FEMA Public Assistance

Cares Act Difficulty

9 June 2020 by Christina Moore

Following COVID Funding

Why is COVID funding so difficult to understand and how to address it? We’ve been following the information closely, and we’re a bit lost too. We do have something to share today.

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The CARES Act: Making History

The United States Federal Government has made a disaster declaration for the entire nation: the states, territories, and district of Columbia. First ever. Normally, when a disaster is declared, FEMA presents itself as the lead agency. Remember, FEMA is part of the Executive Branch of the Government under the Department of Homeland Security (DHS).

In a simultaneous effort, the Congress of the United States wrote, debated, and passed the CARES Act into law. This is the largest-ever economic stimulus package in our history. This law provides some $2 trillion in funding and increased our national debt by about the same value.

How Does the Act Work?

Back in the old days, y’know 2019, a disaster declaration unified the command, informational, and financial flow. While the process varied, basically one looked to the local government’s emergency management entity, then the state’s emergency management agency, then the state’s governor, then FEMA. On really big disasters, additional grant programs often kicked in especially from Housing and Urban Development, and additional FEMA funding for mitigation. It was a routine.

With the CARES Act, funding flows-ish from nearly every federal agencies directly to organizations that they commonly serve. Health and Human Services to health things. Department of Justice to cop-things. Election Commissions to election-y things.

A lot of the funding from the CARES Act is provided at 100% and currently FEMA states they they will do 75% funding.

Is the information we need clearly available, and easily understood? As a nation, we’ll have more organizations applying for loans and grants right now than ever in our history because of COVID. The people doing the research will be over-worked citizens trying to keep their organization operational.

Defining Grants

I am unable to find an overarching road map of COVID-related grant programs with their various scopes, clientele, funding rules, date ranges. I’ve looked. I am a citizen researcher searching in spare time during my days and weeks. If this exists, please drop a comment below!

This is important public information. My inability to find it is not proof it doesn’t exist. Maybe there is a draft poster in the living room of a work-from-home staffer. Who knows?

Without a map, a public sector organization will tap resources they know. The internet is good start. Consultants, colleagues, peer organizations, state affiliated organizations, and even federal agencies. Data one can’t find readily is lost data. I guess that is the definition of lost. I’ve been lost before.

I’ll look at two personal efforts in an effort to provide a factual background to my thesis statement. Who’s in the news? Cops and Hospitals. I’ll start with cops.

The Coronavirus Emergency Supplemental Funding Program

The US Department of Justice funds grants through the office of Justice Programs (OJP), Bureau of Justice Assistance (BJA) – boy one can get tired of understanding the scramble of letters. I researched and read this grant a week ago. It was easy to find through common internet search tools. Today, it had all but disappeared. The program was called Coronavirus Emergency Supplemental Funding Program. It is closed.

Where Did the Grant Go?

It ran Between March 30^th and May 29^th, while it appeared to be open to any/all policing type organizations, 1,725 have been approved grants for a total of $800 million. This is what I know: there are 58 states and territories. There are approximately 3,000 counties in this country. Let’s make believe that’s 200 large cities. I think we can estimate there are 3,500 policing-type agencies in this country. So half of them got a grant.

29^th of May… you’ll hear snark in my voice, certainly. Has there been any COVID related or police related topics in the news between May 28th and June 8th when this video was published? Of course there has. Law enforcement agencies have encountered increased costs for PPE, supplies, training, and overtime.

My off-the-cuff analysis. This now-closed grant provided $800 million to fewer than half of the law enforcement agencies. And the grant program closed before the first day of June.

Will there be another round of funding? Was this first come-first serve? What effort did the DOJ use to publish this grant opportunity.

Clearly, I don’t have answers. I feel confused. To take that confusion further, I went to grants.gov to confirm my findings. I searched for COVID-related grants from DOJ. I found one recently closed DOJ grant that referenced COVID. The research and evaluation on firearm violence grant may be extended due to COVID. Not a COVID grant, or CARES Act grant.

