Federal Time Extension Request for 2012 HSGP

1. Federal Time Extension Request for 2012 HSGP Documents and Info Required

2. Revised Extension PolicyPer Grants Program Directorate email of March 27, 2014 • In anticipation of the end of the Period of Performance for FEMA’s FY 2011 and FY 2012 Preparedness Grant Programs this year, GPD reminds Grantees to complete all project activities within the assigned performance period as stated in their grant award agreement.  In accordance with FEMA Information Bulletin #379, Grantees may submit a request for an extension of their grant award due to compelling legal, policy or operational challenges.  Approval is not guaranteed.  All requests are reviewed on a project-by-project basis and approved only if the request meets the criteria and extraordinary circumstances outlined in FEMA’s Information Bulletin #379.  The FEMA extension process has multiple phases and, given the documentation and other details typically required, the review process can take up to sixty (60) days or longer.  This review period should be factored into any decision to submit a request for an extension.  • Prior guidance required Grantees to submit an extension request no earlier than ninety (90) days prior to the end of the period of performance.  The purpose of this communication is to supersede that prior guidance to permit grant extension requests earlier.  Complete extension request packages – which still must meet the criteria and extraordinary circumstances outlined in FEMA Information Bulletin #379 – may be submitted up to one hundred eighty (180) days in advance of the end of the Period of Performance.  Requests should be submitted no less than ninety (90) days prior to the end of the Period of Performance.  Any extension request made less than ninety (90) days prior to the end of the Period of Performance may risk a decision being final after the expiration of the Period of Performance.

3. Timeframe • The federal Period of Performance ends 8/31/2014 • 90 days prior is 6/2/2014 – absolute last day to submit extension request • 180 days prior was 3/5/2014 • Target date for all submittals from subgrantees to FDEM: 17:00 EDT, 4/22/2014

4. Information Bulletin #379 Extension requests will be granted only due to compelling legal, policy, or operational challenges. Extension requests will only be considered for the following reasons: • Contractual commitments by the grantee with vendors or sub-recipients prevent completion of the project within 24 months; • The project must undergo a complex environmental review that cannot be completed within this timeframe; • Projects are long-term by design and therefore acceleration would compromise core programmatic goals; and • Where other special circumstances exist.

5. Submission Requirements“must contain specific and compelling justifications as to why an extension is required “ • Grant Program, Fiscal Year, and award number; • Reason for delay – this must include details of the legal, policy, or operational challenges being experienced that prevent the final outlay of awarded funds by the applicable deadline; • Current status of the activity/activities; • Approved period of performance termination date and new project completion date; • Amount of funds drawn down to date; • Remaining available funds, both Federal and non-Federal; • Budget outlining how remaining Federal and non-Federal funds will be expended; • Plan for completion including milestones and timeframes for achieving each milestone and the position/person responsible for implementing the plan for completion; and • • Certification that the activity/activities will be completed within the extended period of performance without any modification to the original Statement of Work approved by FEMA.

6. Responsibilities SAA: • Prepares overall grant expenditure figures • Prepares & submits letter to FEMA Subgrantees: • Prepare spreadsheet submissions • Prepare & submit to SAA a formal letter requesting the extension and explaining in narrative the circumstances

7. Template Spreadsheet

8. Template Spreadsheet

9. Template Spreadsheet

10. Review and Approval Process Upon receipt of the grantee’s request, the FEMA PA (1) verifies compliance with financial reporting requirements by confirming that the grantee has submitted all necessary Federal Financial and Programmatic Reports (SF-425s and CAPRs/SAPRs); (2) confirms that the grantee has provided sufficient justification for the request; and (3) reviews all previous extensions to confirm that the grantee has demonstrated sufficient progress and provided a reasonable explanation for the continued delays. If the grantee has not provided adequate detail to justify the requested extension, the PA will coordinate with the grantee. Once all required extension request materials are complete, the FEMA PA will prepare an extension package for the GPD Assistant Administrator’s approval. In accordance with PGD policy, extensions are typically granted for no more than a six month time period. In extreme cases, extensions may be granted up to 12 months. However, the grantee must provide additional justification in order to demonstrate the extenuating circumstances that necessitate a longer extension. Per the email of 3/27/14, “The FEMA extension process has multiple phases and, given the documentation and other details typically required, the review process can take up to sixty (60) days or longer.  This review period should be factored into any decision to submit a request for an extension.”

11. Submit spreadsheets and letters to your grant manager NLT 5:00 PM EDT, Tuesday April 22, 2014. Questions?