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Public Assistance Eligibility & Grants Management 2 - 1 FEMA Public Assistance Program FEMA Region III – Philadelphia Will Blair Senior Emergency Management.

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Presentation on theme: "Public Assistance Eligibility & Grants Management 2 - 1 FEMA Public Assistance Program FEMA Region III – Philadelphia Will Blair Senior Emergency Management."— Presentation transcript:

1 Public Assistance Eligibility & Grants Management 2 - 1 FEMA Public Assistance Program FEMA Region III – Philadelphia Will Blair Senior Emergency Management Program Specialist William.Blair@DHS.Gov (215) 931-5576

2 Public Assistance Eligibility & Grants Management 2 - 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 Public Assistance Eligibility & Grants Management 2 - 3 CATEGORIES OF WORK  Emergency – 6 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.) PA Guide Pages 66-87

4 Public Assistance Eligibility & Grants Management 2 - 4 COST PA Guide Page 40 Types of Direct Costs:  Force Account (your resources):  Labor  Equipment  Materials  Contract Costs (outside resources)

5 Public Assistance Eligibility & Grants Management 2 - 5 CONTRACT ELIGIBILITY

6 Public Assistance Eligibility & Grants Management 2 - 6 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

7 Public Assistance Eligibility & Grants Management 2 - 7 COST CONTRACTS DOCUMENTATION! To include:  Procurement Process  Rationale – Selections/Decisions  Processes, inspections, payment, etc.

8 Public Assistance Eligibility & Grants Management 2 - 8 COST CONTRACTS Full and Open Competition:  Requirement - Intended for all procurements  Stimulates better, lower prices  Pre-qualifying – non-emergency periods  Avoid restricting competition PA Guide page 51 - 53

9 Public Assistance Eligibility & Grants Management 2 - 9 COST CONTRACTS Cost or price analysis  Required for ALL procurement actions  Including amendments/change orders  Tests REASONABLENESS  Independent estimates PA Guide page 51 - 53

10 Public Assistance Eligibility & Grants Management 2 - 10 COST CONTRACTS Accepted Procurement Methods:  Small Purchase  Sealed Bid  Competitive proposals  Non-competitive proposals PA Guide page 51 - 53

11 Public Assistance Eligibility & Grants Management 2 - 11 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 PA Guide page 23

12 Public Assistance Eligibility & Grants Management 2 - 12 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 COST Procurement of Contracts PA Guide page 53

13 Public Assistance Eligibility & Grants Management 2 - 13 NOT ELIGIBLE  Cost plus a percentage of contracts  Piggyback Contracting – not competitive / price structure may vary  Contingency COST Procurement of Contracts PA Guide page 52 - 53

14 Public Assistance Eligibility & Grants Management 2 - 14 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 COST Procurement of Contracts PA Guide page 53

15 Public Assistance Eligibility & Grants Management 2 - 15 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 COST Procurement of Contracts PA Guide page 53

16 Public Assistance Eligibility & Grants Management 2 - 16 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)

17 Public Assistance Eligibility & Grants Management 2 - 17 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 email)  Contracts must include a termination for convenience clause  Contract amendments or modifications must be in writing

18 Public Assistance Eligibility & Grants Management 2 - 18 QUESTIONS? VDEM - FEMA

19 Financial Management Grants/Cooperative Agreements Grants Management Branch FEMA Region 3

20 Public Assistance Eligibility & Grants Management 2 - 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

21 Public Assistance Eligibility & Grants Management 2 - 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 Public Assistance Eligibility & Grants Management 2 - 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

23 Public Assistance Eligibility & Grants Management 2 - 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

24 Public Assistance Eligibility & Grants Management 2 - 24 Revised Grant Guidelines Federal Grant Guidelines Universities States, Local, Indian Tribal Governments Non-ProfitsHospitals Administrative Requirements § 45 CFR 2543 § 2 CFR 215 (formerly A-110) § 45 CFR 2541 OMB A-102 § 45 CFR 2543 § 2 CFR 215 (formerly A-110) § 45 CFR 2543 § 2 CFR 215 (formerly A-110) 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

25 Public Assistance Eligibility & Grants Management 2 - 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

26 Public Assistance Eligibility & Grants Management 2 - 26 Allowable Costs  44 CFR 13.22 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

27 Public Assistance Eligibility & Grants Management 2 - 27 Reasonable 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

28 Public Assistance Eligibility & Grants Management 2 - 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 Public Assistance Eligibility & Grants Management 2 - 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 )

30 Public Assistance Eligibility & Grants Management 2 - 30 Non-Federal Audits  Must follow requirements of 44 CFR 13.26 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

31 Public Assistance Eligibility & Grants Management 2 - 31 Program Changes  44 CFR 13.30 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

32 Public Assistance Eligibility & Grants Management 2 - 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

33 Public Assistance Eligibility & Grants Management 2 - 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 13.32 (equipment) and 44 CFR 13.33 (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

34 Public Assistance Eligibility & Grants Management 2 - 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

35 Public Assistance Eligibility & Grants Management 2 - 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)

36 Public Assistance Eligibility & Grants Management 2 - 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

37 Public Assistance Eligibility & Grants Management 2 - 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

38 Public Assistance Eligibility & Grants Management 2 - 38 Useful Links Grant Regulations http://www.cns.gov/for_organizations/manage/index.asp OMB Circulars http://www.whitehouse.gov/omb/circulars Federal Register (Code of Federal Regulations) http://www.gpoaccess.gov/fr/index.html Resource Center (My Improvement Plan) http://www.nationalserviceresources.org ECourses: Key Concepts of Financial Management & Budgeting (for each stream of service) http://nationalserviceresources.org/resources/courses/financial _management.php

39 QUESTIONS Joe Liciardello Grants Management Branch FEMA Region III 215-931-5574 Joseph.Liciardello@DHS.GOV


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