What is on the DOJ website doesn’t match what is presented on grants.gov.

Let’s take a quick look at HHS.

With an internet search, I found the CARES Act Provider Relief Fund offered by Health and Human Services (HHS). This website states the available funding is $175 Billion. Many websites don’t provide this information at the top. Thank you HHS. HHS has a detailed spending plan on their website. It does not seem that this program is open. There were deadlines in April and a key deadline on the 3^rd of June – so very last week.

I hope that those in need found this program.

Now, I’ll step to my next experiment. The classic answer with the US Government for grants is to go to grants.gov – a free public resource.

What is the Best Option?

The Provider Relief Fund discussed above is not visible in Grants.gov. But there are a lot of other HHS COVID related grants: I count 15 for the 7^th of June as I write this script.

I do not work with HHS grants often. I searched for grants that I affirmatively found at grants.gov back on the HHS website. They didn’t synchronize. The data is different.

This means that within one key agency – HHS – they do NOT have an over-arching road map to grant programs. It appears difficult to research, forecast, predict, and anticipate what will happen. It appears difficult to track what is going on currently.

Furthermore, how would one know whether HHS, or FEMA, or another agency a better option?

FEMA & The CARES Act

During the introduction, I stated that a major disaster declaration has been made across our country. In addition to the $2 trillion from CARES Act, FEMA is providing Emergency Protective Measure grants. This grant program alternately called FEMA Public Assistance or known by the Stafford Act, includes 57 major disaster declarations – each state, 5 territories, the District of Columbia and 1 tribe.

This grant program is NOT on grants.gov. Never was. It is a state managed grant program, typically through the state’s designated emergency management agency. In the recent years, FEMA has moved the grant application process to a FEMA hosted site that they call “the grants portal”.

FEMA is providing emergency protective measures (overtime costs, PPE, equipment, etc) to eligible public sector organization. This is also called a Category B grant. We have a video on this topic. The funding from FEMA is presently slated for 75%. The disaster date starts on the 20^th of January and extends through to September. A period of performance with that sort of date range for an emergency protective measures grant is rare.

Contrasting the Situation

Let’s contrast the situation.

FEMA, the long-standing leader in disaster recovery grants, has a program that is open through September. It will provide 75% funding. The rules are well known. Even has a book called the PAPPA-G. It will cover overtime costs and equipment costs and PPE for eligible public sector-type organizations.

The CARES Act is also providing funding through grants to many of the same organizations. Some of these grants are 100% funded. Some have wickedly complicated rules about what will be paid and not paid. The HHS math that involved Medicare revenue about broke my brain.

While federal grant programs are opening and closing, they are advertised or accessed through various sites. Commonly what is on grants.gov is not on the agencies own page.

Meanwhile, the human beings paying bills, engaged in procurement, tracking labor costs are entirely swamped with the overwhelm. It’s like someone dial the Overwhelm-knob all the way to max.

The teaser at the top was a promise that we’d know how to address it.

Rules to Follow

First, if you think you’ll get CARES Act or FEMA funding because you do work in the public sector or related, then track your labor costs in massive detail. Do your fringe rate calculations and be prepared to get reimbursed by someone for that. The rules vary.

Second, any procurement you do, follow the federal procurement rules. These rules inform you that you must follow the most restrictive rules: your own rules, your state’s rules, and the federal rules. There is a strong preference for fair-and-open competition. There is a strong preference for sealed bids. There are penalties for fraud, waste, and abuse.

Third, research, listen and learn. As busy as you are, now that opportunities are opening and closing without your knowledge. I entirely sympathize. Our firm learned of a grant on Monday due on Friday. We submitted on Thursday. Now we wait.

Fourth, do not submit the same costs to multiple agencies or multiple grants. That is FRAUD.

Fifth, someone will (better) start coming out with this guidance. After all, it is our tax dollars at work. Best if the process were fair and transparent. Oh, listen to my opinion sneaking in again.

