA Guide page 53
FEMA Public Assistance Eligibility & Grants Management

16. Ensure Procurement Process includes:
PROCUREMENT REVIEW
Ensure Procurement Process includes:
A clearly defined SCOPE OF WORK
Following of the VA Procurement Act & FEMA’S policy
Documenting of all processes for proposals or bids
All contracts include a maximum fixed cost (no open ended contracts)
Competitive bidding
(continued)
CONTRACTS is an area where FEMA reimbursement may be impacted or lost.
Therefore, let’s review a few items …
FEMA Public Assistance Eligibility & Grants Management

17. Ensure Procurement Process includes: (con’t)
PROCUREMENT REVIEW
Ensure Procurement Process includes: (con’t)
“Emergency Procurement” typically limited to the first 70 hours
Use written bid request as needed (fax or )
Contracts must include a termination for convenience clause
Contract amendments or modifications must be in writing
FEMA Public Assistance Eligibility & Grants Management

18. QUESTIONS?
VDEM - FEMA

19. Financial Management Grants/Cooperative Agreements
Grants Management Branch
FEMA Region 3
FEMA Public Assistance Eligibility & Grants Management

20. Basics of Financial Management
Accounting system with detailed chart of accounts
Proper documentation of expenditures
Appropriate time and activity reporting
Procedures to ensure costs are allowable
Written cost allocation plan
Regular review of budget to actual expenses
Strong system of internal controls
Written policies and procedures
Risk-based monitoring
Effective program management
FEMA Public Assistance Eligibility & Grants Management

21. Your Guide to Financial Management
44 Code of Federal Regulations Part 13
A-21 Cost Principles for Educational Institutions
A-87 Cost Principles for State, Local, and Indian Tribal Governments
A-102 Grants and Cooperative Agreements with State and Local Governments
A-110 Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
A-122 Cost Principles for Non-Profit Organizations
A-133 Audits of State, Local, Governments, and Non-Profit Organizations

22. Financial Management Systems
Standards contained in 44 CFR 13.20
State funding recipients must follow State laws and procedures
Allow for accurate, current, and complete disclosure of financial results
Maintain records that adequately identify source and application of funds
Maintain effective internal control and accountability
Adequately safeguard all property
Compare actual expenditures or outlays with budgeted amounts
The standards for financial management systems are contained in 44 CFR FEMA may review the adequacy of the CTC’s financial management system as part of a preaward review or at any time subsequent to the award.
State CTC funding recipients must expend and account for award funds in accordance with State laws and procedures for expending and accounting for their own funds.
FEMA Public Assistance Eligibility & Grants Management

23. Financial Management Systems
Federal Funding Recipients Must:
Ensure that applicable OMB cost principles and terms of award are followed
Maintain accounting records supported by source documentation
Implement procedures for minimizing time elapsing between transfer and disbursement of funds
Requirements for local and regional CTC funding recipients’ financial management systems (continued):
Ensure that applicable OMB cost principles and terms of the award are followed in determining the reasonableness, allowability, and allocability of costs (allowable costs are discussed later in this unit).
Maintain accounting records supported by source documentation such as cancelled checks, paid bills, payrolls, time and attendance records, contract award documents, etc.
Implement procedures for minimizing the time elapsing between transfer of funds from the U.S. Treasury and disbursement by the CTC funding recipient (this requirement applies to CTC funding recipients paid in advance of incurring the expense).
FEMA Public Assistance Eligibility & Grants Management

24. Revised Grant Guidelines
Federal
Grant Guidelines
Universities
States, Local, Indian Tribal Governments
Non-Profits
Hospitals
Administrative Requirements
§ 45 CFR 2543
§ 2 CFR 215 (formerly A-110)
§ 45 CFR 2541
OMB A-102
Cost Principles
§ 2 CFR 220 (formerly A-21)
§ 2 CFR 225 (formerly A-87)
§ 2 CFR 230 (formerly A-122)
§ 45 CFR 74
(HHS regulations)
Audit
Requirements *
OMB A-133
Notes:
CFR = Code of Federal Regulations
* = Organization is subject to A-133 if it expends more than $500,000 in Federal funds in its fiscal year
FEMA Public Assistance Eligibility & Grants Management

25. Cost Principles
Guidance for determining the allowable costs incurred by organizations
Federal awards bear their fair share of costs
Guidance about reimbursement requirements
Uniform standards of allowability and allocation
Consistency of treatment of costs
FEMA Public Assistance Eligibility & Grants Management

