This wraps up our series on navigating the murky waters of Federal grants following a Federal disaster declaration.
In this article, we continue our interview with Thad Leugemors, a Program Execution Manager for Tetra Tech and get further into what governmental units can do to prepare for disasters.
Listen to the whole interview below:
There are things that can be put in place prior to a disaster that will greatly increase your community’s success in dealing with various Federal agencies for reimbursement of costs related to public assistance grants for uninsured losses.
3 Things to Do Before the Disaster
Let’s shift gears just a little bit here as Thad and I talk about some tips that a community or an organization can put in place prior to disaster striking.
Here are three things that you can put in place NOW to maximize your access to disaster funds after disaster strikes:
Negotiate Standby Contracts
The concept of standby contracts has really come into favor over the last ten years or so with a lot of FEMA support.
Basically the standby contracts cover the types of immediate needs that will likely be needed post-disaster.
They include things like:
- Debris removal contracts
- Debris monitoring contracts
- Consulting services for launching the public assistance process
- Engineering services
- Additional security staff
FEMA has put together a lot of policy guidance on the standby contracts and a model of incident command.
When you do these things in advance, it puts you in a better position with FEMA to make the disaster process go smoother.
Have a Well-Documented Pay Policy in Place
It’s a given that a disaster of any scale is going to require additional hours to be worked by police, fire/rescue, emergency responders, hospital staff, and others.
By having a well-documented pay policy in place you position yourselves for maximizing the reimbursement from Federal funds.
Here’s an example:
During a disaster, you may have a number of people from the sheriff’s department operating the Emergency Operations Center. (EOC)
Their normal work week may be a salaried position around 40 hours, but during a disaster they are working 80 hours.
If the county decides to pay them more because they are working way over their salaried time, FEMA will not honor those costs for reimbursement unless there is already a pay policy in place.
And the policy has to be in place ahead of time and implemented before a disaster strikes to be eligible costs.
Have Procurement Policies in Place
When you are in the middle of dealing with a natural disaster is not the time to start putting together a procurement policy.
By having solid procurement policies in place prior to a disaster, you increase the chances that your community will receive and keep disaster recovery funds that are paid by Federal agencies.
This includes things like:
- Who can authorize spending?
- What documentation is required for various levels of spending?
- How are emergency procurements handled?
- What level of competition is required?
- How are sole source purchases justified?
- What are the responsibilities for contract administration and monitoring?
Federal grant regulations have long required written procurement procedures be in place prior to awarding Federal funds, but truthfully, enforcement of this regulation has been spotty…
That is until the new Uniform Guidance for grant management.
3 Things to Do After the Disaster
Next, when disaster strikes, be ready to help your community or organization get all the assistance that it is entitled to:
#1 Create a Master File/Audit File/FEMA File
One of the first things to do post-disaster is to determine a secure location and a responsible person to begin collecting all the required documentation.
This file should contain everything that you need to be reimbursed by the Federal government, survive closeout and be ready for audit.
This includes the project worksheets which are the heart and soul of the disaster recovery and hazard mitigation scope of work.
Note: Because records can be audited for three years after the project is closed out (let’s say it’s a road project that took five years) the requirements for record-keeping is SUBSTANTIAL and CRITICAL.
#2 Document Everything
Disasters require lots of documentation.
I mean LOTS of documentation…
And much of it can’t be recreated.
If you miss creating it at the right time, your chance of getting and keeping those Federal funds is nil.
Here are just a few examples of documentation that Thad shared in our interview:
- Turtle monitors-people who ensure protected turtles are not disturbed during beach clean up
- Cradle to grave debris removal and disposal-people who ensure that all debris is picked up, classified correct and the disposal of the materials happens only at facilities able to handle those types of material.
- Records of where the debris was picked up since only debris removed from public property is eligible for cost reimbursement.
If you can’t “prove” that these things happened when they were supposed to, the Federal government can claw back the funds that were given for related disaster recovery costs from the states, and in turn the states will want to get back funds from the municipality.
As you might expect this whole scenario turns into a political nightmare.
And though this situation could be avoided with a focus on adequate documentation and monitoring Navigating Federal Grants, the disallowance of costs happens quite often.
There is an old adage at FEMA: “Documentation, documentation, documentation Navigating Federal Grants.”
Yes, you have to do it right! (But you also have to be able to document that you did it right.)
#3 Understand Your Grant Terms and Conditions
After a disaster, it can seem like money is flowing everywhere, whether you are ready or not.
Unfortunately, what the Federal government giveth, it can taketh away Navigating Federal Grants.
This is because many governmental units and organizations have not taken the time to understand the terms and conditions that came with the Federal funding.
But you don’t have to look too far…FEMA.gov has all of their policies there online and available.
Click on the Response and Recovery section to see both individual assistance and Public Assistance: Local, State, Tribal and Non-Profit.
Go to the resource page and you’ll find a huge amount of downloadable and viewable resources listed there.
Check out When Disaster Strikes Part I
Check out When Disaster Strikes Part II
Ready to Improve Your Grant Management?
How about you?
Would you like to be a better grant manager?
We have another grant management training seminar coming soon.
Click here to get all the details!
Hope to see you there!
Author:
Lucy Morgan CPA, MBA
CEO, Compliance Warrior
Author of “Decoding Grant Management-The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.
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