FEDERAL EMERGENCY
MANAGEMENT AGENCY
CFDA 83.543 INDIVIDUAL
AND FAMILY GRANTS
I. PROGRAM OBJECTIVE
The Individual and
Family Grants (IFG) program is a cost-shared program authorized by Section
411 of the Robert T. Stafford Disaster Relief and Emergency Act (Stafford
Act), Public Law 93-288, as amended. Its purpose is to provide funds for
the necessary expenses and serious needs of disaster victims, which cannot
be met through other forms of disaster assistance or through other means
such as insurance.
II. PROGRAM PROCEDURES
The Governor may
request that a Federal grant be made to a State for the purpose of such
State making grants to individuals or families who, as a result of a major
disaster, are unable to meet disaster-related necessary expenses or serious
needs. The total Federal grant is made only on condition that 25 percent
of the actual cost of meeting individuals= or families= necessary expenses
or serious needs is paid from funds made available by the State (44 CFR
section 206.131).
The State administers
the IFG program based on a State Administrative Plan that must be approved
by FEMA each January and at the beginning of the recovery process before
Federal funds are awarded to the State. FEMA provides States administrative
expenses in an amount equal to up to five percent of the Federal share
of the program.
III. COMPLIANCE
REQUIREMENTS
In developing the
audit procedures to test compliance with the requirements for a Federal
program, the auditor should first look to Part 2, Matrix of Compliance
Requirements, to identify which of the 14 types of compliance requirements
described in Part 3 are applicable and then look to Parts 3 and 4 for
the details of the requirements.
A. Activities
Allowed or Unallowed
Activities allowed
are grants to individuals or families who, as a result of a major disaster,
are unable to meet disaster-related necessary expenses or serious needs
and State administrative expenses (44 CFR section 206.131(a)).
E. Eligibility
1. Eligibility
for Individuals
With respect to
any one major disaster, an individual or family may not receive a grant
or grants under IFG totaling more than the statutorily determined maximum
amount. This amount is $13,100 for October 1, 1996 through September
30, 1997 and $13,400 for October 1, 1997 through September 30, 1998.
The amount is adjusted annually to reflect changes in the Consumer Price
Index. FEMA notifies the States each year of the adjusted amount.
The State determines
eligibility in accordance with the IFG State Administrative Plan, as
approved by FEMA in accordance with 44 CFR section 206.131. FEMA performs
damage verifications for the State on IFG applicants who are not required
to apply for a Small Business Administration (SBA) loan, and on those
applicants referred by SBA to IFG as a result of that agency's loan
application process. FEMA conducts verifications (for States) in the
categories of housing and real property, including verification of home
ownership and primary residency, personal property, and transportation
(vehicles) for those applicants who also have real and/or personal property
losses. FEMA contract inspectors collect information for the State IFG
program because they are at the damaged residence to perform verification
on real and personal property losses. FEMA does not perform verification
for applicants that only have a vehicle loss; the State performs verifications
for those applicants. Certain damage or loss verifications are performed
by the State, such as on late applications or reinspections, medical,
dental, funeral, and other categories.
2. Eligibility
for Group of Individuals or Area of Service Delivery - Not Applicable
3. Eligibility
for Subrecipients - Not Applicable
G. Matching, Level
of Effort, Earmarking
1. Matching
Costs for payments
to individuals and families is shared on a 75 percent Federal and 25
percent State basis. The State must provide the matching for IFG at
the time of expenditure of Federal funds (e.g., when each IFG dollar
is paid, the State provides 25 cents and the Federal funds provide 75
cents) (44 CFR section 206.131(a)).
2. Level
of Effort - Not Applicable
3. Earmarking
State administrative
expenses shall not exceed five percent of the Federal grant (44 CFR
section 206.131(a)).
L. Reporting
1. Financial
Reporting
a. SF-269,
Financial Status Report - Applicable
b. SF-270,
Request for Advance or Reimbursement - Applicable
c. SF-271,
Outlay Report and Request for Reimbursement for Construction Programs -
Not Applicable
d. SF-272,
Federal Cash Transactions Report - Applicable
e. FEMA Form
76-28, Disaster Automated Reporting and Information System (DARIS)
Status Report (OMB No. 3067-0163).
Key line item
is 9, $ Amount of Payments Disbursed to Date.
2. Performance
Reporting - Not Applicable
3. Special
Reporting - Not Applicable
FEDERAL
EMERGENCY MANAGEMENT AGENCY
CFDA 83.544 PUBLIC
ASSISTANCE GRANTS
I. PROGRAM OBJECTIVE
The objective is
to provide assistance to States, local governments, and selected non-profit
organizations under the Public Assistance Program.
II. PROGRAM PROCEDURES
Following a Presidential
declaration of a major disaster or an emergency, the Federal Emergency
Management Agency (FEMA) awards grants for public assistance to States.
The State may use the funds to restore its own disaster-damaged projects
and to provide subgrants to local governments and selected private non-profit
facilities.
