Sneak Preview: FEMA Publishes Simplified Procedures Policy
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) The Federal Emergency Management Agency (FEMA) recently issued a Public Assistance (PA) Simplified Procedures policy aimed at streamlining the documentation requirements for small projects funded by the PA program and reducing the administrative burden on state, local, tribal and territorial governments, along with nonprofits, that receive FEMA financial grants following a disaster.
The new policy incorporates the agency’s Aug. 3, 2022, final rule that revised its PA program regulations to update the monetary threshold at which level FEMA will determine a project is a large project, raising the threshold to $1 million (see “FEMA Increases Public Assistance Threshold to $1M,” September 2022). It supersedes guidance pertaining to small projects in the FEMA’s Public Assistance Program and Policy Guide and establishes additional requirements related to small projects.
FEMA categorizes each grant awarded as either a small or large project, which is determined by a monetary threshold set each year pursuant to statute. The agency obligates money for a small project based on an estimate of the project costs, and FEMA obligates money for a large project based on actual project costs as the project progresses and cost documentation is provided.
“The Department of Homeland Security and FEMA are committed to providing equitable and accessible recovery support to affected communities,” according to the policy. “FEMA will continue adjusting the threshold annually to reflect changes in the Consumer Price Index for all urban consumers.”
Using simplified procedures for small PA projects that are based on estimates reduces final accounting and project closeout tasks. It expedites FEMA’s processing of PA grant funding by eliminating much of the administrative burden that FEMA experiences when awarding projects at or above the threshold, ultimately reducing FEMA’s cost of administering PA funding. Projects below the threshold represent the vast majority of individual projects, but a small portion of FEMA’s overall funding under the PA program.
To streamline the application process for small projects, FEMA will not adjust estimated costs to the actual incurred amount, according to the policy. Once the estimated amount is obligated, FEMA will consider it reasonable and eligible and will not re-evaluate the cost if there is no evidence of fraud, waste or abuse, and the applicant complies with federal grant conditions. The itemized cost estimate must include information to support the estimate and certify that the costs claimed directly correlate to work required to address major disaster and emergency related impacts in the project application.
(The full version of this story has now been made available to all for a limited time here.)
Join us for our following Thompson Grants events:
Federal Grants Forum for State & Local Governments | Feb. 15-16, 2022 | Virtual Event
Nonprofit Legal, Finance, and Grants Conference | April 6-7, 2023 | Washington, D.C.