26. Allowable Costs
44 CFR specifies requirements for allowable costs
OMB Circular A-87 contains Federal principles for determining cost allowability
Standards of Allowability
Reasonable
Necessary
Allocable (Assignable)
Authorized and legal
Within cost limits
Treated consistently
Meets Cost Accounting Principles and Standards
Not double charged
Well documented
44 CFR specifies the requirements for allowable costs associated with the CTC award. Award funds may be used only for allowable costs of the funding recipient and cost-type subcontractors, including allowable costs in the form of payments to fixed-price subcontractors. Award funds may also be for reasonable fees or profit to cost-type subcontractors, but not any fee or profit (or other increment above allowable costs) to the funding recipient.
Attachment A of Circular No. A-87 covers general principles for determining allowable costs. The principles are for purposes of cost determination and are not intended to identify the circumstances or dictate the extent of FEMA financing of a particular project. In general, to be allowable under a CTC award, costs must meet several criteria, including:
Necessary and reasonable
Allocable to Federal awards
Consistent with other activities of funding recipient and accorded consistent treatment
Be determined using generally accepted accounting procedures
Cannot be included as a cost or cost-sharing match for other Federal awards
Be adequately documented
FEMA Public Assistance Eligibility & Grants Management

27. Reasonable Examples of costs described in OMB Circular A-87:
A cost is reasonable if, in its nature or amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costs
Examples of costs described in OMB Circular A-87:
= Compensation / Materials / Equipment / Monitoring
Advertising and public relations costs
Memberships, subscriptions, and professional activity costs
Recruiting costs
Rental costs
Training and education costs
Travel costs
FEMA Public Assistance Eligibility & Grants Management

28. A-87 Highlights Comingling of federal awards not permitted
Composition of Costs
No universal rule for classifying costs as direct/indirect under every accounting system
Indirect Costs
Common and joint purpose benefitting more than one cost objective - eg. goods, services, facilities
Cannot apply if assigned for any other purpose as direct
Interagency Services
May calculate actual indirect
Flat 10% standard for direct salary & wages

29. Payment Methods May be made in advance or as reimbursement
For advance payments, Grant funding recipient must minimize time elapsing between transfer and expenditure of funds
Any interest earned on advances must be refunded to FEMA
Two mechanisms for payments:
1. HHS Smartlink System
2. Direct Deposit/Electronic Funds Transfer (DD/EFT)
For CTCs that will be receiving FEMA awards for mapping activities, payments will be made in accordance with 44 CFR Payments may be made in advance or as a reimbursement after the expense has been incurred.
For advance payments, the CTC funding recipient must be willing and able to maintain procedures to minimize the time elapsing between the transfer of funds from FEMA and expenditure of the funds by the funding recipient (44 CFR (c)).
CTC funding recipients are required to promptly (and at least quarterly) refund to FEMA any interest earned on advances. The CTC funding recipient may keep interest amounts up to $100 per year for administrative expenses (44 CFR (i)).
If the CTC funding recipient is not willing or able to maintain procedures to minimize the time elapsing between the transfer and expenditure of funds, payment will be made using the reimbursement method (44 CFR (d)).
FEMA Public Assistance Eligibility & Grants Management

30. Non-Federal Audits
Must follow requirements of 44 CFR and revised OMB Circular A-133
Audits must be by independent auditor
Audits must be in accordance with generally accepted government financial auditing standards
Auditor procurement must meet requirements of 44 CFR 13.36
All CTC funding recipients must follow the audit requirements of 44 CFR and revised OMB Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations.” A copy of OMB Circular A-133 is provided at the end of this unit as Attachment 8.
The audits must be made by an independent auditor in accordance with generally accepted government auditing standards covering financial audits. In arranging for audit services, the procurement requirements of 44 CFR must be followed (these requirements are discussed later in this unit).
If the CTC funding recipient expends $300,000 or more in a year in Federal awards, they must have a single or program-specific audit conducted for that year in accordance with the provisions of revised OMB Circular A-133.
FEMA Public Assistance Eligibility & Grants Management