The Public Assistance
program is administered by the State (e.g., the State Emergency Agency)
in accordance with a FEMA-State Agreement to provide assistance which
may be available under an emergency or major disaster declaration. The
State acts as the grant administrator for all funds provided under the
Public Assistance grant program. The grant administrator's responsibility
includes providing technical advice and assistance to eligible subgrantees,
providing State support for damage survey activities, ensuring that all
potential applicants are aware of assistance available, and submission
of documents necessary for grant awards (44 CFR sections 206.200 through
206.253).
For purposes of the
Public Assistance program, the following terms will be used:
State -
The State Agency which is defined as the Grantee under FEMA regulations
and acts as the grant administrator for the program.
Subgrantee
- The government or other legal entity to which a subgrant is awarded
and which is accountable to the grantee for the use of the funds provided
(44 CFR section 206.201(l)). (For example, in explaining this program,
a State Highway Agency is considered a subgrantee of a State Emergency
Agency even though both agencies may be included in the same State-wide
single audit.)
RD - The
FEMA Regional Director .
Public Assistance
program awards are made based upon a Damage Survey Report (DSR) which
is prepared by an inspection team. The inspection team normally includes
a representative of FEMA, the State, and any subgrantee. The DSR documents
the inspection team's determination of the eligible scope of work and
cost estimate. The Public Assistance Program will fund a part of this
eligible work in accordance with the FEMA-State Agreement. Each DSR has
a control number and any supplemental DSRs will be referenced to the original
DSR.
Project funding made
for large and small projects is based upon the cost of the eligible work
for the individual project. Projects which equal or exceed the threshold
of $47,100 for October 1, 1997, through September 30, 1998 ($46,000 for
October 1, 1996, through September 30, 1997), are large projects. Projects
below this threshold are small projects. This threshold is adjusted by
FEMA each October to reflect changes in the Consumer Price Index. The
thresholds are published in the Federal Register. The date the
disaster is declared on a disaster declaration determines the threshold
in use.
Small Projects
For small projects,
final payment of the Federal share of eligible costs is made upon approval
of the project. The amount awarded for small projects based on the DSR
generally will not change except under unusual circumstances, such as
the work was not done, there is an unexpected insurance recovery, or there
is an obvious error in calculation. At close-out of the disaster contract,
the State is required to certify that all projects were properly completed
and that the State contribution, as specified in the FEMA-State Agreement,
was paid to each subgrantee. However, this certification does not specify
the amount spent by a subgrantee on small projects. If the actual cost
for small projects is less than the estimated cost on the DSR, FEMA generally
will not ask for a refund. Similarly, FEMA generally will not provide
additional funding when actual costs exceed the DSR estimate. However,
provision is made that, when a subgrantee has significant overruns, a
request may be made to FEMA for additional funding based upon the total
final costs for all small projects (44 CFR sections 206.204(e) and 206.205(a)).
Large Projects
For large projects,
the State must make an accounting to FEMA of eligible costs for each approved
large project. In submitting the accounting, the State must certify that
reported costs were incurred in the performance of eligible work, that
the approved work was completed, that the project is in compliance with
the FEMA-State Agreement, and that payments for the project have been
made in accordance with the A-102 Common Rule's requirements for payment.
The subgrantee is required to make similar accounting and certifications
to the State. If actual costs are less than the approved amount, then
the FEMA share will be based upon the actual costs. The subgrantee may
request additional funding for eligible cost overruns on large projects.
For additional funding, these requests must include a written recommendation
from the State and approval of the RD (44 CFR sections 206.204(e) and
206.205).
Improved Projects
If a subrecipient
desires to make improvements, but still restore the pre-disaster function
of a damaged facility, State approval must be obtained. Federal funding
for an improved project is limited to the Federal share of the approved
estimate of the eligible costs. Funds approved as an improved project
can only be used as a contribution for the construction of larger or improved
facilities that restore at least the pre-disaster capacity of the damaged
or destroyed facility. For example, if eligible work to restore the pre-disaster
capacity is $100,000, and the subgrantee chooses to rebuild an improved
facility which costs $200,000, then the FEMA share is only based on the
$100,000. However, if the actual costs is less than the eligible work
of $100,000 (e.g., construction costs are much lower than expected), then
a FEMA adjustment is required (44 CFR section 206.203).
Alternate Projects
In a case where the
subgrantee determines that the public welfare would not be best served
by restoring a damaged public facility, the State may request that FEMA
approve an alternate project. Federal funding for such alternate projects
is based on 90 percent of the approved estimate of eligible costs (44
CFR section 206.203(d)(2)). For example, if the approved estimate of eligible
costs to restore the pre-disaster capacity is $100,000, and the entity
chooses not to rebuild but instead to do alternate work, then assuming
a 75 percent match, the Federal share is computed as:
Approved estimate
of eligible costs $100,000
Assumed match of
75% Federal/25% State X 75%
Subtotal
$ 75,000
Adjustment for
alternate project X 90%
Federal share
$ 67,500
Funds contributed
for alternate projects may be used to repair or expand other selected
public facilities, to construct new facilities, or to fund hazard mitigation
measures. These funds may neither be used to pay the non-Federal share
of any project nor for any operating expense (44 CFR section 206.203(d)(2)).