Grant Management Basics: How to Do Progress Reports for Grants

4 June 2020 by Christina Moore

Grant Progress Reports

Cut your progress reporting time by 20 minutes per grant by answering three questions on a web form. We’ll take a look at the grant progress reports in Tempest-GEMS. With FEMA and other federal granting agencies, applicants are encouraged to provide progress reports each quarter.

We are coaching you on grant management best practices using grant management software. If you appreciate this presentation, please share it.

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Progress Reports

Progress reports occur as a part of the dynamic between the grant execution team, also called the sub-recipient, and the state’s grant administration team. The questions that the grant managers, or applicants answer come from the state. Here at Storm Petrel, we modify this process to meet the state’s needs. Quarterly, the applicants are asked to identify if the scope is sufficient, funding is sufficient, and if there is progress on the mission.

The state reviews and summarizes for the federal granting agency.

Creating Progress Reports

The progress reporting process is specific to a grant. Open the grant menu on the left to find progress – it has a bar-chart for an icon. Click the green button to add a progress report. Answer the questions from the state then hit submit.

The questions normally focus on your activities and needs. It is an early warning or early detection system. A key risk with larger disaster grants is abandonment. Success is accomplished with regular steady work. The quarterly progress reports reinforce this message.

Reviewing of Progress Reports by States

With each cycle of progress reports, the state reviews the effort with workflows and reports in Tempest-GEMS. The action taken by the state is for them to decide. Maybe the reports get sent to FEMA, maybe just summarized.

Communication is Key

Progress reports keep communication going between the state and the applicant. The effort reminds people to review grants, reimbursement status, data entry activities, and others factors, then document the situation.

We are providing you a Power Tools card on Progress Reports. We strive to reinforce successful grant management practices.

Power Tools Cards on Progress Reports

Grant Management Basics: Reimbursement Requests

2 June 2020 by Christina Moore

Reimbursement Requests

How to ask for—and get—grant money, extensions, and scope changes. Grant management best practices using grant management software emphasizes an all-in-one solution. With Tempest-GEMS, this process is called a Request. You make a Request of your state to get funds. You make a Request of your state to get an Extension. You make a Request of your state for a change in scope or budget. This is how you get reimbursed by a grant.

We are providing training on how to manage disaster relief grants such as the CARES Act and FEMA grants. If you appreciate this presentation, please share it.

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Request & Review Processes

In our FEMA Quest came, we identify the Call-and-Response loop. You and your state collaborate with back-and-forth effort steadily moving the grant management process through reimbursements to scope changes and ultimately to close out. The grant execution team makes a Request. The grant administration team then steps through Workflows.

Your data entry process, and document gathering process, may continue for months and months. Especially with large capital projects such as rebuilding infrastructure (roads, bridges, damaged public buildings, etc). These kinds of grants may remain open for years. Category B – emergency protection measures – often close a few months after the emergency period. With COVID-19, we already have a 90-day emergency period. For the first time ever, we have an emergency funding grant with a significant period of performance.

We’ll look at the Request process from the applicant’s side in the Tempest-GEMS grant execution module.

Then we’ll look at the Request review process on the state’s side in the Tempest-GEMS grant administration modules.

Request for Reimbursement

https://vimeo.com/412764143/42dab6805e

Log into Tempest-GEMS, I have my grant selected in green with the check mark. I’ll now use the menu to click Request. It has a hand-pointing icon. This takes me to the Requests page. On this page, you clearly see the name of your grant. And it shows you your past requests and their disposition.

Gone are the days of emailing documents, emailing requests, and shipping documents to states. The auditing and transparency benefit all teams.

I’ll add a Request. In Tempest-GEMS, green buttons add.

I’ll pause on this Select Request Type page. This list of the Request types changes based on where you are in the grant lifecycle. For example, you can not ask for Reimbursement if the grant has not been awarded or obligated.

The Request Types are a feature that states can add and modify. Our software is customizable-off-the-shelf or COTS.

