Managing Disaster Relief Grants
We want to help you and your team use FEMA disaster assistance wisely. We are using a series of videos, podcasts, and blog posts to help you understand the FEMA public assistance grant program. This episode helps with navigating public assistance following a disaster. During this presentation we will discuss the FEMA PAPPG (Public Assistance Program Policy Guide) and the Stafford Act.
Introduction to the Application Process & FEMA Grants Portal
In this episode, we will reference the FEMA Quest game that we invented to illustrate the FEMA Public Assistance grant lifecycle. This time, we’ll take a bit more a buttoned-up, collared shirt approach. We will step through the FEMA process using FEMA terms and applying more standard government-like language. We intend to bridge between our casual and fun way to looking at the process and the FEMA-lingo.
We will introduce you to the application process and FEMA Grants Portal. We’ll discuss terms such as obligation and grant award. We’ll drive home the importance of the scope-of-work.
We will again touch on the difference between large and small grants.
As we step through the lifecycle, we’ll identify the differences in each phase. Here FEMA seems in charge. Here your state. Here you do your thing quietly. And the tools available to you as you work through this.
We’ll define reimbursement and advances. We’ll touch on other Requests that you may make to your state.
The lifecycle concludes with Closeout and the final reimbursements.
The next Episode is about the FEMA Public Assistance Category “B” grant used for Emergency Protective Measures.
FEMA Public Assistance Grant Program
There are elements of the FEMA Public Assistance Grant Program that are more hidden to the normal applicant, and I am going to ignore those elements. This process that I care the most about begin when we know that a disaster has been declared, or it is likely one that will be declared. You and I can do little about the process before declaration. That’s between the governor and the president and FEMA.
For coastal community, we know that when a hurricane impacts us, our declaration may include several days before the impact. That’s interesting and it is relevant to COVID-19 because most declarations I have seen so far (April 2020) set the date of disaster to 20JAN which is almost 45 to 60 days ago. You have costs that may be eligible for weeks prior to the declaration.
My audience are people who are responsible for executing projects funded by FEMA grant dollars. Therefore, our starting point is the Disaster Declaration and more precisely the Performance Start Date. There is no grant before this moment.
The experienced amongst us may start collecting data and logs beforehand in anticipation of funding. Good for you. Well done.
The Grant Application process with FEMA is squishy and flexible. Of course, the day you are informed about it, then it is precise!
Follow the rules of the day! Why is it squishy and flexible? Because the process changes one disaster to another. They (whoever they are) won’t admit this. Some years, you must be physically present in a room and sign a roster and fill out a piece of paper to declare your intent. Not likely with COVID-19.
Sometimes, you’ll be instructed to go to the FEMA Grants Portal to initiate your process. Through 2019, that was either absolutely mandatory or unknown. FEMA and state directors figured that out along the way. There is a rumor here in April 2020 that the COVID-19 grant application process may go to the Grants Portal for some and others will be helped in other ways.
I can’t help. There is a grant application process. It is either in FEMA Grants Portal or Not. And at the end of the process you will have zero, one, or more grant awards with federal funds obligated to it.
What do you need for the grant application?
Number 1 is a means of estimating the cost of the disaster. The declarations I have seen involve Category B – Emergency Protective Measures. Any action that your governmental entity undertook to prevent death, improve public health, and protect improved property from the impacts of this disaster may be eligible for reimbursement. If you run a municipality or municipal agency, you are a likely candidate. If your organization provides essential government-like services, you are a likely candidate. In our Eligibility post we discuss this topic. This includes non-profit ambulance services, non-profit water districts, non-profit libraries and non-profit hospitals/nursing facilities.
You’ll need to estimate your labor costs. Go listen to the first episode in this series for help on that or read it here. You’ll need to estimate material costs, incidental costs, and contracted costs.
If you contracted services and purchased materials, know that the federal procurement rules apply. We talk a lot about this in this series. That’s your biggest trap right there.
The grant application involves cost estimates and the scope-of-work you provided or may provide in the future.
FEMA Grants Lifecycle
1. Grant Application
The grant application for FEMA involves the following elements
- Cost Estimates for labor, equipment, material for activities that have been completed
- Cost Estimates for labor, equipment, and material for activities that are planned.
The activities must be within the proposed scope of the grant and fit within the confines of the FEMA Public Assistance Grant Program. This means between date X and date Y (the start of performance and end of performance dates).
For COVID-19, this also means that the activities directly supported Emergency Protective Measures (preservation of life, public health, and at-risk improved property).
If you request funding for labor, equipment, and material costs, you MUST provide the documents that provides proof for your labor costs. These include labor contracts, union contracts, payroll records, work logs that tie the activities to eligible work. For equipment, you’ll need to provide equipment logs and costing based on the FEMA equipment schedule.
For non-labor based costs, you’ll need to execute procurement within the guidelines of your procurement policy, your state’s procurement policy, AND the federal procurement policy – which ever is the most strict. This tends to require more documentation than standard small government/non-profit process and open bidding processes.
Supporting Proof for Grant Application
- Applicant documents such as:
- Union Contracts
- Labor Agreements
- Fringe Rate Calculations
- Labor Cost Support
- Work Logs
- Payroll Records
- Expenses Support
- Contracting Documents
- Proof of Payment
2. Grant Award (Obligation of Funds)
The grant lifecycle really starts at Award or Obligation. The process of making the award is typically FEMA led, or if State-led, then FEMA has a heavy hand behind the scenes. And let me define state. In 2CFR200.90, the US Government defined state to include the territories and the District of Columbia. Within the body of laws related to federal grants, we have 58 states.
3. Grant Management
After grant award, and financial obligation by FEMA, you’ll be responsible for tracking actual costs, executing procurement in accordance to federal law, and collecting documents proving you did each action that is required of you.
You may make requests of the state to extend the timeline, ask for more money, ask for reimbursement. In time, you’ll be ready to close out your grant.
Common tasks in this extended phase (typically the longest phase) include:
- Requests for Advanced Funding
- Requests for Reimbursement
- Quarterly Progress Reports
- Requests for: scope/budget change, appeals, etc
99. Grant Close Out (Your End Goal)
Your ultimate objective is to recover funds from FEMA and your state within the legal bounds. The grant lifecycle really starts with the grant application phase. You’ll provide cost estimates and describe your
mission. . You’ll collate all of your documents in a neat orderly fashion then submit to your state. Note that this maybe seem like a duplicate process. You gave them this or that. Doesn’t matter. Your close-out book is the story from Bang to Closeout inclusive.