31. Program Changes
44 CFR and OMB Circular A-87 specify conditions requiring prior FEMA approval
A recipient may rebudget within approved direct cost budget to meet unanticipated requirements and make limited changes
CTC funding recipients must follow the prior approval requirements in 44 CFR for any changes to the budget or scope of the approved project.
OMB Circular A-87, “Cost Principles for State, Local, and Indian Tribal Governments”, contains requirements for prior approval for certain types of costs (allowable costs were discussed earlier in this unit). Thus, if the proposed change would result in adding one of these costs to the project, prior written FEMA approval is required.
CTC funding recipients are permitted to rebudget within the approved direct cost budget to meet unanticipated requirements and may make limited program changes to the approved project. However, certain types of post-award changes in budgets and projects require written approval from FEMA. These are discussed on the following page.
FEMA Public Assistance Eligibility & Grants Management

32. Program Changes
Federal funding recipients should obtain prior FEMA approval for:
Some transfers of funds between total direct cost categories
Revision resulting in need for additional funding
Transfer of funds allotted for training
Revision of scope/objective of project
Changes in key persons
Subcontracting
Transfer of funds to other agencies
The CTC funding recipient should obtain prior FEMA approval for any of the following changes:
Transfers of funds between total direct cost categories in the approved budget (for awards in excess of $100,000 when such cumulative transfers among those direct cost categories exceed 10 percent of the total budget).
Any revision that would result in the need for additional funding for the project.
Transfer of any funds allotted for training allowances (although FEMA will typically not fund training activities through a CTC Cooperative Agreement).
Any revision of the scope or objective of the project (regardless of whether there is an associated budget revision).
Changes in key persons specified in the application or cooperative agreement.
Subcontracting any activities that were previously identified to be performed by the CTC funding recipient as part of the Cooperative Agreement.
Transfer of funds to agencies other than those identified in the approved Cooperative Agreement application.
Any request for a prior FEMA approval of any budget revision must be made in the same budget format the CTC funding recipient used in its application and should be accompanied by a written justification for the proposed revision. Any request for a prior approval based on the allowable cost principles of OMB Circular A-87 may be made by letter.
No monetary increase or time extensions will be approved unless all financial and performance reports are current. Financial and performance reporting are discussed later in this unit.
FEMA Public Assistance Eligibility & Grants Management

33. Equipment and Supplies
Equipment: useful life of more than 1 year and an acquisition cost of $5,000 or more per unit
Supplies: all tangible property other than equipment
Use and disposition requirements contained in 44 CFR (equipment) and 44 CFR (supplies)
Must compensate FEMA for residual inventory of supplies exceeding $5,000 in total aggregate fair market value
In general, agreements will not be used to purchase equipment or supplies
Exceptions must be specified in Cooperative Agreement
Equipment means tangible, non-expendable, personal property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. Supplies means all tangible property other than equipment.
In general, CTC agreements will not be used to purchase equipment or supplies. It is expected that the CTC has the necessary hardware, software, and other resources to perform the mapping activity being funded by the Cooperative Agreement. In some circumstances, exceptions may be allowed to acquire certain supplies or equipment that would be uniquely required to meet the requirements of FEMA’s mapping program. Acquisition of any supplies or equipment must be specified in the Cooperative Agreement.
FEMA Public Assistance Eligibility & Grants Management

34. Equipment and Supplies
States must use, manage, and dispose of equipment in accordance with State laws and procedures
Local and regional must:
Use equipment for intended project
Maintain property records and conduct biennial physical inventory
Maintain adequate maintenance procedures
Retain or sell when no longer needed
Equipment
States must use, manage, and dispose of equipment acquired under a Cooperative Agreement in accordance with State laws and procedures. Local and regional agency CTC grantees must:
Use the equipment in the program or project it was acquired for as long as needed, whether or not the project continues to be supported by Federal funds. Can also be used for other projects currently or previously supported by the Federal Government as long as it does not interfere with the completion of the Cooperative Agreement under which it was acquired. First preference should be given to FEMA-supported programs or projects. When no longer needed for the original project, it can be used for other activities currently or previously supported by a Federal agency.
Maintain property records that include a description of the property, a serial number or other identification number, the source of property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the cost of the property, the location, use, and condition of the property, and any ultimate disposition data, including the date of disposal and sale price of the property. Additionally, a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years.
Maintain adequate maintenance procedures to keep the property in good condition.
When original or replacement equipment is no longer needed for the original project or other Federally supported programs or projects, retain or sell the equipment. If the current per unit fair market value is in excess of $5,000, FEMA will have the right to an amount calculated by multiplying the current market value or proceeds from the sale by FEMA’s percentage share of the equipment. If the per unit fair market value is less than $5,000, the CTC funding recipient may keep it with no further obligation to FEMA.
FEMA Public Assistance Eligibility & Grants Management