Everyone’s favorite request is the RFR, or Request for Reimbursement. It is our favorite because it is how we walk the Money Please loop in FEMA Quest. Money’s how we all keep score in this game. We spend money on authorized projects and missions. Then we ask for a reimbursement.

The Reimbursement Request involves a few simple steps and questions. The specifics are state-driven. Some states want a signed letter on letter head. Some don’t. Some just use Tempest-GEMS but limit who can make the Request to specific people.

Enter, click, confirm, and hit confirm and submit at the end. This results in the information being “sent” to the state. Of course, the data doesn’t move. The state team uses their tools to review your efforts.

The Grant Administration Module

https://vimeo.com/412764845/57a80e12fe

I have stepped over the Grant Administration Module, the state’s tool. I’ll start with the Standard Requests page. This shows the pending Requests from applicants. If you study these pictures too closely, you’ll see that I’m using my demo data with data put in by our programmers. It’s test data for us, but it serves a purpose to show you the variety of actions and processes.

Users may sort and filter data. We can accommodate multiple grant types – more coming all the time, including CARES Act grants. Please pause this video or rewind if we go to fast through this. Lean right in.

The review and approval process for most Requests follows a state-defined process. Often a quick document validation process involving consistency and completeness. Are documents actually what they are supposed to be? And how are applicants doing at gathering the essential documents as defined in the master list that we call the Virtual Binder?

Reimbursement Queue

Next, we’ll look at the Reimbursement Queue. For the state team, this is a bit more involved. The team not only reviews the documents for consistency and completeness, they also review the financial data.

The Reimbursement Queue involves a multi-stage review and approval process. The first team does the in-depth analysis – these people are often contractors or temporary staff. The next tier is an approval process and confirmation. Typically, a state employee. The third approval sends the data to the state’s financial system or other system. This can happen either with a digital link or by paper.

When payment is completed, someone on the Grant Administration goes into the disbursement queue. This final process notifies the applicants that funds have moved, and it updates the Tempest-GEMS financial balances.

Benefits of Grant Management Software

Before using grant management software, people shipped documents to the state. Or the state came to an applicant’s site to review documents. This is a labor intensive and travel intensive process. Grant management software like Tempest-GEMS facilitates collaboration and cooperation between the applicant team and the state team. We work as one helping our communities recover from disasters.

The grant management basics don’t change. Our process of doing requests is an improvement on email and shared file folder. Our process of stepping through a WorkFlow on the state-side provides the monitoring-and-controls that FEMA and other federal agencies expect of our grant administrators.

The days of using a pencil and yellow paper for grant management are long gone. Quickly we are seeing the end of using an electronic spreadsheet for managing disaster relief funds. Sophisticated tools like Tempest-GEMS prevent fraud, waste, and abuse.

Additionally, it help us all confidentially navigate the rough terrain that is federal grant management.

Please share this material with colleagues. Post about us and our efforts on your favorite social media platform. And don’t forget to grab the Hints and Hacks on Requests to help you with your FEMA Quest.

Hints and Hacks on Requests

Grant Management Basics: How to Document Your Use of Grant Funds

28 May 2020 by Christina Moore

Documenting Your Grant Funds Use

Document organization can be challenging and boring. Use your tools to make your life a whole lot easier. Oh, and both reimbursement and closeout will be easier too. The other hint is to turn it into a game. Here is a list of things to find… Go find them. Grant management best practices includes actions that are done for their own sake. It may not be as dramatic as responding to 911 calls or triaging patients. Those actions require funding, paychecks, supplies, power, and internet. Your work keeps all of that moving. Documenting your grant fund use is an integral part of how to manage relief grants.

We are providing grant management best practices so that you and your team will learn how to document your grant funds use. If you appreciate this presentation, please share it.

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The Virtual Binder

Tempest-GEMS includes a Virtual Binder. Just like a 3-ring that is empty and awaiting documents to be slid in. It serves two immediate purposes. First, it provides a robust master list of all documents you will need or should have between now and close-out. When using grant management software, like our Tempest-GEMS, you should have an easy and consistent means of gauging progress.

