1 / 39

FEMA Public Assistance Program

FEMA Public Assistance Program. FEMA Region III – Philadelphia Will Blair Senior Emergency Management Program Specialist William.Blair@DHS.Gov (215) 931-5576. FEMA Public Assistance Grant Program. Eligible Applicants: State and Local governments Certain Private Nonprofit entities

kuri
Download Presentation

FEMA Public Assistance Program

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript


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

  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 • 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. COST Types of Direct Costs: • Force Account (your resources): • Labor • Equipment • Materials • Contract Costs (outside resources) PA Guide Page 40

  5. CONTRACT ELIGIBILITY

  6. COSTCONTRACTS 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. COSTCONTRACTS DOCUMENTATION! DOCUMENTATION! DOCUMENTATION! To include: • Procurement Process • Rationale – Selections/Decisions • Processes, inspections, payment, etc.

  8. COSTCONTRACTS 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. COSTCONTRACTS Cost or price analysis • Required for ALL procurement actions • Including amendments/change orders • Tests REASONABLENESS • Independent estimates PA Guide page 51 - 53

  10. COSTCONTRACTS Accepted Procurement Methods: • Small Purchase • Sealed Bid • Competitive proposals • Non-competitive proposals PA Guide page 51 - 53

  11. COSTCONTRACTS 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. COSTProcurement of Contracts 3Types 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 PA Guide page 53

  13. COSTProcurement of Contracts NOT ELIGIBLE • Cost plus a percentage of contracts • Piggyback Contracting – not competitive / price structure may vary • Contingency PA Guide page 52 - 53

  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 PA Guide page 53

  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 PA Guide page 53

  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. 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. QUESTIONS? VDEM - FEMA

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

  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. 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

  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 disbursementof funds

  24. Revised Grant Guidelines 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. 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. 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. 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. 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)

  30. Non-Federal Audits • Must follow requirements of44 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. Program Changes • 44 CFR 13.30 and OMB CircularA-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. 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. 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. 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. 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 andregional agencies at 44 CFR 13.36(b) through (i)

  36. Monitoring and Reporting Program Performance • Requirements specified in44 CFR 13.40 • Performance reports due 30 daysafter end of each quarter • Final performance reports due 90 days after close of agreement • Significant events reported immediately

  37. Financial Reporting • Reporting requirements specifiedat 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. 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

More Related