35. Procurement of Contractors
Requirements for procurement specified in 44 CFR 13.36
State agencies must follow the same policies and procedures used for procurements from their non-Federal funds
Requirements for local and regional agencies at 44 CFR 13.36(b) through (i)
The minimum Federal requirements for procuring property and services under a CTC Cooperative Agreement award are specified in 44 CFR State agencies will follow the same policies and procedures they use for procurements from non-Federal funds. Procurements by local and regional agencies must comply with the requirements of 44 CFR 13.36(b)through (i).
The selection of contractors is discussed in more detail in Unit VII of this training course.
FEMA Public Assistance Eligibility & Grants Management

36. Monitoring and Reporting Program Performance
Requirements specified in 44 CFR 13.40
Performance reports due 30 days after end of each quarter
Final performance reports due 90 days after close of agreement
Significant events reported immediately
The CTC funding recipient is responsible for managing the day-to-day operations of the award supported activities, but is required to submit periodic performance reports to FEMA. The requirements for monitoring and reporting program performance are specified in 44 CFR Performance reports should contain information on the following:
A summary of project accomplishments and comparison to established objectives
Reasons for slippage if planned objectives were not met
Problems encountered in accomplishing the project and how those problems were resolved
Problems requiring a decision by the FEMA PO. The report should also include recommended resolution(s) to the problem.
Objectives and schedule for upcoming reporting period(s)
Additional pertinent information including, when appropriate, analysis and explanation of cost overruns or high unit costs
Performance reports should be submitted to the FEMA PO within 30 days after the end of each Federal fiscal quarter. Final performance reports are due 90 days after the close of the Cooperative Agreement.
Further, if events having significant impact upon the award-supported activity occur between scheduled performance reporting dates, the CTC funding recipient should notify the FEMA PO as soon as practicable. Examples of events that should be reported include problems, delays, or adverse conditions that will impair the ability to meet the objective of the project. If the problems are technical in nature, a “Special Problem Report” should be completed and submitted to the FEMA PO (Special Problem Reports are discussed later in this unit). Favorable developments that enable meeting time schedules and objectives sooner or at less cost than anticipated or producing more beneficial results than originally planned should also be reported.
The FEMA PO or AO, or designee, may visit the site as warranted by project needs.
FEMA Public Assistance Eligibility & Grants Management

37. Financial Reporting Reporting requirements specified at 44 CFR 13.41
Must submit Financial Status Report to FEMA Regional Office within 30 days after end of each quarter
Final financial reports due 90 days after close of agreement
HHS Smartlink users should also submit PMS 272 report
The financial reporting requirements are specified at 44 CFR
The CTC funding recipient must submit financial reports (FEMA Form , “Financial Status Report,” to the FEMA AO within 30 days after the end of each quarter. The address for submitting the reports can be found in Article V of the Agreement Articles for the particular Cooperative Agreement. A copy of FEMA Form is included at the end of this unit as Attachment 9.
If the CTC funding recipient uses HHS Smartlink to receive payment of the award, a copy of the PMS 272 report should also be submitted to the FEMA Regional Office.
If the SF 270 is used for payment of the award, the quarterly financial reports may be waived with only a final financial report due 90 days after the close of the Cooperative Agreement. Request for such a waiver should be made to the FEMA AO for the Cooperative Agreement.
FEMA Public Assistance Eligibility & Grants Management

38. Useful Links Grant Regulations
OMB Circulars
Federal Register (Code of Federal Regulations)
Resource Center (My Improvement Plan)
ECourses: Key Concepts of Financial Management & Budgeting (for each stream of service)
_management.php
FEMA Public Assistance Eligibility & Grants Management

39. Grants Management Branch
QUESTIONS
Joe Liciardello
Grants Management Branch
FEMA Region III
Learning Check:
When will FEMA close out the award?
When must the CTC funding recipient submit all financial, performance, and other reports required as a condition of the award?
What reports must be submitted?
How will FEMA adjust costs?
What rights and obligations are not affected by close out?
What actions may FEMA take to collect funds in excess of award?
FEMA Public Assistance Eligibility & Grants Management