In this episode, we’ll first look at the virtual binder – as a framework for document management and skim through a few examples. Then we’ll look at uploading documents. I’ll define what we mean by “applicant” or “grant” documents. We’ll, also, compare the document upload wizard verses the upload button.

Before closing the episode, I’ll show you how the Virtual Binder is used for the monitoring and control process at the state. The grant administration team steps through the document validation process first confirming the documents as what you say they are. Then they go through and compare what you’ve uploaded against the Virtual Binder – as list of what is expected.

Applicant Documents

Documenting your grant funds use? Follow the outline shown in Tempest-GEMS. There are some documents that are about you, the applicant. These documents should be part of every grant binder. With our system, you upload them once. Applicant documents include items such as procurement policy, overtime policy, union contracts, fringe rate calculations. Some organizations, especially non-profits, may also have to provide corporate documents that give evidence to your status as an essential organization.

Score Card Outline

Our grant management software then uses this outline to create a score card. The goal is to have one of each type of document. And maybe if a document is non-existent, write a memorandum for record with an explanation. Here in Tiny-Town Vermont, our road department does not have a union, therefore there is no union contract. A quick note to explain that fills the gap and gives the point. Points are good.
You can, by using the outline, modify this list to fit your needs. We provide a score card based on our experience, this does not mean it is perfect for this disaster or your state. We try… but we also give you the tools to take care of your own needs.

Let’s go answer the question how do we earn the points and upload documents.

The Grants Menu & Documents

First, navigate to the Grants menu and find documents on the menu – it has a little PDF icon. We have two green buttons for uploading documents. Why? One is a short cut for experienced folks, the other walks through a wizard giving guidance and coaching.

Remember your goal is grant closeout and final reimbursement. To do this well, you need to fill your Virtual Binder and get as many points as possible. Grant Management basics! We looked at the document score card. Tempest-GEMS and the state can only evaluate documents if they are tagged correctly. So, every document must be a PDF. This is done for security reasons. When FEMA uses our system, their security team requires only PDF.

Document Wizard

I am clicking on the Document Wizard button. I am expanding the “Examples” section. This is another guidepost in our software to help you expertly navigate through the rough terrain of FEMA Quest. My next steps are just to illustrate. I’ll pick a grant class: applicant, grant, program, transaction, etc. In my case, I’ll upload a policy for this Applicant. I pick the document type. And move on to the next page with the Next button.

Then I upload a document from my local computer.

The Upload Document button does the same thing but with fewer key clicks. Each section of the software: grants, program, applicant, vendor, etc – has a document page. Some users prefer to save keystroke, and know to click to “applicant” to upload a policy or fringe rate calculation.

Our software has flexibility and gives you two ways to accomplish the same goal!

Perform a Virtual Binder Review

The Virtual Binder is used by the state grant administration team as well. During their quality assurance process, they perform document validation. The first step confirms the documents what they are reported to be. The second step gauges completeness. They compare the documents applicants have uploaded again the Virtual Binder.

On the screen is an article from Storm Petrel’s knowledge base site. Yes, we also provide targeted how-to articles on our knowledge base too. We’re here to help in every way we can.

In this article, we are showing a grant administrator how to perform a Virtual Binder Review. Although not shown, red identifies errors or failures. Yellow is a warning indicating missing documents. And Green indicates that not only is a documented uploaded, but it has passed the review process.

On the left-hand side, the master list of documents – the Virtual binder. On the right, we show documents uploaded and their status: pass or fail.

The state-side or applicant-side, Tempest-GEMS uses the same tools, the same lists, the same rules to aid both teams through towards their shared goal: a successful close out of a grant.

Adding PDFs to the Virtual Binder

The Virtual Binder, which when I was in New York City we called the Document Manifest, is nothing more than a target or a master list of items for a scavenger hunt. Find them, save them, scan them to PDF and upload them appropriately in Tempest-GEMS.

