Introduction to Recovery

1. Introduction to Recovery

2. Presenters • Ron Campbell • University of North Carolina Chapel Hill, Emergency Management Coordinator • 24 years of experience in emergency management including more than a dozen disaster events including Hurricane Irene at UNC-CH • Peter Drenan • Dewberry, Vice President • 32 years of experience including 10 years with FEMA’s Public Assistance program and 10+ years as architect at University of Virginia

3. Overview Recent Experience What is Public Assistance Common Challenges Tools and Tips Recovery Program

4. Recent Experience Snow Storms Hurricane Irene Tornados Floods

5. Disaster Resistant Universities • Pre-disaster plan focused on mitigation • Minimize disruptions and closings • Protect research • Control insurance rates • Reduce damage to facilities • 4 Phases: • Phase 1 - Organize Resources • Phase 2 – Hazard Identification & Risk Assessment • Phase 3 – Developing The Mitigation Plan • Phase 4 – Adoption & Implementation

6. Public Assistance • Post-disaster Federal financial assistance • What does it cover: • Debris removal • Emergency protective measures • Repair, replacement, or restoration • Mitigation of damaged facilities • 75% Federal, 25% State/Local

7. Why YOU Need to Understand the Program • MONEY $$$$$ • Benefits: • Maximum reimbursement • Expeditious project approval • Maximize time and resources • Consequences: • Minimal reimbursement • Delays in project approval • Diminished credibility • Appeals • Audits • De-obligation of funding

8. A Real Example • Major storm hit a small university • All 43 buildings flooded for weeks • Classes were closed • Students sent home • Administration’s stated goal was to open next semester for all students • Emergency Financing required to develop temporary teaching and research facilities • What are the issues and considerations for getting the work done and getting FEMA reimbursements?

9. Common Challenges • Project Accounting • Unsupported Costs • Duplication of Benefits • Excessive Equipment Charges • Unrelated Project Charges • Excessive Labor and Fringe Benefits Charges • Poor Contracting Practices • Unapplied Credits

10. Poor Project Accounting • Criteria: Federal regulations (44 CFR 13.20 and 206.205) require each subgrantee to: • maintain a system that accounts for FEMA funds on a project-by-project basis. • The system must disclose the financial results for all FEMA-funded activities accurately, currently, and completely. • Examples: • Collecting or tracking the information well after the incident • Notes were maintained by hand

11. Unsupported Costs • Criteria: Federal regulations (OMB Circular A-87 and 44 CFR 13.20) require that costs claimed under federal programs be adequately supported by source documentation such as cancelled checks, payrolls, contracts, etc. • Examples: • Invoices do not provide detailed dates that coincided with the storm. • Records for vehicle use does not match up with the payroll records. • Records for vehicle use cannot be verified with event related calls. • Receipts do not have an employees name associated with it.

12. Duplication of Benefits • Criteria: Government laws and regulations (Stafford Act and 44 CFR 206.191) prohibit duplication of benefits. • Examples: • Insurance claim not submitted for a project covered by insurance. • Reimbursement from another source was not disclosed on the Project Worksheet.

13. Unapplied Credits • Criteria: According to OMB Circular A-87, grants must be reduced by credits that offset or reduce expenses allocable to federal awards. • Examples: • Jurisdiction received proceeds from the sale of scrap material related to the FEMA project but did not apply them. • Jurisdiction received two credit discounts for early payments to a contractor that were not applied.

14. Excessive Equipment Charges • Criteria: Federal regulations (44 CFR 206.228) require that subgrantees use the FEMA schedule of equipment rates or their local rates, whichever are lower. • Example: • Claiming the FEMA equipment rate rather than the lesser local rate.

15. Unrelated Project Charges • Criteria: According to OMB Circular A-87, charges to federal grants must be necessary and reasonable to fulfill the objective of the grant program. • Examples: • Unrelated charges were included in a claim. • Funding received was not applied to the correct project.

16. Excessive Labor and Fringe Benefit Charges • Criteria: According to OMB Circular A-87, allowable costs must be consistent with policies, regulations, and procedures that apply uniformly to both federal awards and other activities of the governmental unit. According to 44 CFR 206.228, straight or regular-time salaries and benefits of permanent employees engaged in emergency service work are not eligible for FEMA assistance. • Example: • Fringe benefit rates are applied differently to overtime compared to regular time. • Regular time is almost always not eligible.

17. Poor Contracting Practices • Criteria. According to federal regulations (44 CFR 13.36), a subgrantee must comply with specific procurement standards. • Examples: • Jurisdiction did not document the basis or method for the contract selection. • Jurisdiction entered into a contract which included an overhead and profit allowance of 25% of actual costs.

18. Xavier University of Louisiana • Xavier received $75.4 Million for damages • 40 ‘large’ and 57 ‘small’ grant authorizations • Inspector General audit done in June 2010 • At that time, $35 million had been disbursed • Final IG Recommendation: • Disallow $75.4 million

19. Xavier University of Louisiana #1- Disallow $25,648,720 due to unsupported costs #2 – Disallow $49,409,570 due to ineligible contract costs #3 – Disallow $281,430 due to ineligible insurance costs #4 – Disallow $12,291 due to ineligible facilities #5 – Finalize insurance review and allocate proceeds to repairs #6 – Implement controls on time restrictions & extensions

20. Tools and Tips • Standard Systems • Documentation • Checks and balances • Use it everyday • Project Worksheet • How to fill them out • How to Think During an Event

21. Standard Systems Documentation is key!

22. Documentation • Policies should require departments and personnel to: • maintain a system that accounts for university funds on a project-by-project basis. • The system must disclose the financial results for all university-funded activities accurately, currently, and completely • Costs being claimed must be adequately supported by source documentation such as cancelled checks, payrolls, contracts, etc.

23. Checks and Balances Duplication of Benefits Excessive Equipment Charges Excessive Labor and Fringe Benefits Poor Contracting Practices Unapplied Credits

24. Use it Everyday The more you use it the easier it will be!

25. Basic Project Information Damage Description and Dimensions Scope of Work Special Considerations Cost Project Worksheet: Main Components

26. Telling the Story Describe the damage description and dimensions Describe the cause of the damage Describe the pre-disaster condition Quantify the disaster related damage Describe how you fixed the damage, scope of work

27. How to Think During an Event Necessary vs. Unnecessary Justifiable vs. Unjustifiable Normal Policies/Process vs. Not Normal

28. Recovery Program • Next steps: • Review systems • Adjust/Develop systems • Establish/adjust processes and policies • Train staff

29. Closing Common Challenges Can be Navigated Documentation, Documentation, Documentation!

30. Questions?