The Virtual Binder structure can be modified to suite your needs or modified by the state to meet the needs of the FEMA Public Assistance Grant Program, or a CARES Act grant program. To us it is just a list. Same is true for you. It is just a list. It represents grant management best practices.

Over the years, we are so often asked can’t I upload my Word or Excel documents? The rule is upload PDF. PDF documents do a better job of not including malware. Because Word and Excel permit macros and some programming inside, they also represent a higher security risk. You know that yellow warning banner you see when you open a spreadsheet from an email? The warning states: do not open documents from unknown sources.

That’s why PDFs are better.

Additionally, FEMA will not permit their staff to download anything but PDF.

Ergo, you must upload PDFs.

Please share this material with colleagues. Post about us and our efforts on your favorite social media platform. And don’t forget to grab the Hints and Hacks on Required Documents to help you get started with FEMA Quest.

Hints and Hacks on Required Documents

FEMA Grant Accounting Basics: How To Make Big Purchases With Grant Funds

26 May 2020 by Christina Moore

Big Purchases With Grant Funds

Avoid the number one failure that causes the DHS OIG to recommend grant clawback, and keep your hard-won grant funds working in your community. In our FEMA Quest game and in our game cards, we call this the Land of Eleven. The reason is that there are eleven essential steps which will generate at least eleven documents. Get eleven documents, and you’re likely following grant management best practices. In this episode, we learn how to make big purchases with grant funds.

We are providing grant management best practices so that you and your team will learn how to manage FEMA grant accounting basics. If you appreciate this presentation, please share it.

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Large Purchases Defined

What is a large purchase? A large purchase is defined in procurement policy, or it should be. If you have a policy, you should define this threshold. If not, you fall on your state’s policy and their threshold. If they don’t have one, then you use the federal policy.

The federal policy uses the Simplified Acquisition threshold which is normally $250,000. Some funny things happened to it during the spring of 2020.

I looked up Arizona’s policy. Their policy stated that in the event of federal funding their policy guidelines revert to the federal. If you live in Arizona, your threshold is that Simplified Acquisition threshold above.

I looked up Virginia’s policy. They did offer a definition basically $100,000 (§ 2.2-4304. Methods of procurement G.1.)

That’s a lot of words and gibberish.

The Eleven Steps of Grant Management

Let’s make a short cut. When in doubt, use a competitive procurement process. It takes eleven steps, cost a few dollars. With COVID-19 emergency, there is printed guidance from FEMA about single-sourcing. That guidance precisely follows the law and matches 2-CFR-200. It seems tempting to sole-source – but please don’t. It will come around and sting years down the road. The warning is that FEMA and the OIG have a short memory. After a few lovelies abused this process, there will be scrutiny on all of us! Single source seems attractive, people will have failures and rejection because some costs are not reasonable. Oops.

In this episode, I am going to go through the eleven steps as they relate to the policy. Then I’ll show you how to set that up in Tempest-GEMS and how using grant management software, provide guidance, and scoring.

You’ll do best thinking of this as a game. Earn points here to protect yourself from bad stuff. And that is good.

Competitive Procurement “Hints and Hacks”

On the FEMA Quest Competitive Procurement “Hints and Hacks” card, you’ll see the eleven steps needed for this effort. When making big purchases with grant funds, you’ll want to follow this list.

Create a written rationale for the procurement method. Could be a memo, an email, or a motion at a meeting. State you are using a competitive process because it is a large purchase.
Create a bid packet with clear and complete instructions. For construction, this is a lot of work. For other goods and services, it can be simpler. Reference common phrases and definitions.
Issue invitations to bid. Grab a copy or screen shot of that effort in PDF.
Invite disadvantaged business entities or what ever they are called in your state. Typically you can email a state agency to send this out for you. Grab a copy of the email in PDF.
Advertise publicly. Grab a copy or screen shot in PDF.
Capture the proof of payment for an ad. If no paid ad, state that. In PDF, of course.
Hold a public meeting to open the bids. Take minutes. Make a PDF of the minutes and the attendance roster.
Validate the winning bid is not debarred in sam.gov. Keep the PDF.
Do a bid tabulation or scoring sheet. Keep them all, make PDFs.
Write a letter of intent to the winner. And yes, keep the PDF copy of that.
Write a contract that includes all of the provisions you find in your grant (Clean Water Act, Davis-Bacon, etc).

That’s eleven. The Land of Eleven!

The Contract Tool

In Tempest-GEMS, we’ll use the contract tool to help us. Let’s assume you’ve set up the vendor. That was covered in the small purchase episode. That’s an easy step. You’ll find vendors on the menu below the name of your Applicant. The icon is a map pin.

The Grants Menu

With a Vendor defined, go to the Grants menu, then the Contracts menu as shown in the illustration. You’ll add a contract (green-buttons add). Select your vendor, then pick your contract type. This will be sealed bid. Give it a name and save it. You can do all sorts of data entry, or skip it. The system can track amounts, dates, and such. Up to you.

The Contract Scorecard

Here is the contract scorecard. Each of the eleven steps are detailed. We have the reference to the law, 2-CFR-200. The eyeball icon shows you the exact text and can even take you to the government’s website for more details.

Each document you upload, you get a point. Eleven steps, eleven documents.

Uploading Documents

How do you upload the documents? Well there is a documents option in the contract menu. You upload one document at a time to Tempest-GEMS. Tag it with the document type. That’s what gets you the point.

Rinse, wash, repeat. By that I mean: upload, tag it, and do it again. Probably about eleven times.

Now when you do your expense data entry, you can link that cost to a specific contract. There is a cool report in Tempest-GEMS to show your contract expenses. And Tempest-GEMS show you summaries and such provide guidance.

FEMA grant accounting requires this granularity. It will keep your process moving. It is how to manage disaster relief grants.

Sealed-Bid Closeout

The sealed-bid or competitive process is the most-favored procurement process when managing FEMA assistance grants. There are eleven steps and Tempest-GEMS provides you both the guidance and tools to help you keep score.

These eleven steps ensure a successful close out, an optimized reimbursement, and prevents issues with financial clawbacks!

Please share this material with colleagues. Post about us and our efforts on your favorite social media platform. And don’t forget to grab the Large Purchase Guide to help you get started with FEMA Quest.

Large Purchase Guide

FEMA Grant Accounting Basics: Small Purchases with Grant Funds

21 May 2020 by Christina Moore

Small Purchases with Grant Funds

The small purchases are often the ones that can skew the budget if unchecked. Maximize your reimbursements and make sure everything you’ve spent is covered by following these three simple steps – and by three steps, I think I mean four. Join us as we examine how to make small purchases with grant funds. In our FEMA Quest game, this corresponds to the Lil Money Loop.

Standards for Small Purchases

What is a small purchase? A small purchase involves procurement for a product or service that fits between micro and large. Not so helpful was that. Sorry. Let’s start over. You either have or don’t have a procurement policy. The United States Federal Government provides a definition of small. It falls below the Simplified Acquisition threshold and above $3,000 (micro). Under normal circumstances that value is $250,000.

I looked up Arizona’s policy and I did not see a policy definition there for small. I am not an expert and only been a tourist in that great state. Their policy stated that in the event of federal funding their policy guidelines revert to the federal.

I went and looked up Virginia’s policy. They did offer a definition, it’s basically $100,000. Clearly, if you are in Virginia read their policy. I am using this as an example. I see exceptions to this policy in the black-and-white on the left screen. The policy is § 2.2-4303. Methods of procurement G.1.

My little town has a threshold at $10,000.

The standard guidance for “small” purchases is that you documented that you have done some shopping. You found three or four or more competitive prices, you’ve then gotten three email quotes, looked up on-line, that sort of thing. You need to confirm that your price is reasonable.

Almost all of us know the basics of shopping and price comparisons. The difference with small purchases with grant funds is the documentation.

First, write a little memorandum for record or email to your boss, or pass a motion that states your purchase is small because it is below this threshold and above that one.

Second, do your price comparison and shopping. But add the steps of printing the prices you see to a PDF document – or better yet, print that paper, sign it and date it. You don’t have to pick the cheapest. Identify the precise product or service you need. You can’t run tissue paper through your printer. You may need good quality archival acid-free paper. Price compare that. Gather your competitive research, print it to a PDF and save it.

Third, run the name of the vendor through sam.gov. Print that to PDF; that page proving that the vendor is not debarred by the federal government. If your state has such a tool, use that as well.

Four, issue the purchase order, or execute the purchase as you normally would. This time, scan the purchase order, the invoice, and delivery receipt to a PDF. And get a copy of the cancelled check, ACH payment, or credit card statement that proves it was paid.

Managing Disaster Relief Grants

FEMA grant accounting basics – we want to get reimbursed for that purchase. Together, we are studying how to manage disaster relief grants. If you don’t have Tempest-GEMS, you’ll need a manual method for tracking these expenses. In Tempest-GEMS, it is easy. Let’s recap. You have the following documents scanned and ready to go: justification for purchase method, price comparison, debar check, and invoice with proof-of-payment.

Creating a New Vendor

First, we’ll create a new vendor. There is a map-pin icon on the blue menu to the left, near your applicant’s name. Open vendor. You really don’t need training on the how, but I do want to touch on some important items! In tempest-GEMS, green buttons add. We’ll add a vendor called Acme Insurance.

Please note that we ask you, as a reminder, to do a debar check. And if so, when. These questions are to help you. FEMA does not provide a lower threshold on debarment checks. Just the hint. FEMA says do it. So why not. Takes a second.

Adding the Debarment Check

Now upload the debarment check with the Vendor. Done once, saved. Good for you!

Data Entry & Supporting Documentation

Second step, because we are using grant management software, we do the data entry. This is just like popular accounting systems. Vendor, invoice number, description, date and that sort of thing. But because Tempest-GEMS is not an accounting system, you’ll need to tell it (and your state and FEMA) that the invoice is paid. Only paid invoices are eligible for reimbursement. Mark it as paid, provide the paid date, the check number, EFT/ACH number, what ever that is.

Third step, you upload the supporting documentation. You can upload one or any many as you want. You’ll want to upload the invoice and proof-of-payment at a minimum. The bonus points go for the competitive research you did. And the super bonus point for that silly memo stating why this is a small purchase.

You tick those boxes, do accurate data entry and upload those documents and you are golden.

Closing Warnings

When you make small purchases with grant funds, you can circle around and around on the Lil Money Loop making small purchases and reporting them. There are a couple of closing warnings.

Warning number one, the prevailing rule for FEMA assistance is always: necessary and reasonable. Keep that in mind.

Warning number two, the federal government and most states frown on using the small purchase process if your annual aggregate expense with that vendor or product exceeds the threshold. That sounds like you dodged some rules. Just be aware.

And on a happy note, a lot of popular on-line vendors for office supplies have pre-competed government pricing. If use those vendors, you just simplified things a lot. No debar check. No competitive steps.

Simplified Procurement Process

FEMA assistance comes with strings… Small purchases fall below the competitive procurement threshold. The simplified procurement process suggests you note why you are using a small purchase process – a test to see if you know the threshold and rules. Second, a bit of price shopping that you keep as PDFs. Third, do a debar check at sam.gov. Execute your purchase, then put all of that data and documents in Tempest-GEMS readying you for your next reimbursement, moving you closer to close out!

Please share this material with colleagues. Post about us and our efforts on your favorite social media platform. And don’t forget to grab the Small Purchase Hints and Hacks Guide to help you get started with FEMA Quest.

Small Purchase Hints and Hacks Guide