Funds approved for
an alternate project can be used only for alternate projects specifically
approved by FEMA. While the States and subgrantees have flexibility to
propose the type and size of alternate projects they wish to construct,
FEMA must review such proposed projects to ensure compliance with environmental
and other special concerns (44 CFR section 206.203).
III. COMPLIANCE
REQUIREMENTS
In developing the
audit procedures to test compliance with the requirements for a Federal
program, the auditor should first look to Part 2, Matrix of Compliance
Requirements, to identify which of the 14 types of compliance requirements
described in Part 3 are applicable and then look to Parts 3 and 4 for
the details of the requirements.
A. Activities
Allowed or Unallowed
The
allowed activities for the Public Assistance program are for the approved
project as described on the DSR and supporting documentation.
B. Allowable
Costs/Cost Principles
1. Equipment
Rental
The
Public Assistance program restricts eligible direct costs for applicant-owned
equipment used to perform eligible work to reasonable rates that were
established under State guidelines, or when the hourly rate exceeds
$75, rates may be determined on a case by case basis by FEMA. When
local guidelines are used to establish equipment rates, reimbursement
is based on those rates or rates in a Schedule of Equipment Rates
published by FEMA, whichever is lower. Provision is also made when
no rates are established or the entity wishes to claim an equipment
rate which exceeds the FEMA Schedule (44 CFR section 206.228).
2. Administrative
Costs
All
administrative costs of Public Assistance programs at the subgrantee
level are covered by a specific percentage in the Stafford Act (42
USC 5121 et seq.). No costs of administering the program other than
that percentage should be charged by a subgrantee. For States, administrative
costs are allowed for extraordinary costs incurred by the State for
preparation of DSRs, final inspection reports, project applications,
financial audits, and related field inspections by State employees,
including overtime pay and per diem and travel expenses. However,
regular time for such employees is not covered by the percentage allowance
under the Stafford Act. States are permitted to recover the straight
time salaries and certain other direct management costs when prescribed
on a DSR (44 CFR section 206.228).
3. Force
Account Labor Costs
The
straight- or regular-time salaries and benefits of a subgrantee's
permanently employed personnel are not eligible in calculating the
cost of eligible work for emergency protective services or debris
removal under sections 403 and 407 of the Stafford Act (42 USC 5170b
and 5173, respectively). For performance of eligible permanent restoration
under section 406 of the Stafford Act (42 USC 5172), straight-time
salaries and benefits of a subgrantee's permanently employed personnel
are eligible (44 CFR section 206.228(a)(4)).
4. Insurance
and other recoveries
Auditor's
are advised that there are likely to be amounts from insurance settlements,
salvage, or other sources which must be considered in determining
allowable costs because allowable costs must be net of applicable
credits.
G. Matching,
Level of Effort, Earmarking
1. Matching
Costs
must be on a shared basis, as specified in the FEMA-State agreement
(Public Law 93-288 as amended by the Stafford Act, 42 USC 5121 et seq.;
44 CFR 206.203(b)). In general, the minimum Federal share is 75 percent
of eligible costs. The matching split between the State and the subgrantee
will vary. The accountability for meeting the matching requirement is
determined at the time of project accounting as part of project closeout,
(e.g., the State match does not have to be provided until the end of
the project).
2. Level
of Effort - Not Applicable
3. Earmarking
- Not Applicable
L. Reporting
1. Financial
Reporting
a. SF-269,
Financial Status Report - Applicable
b. SF-270,
Request for Advance or Reimbursement - Not Applicable
c. SF-271,
Outlay Report and Request for Reimbursement for Construction Programs -
Applicable
d. SF-272,
Federal Cash Transactions Report - Applicable
e. Public
Assistance Program (OMB No. 3067-0151) - The State is required
to submit quarterly financial and progress reports to the RD. The
reports should describe the status of those projects on which a final
payment of the Federal share has not been made to the State and outline
any problems or circumstances expected to result in non-compliance
with the approved grant conditions (44 CFR section 206.204(f)). Subgrantee
reporting is as required by the State. The auditor is only required
to test the financial amounts on these reports.
2. Performance
Reporting - Not Applicable
3. Special
Reporting - Not Applicable
N. Special
Tests and Provisions
1. Project
accounting
Compliance
Requirement - For large projects, the State is required to make
an accounting to FEMA of eligible costs. Similarly, the subgrantee must
make an accounting to the State. In submitting the accounting, the entity
is required to certify that reported costs were incurred in performance
of eligible work, that the approved work was completed, that the project
is in compliance with the provisions of the FEMA-State Agreement, and
that payments for that project were made in accordance with the A-102
Common Rule's payment provisions. For improved and alternate projects,
if the total cost of the projects does not equal or exceed the approved
eligible costs, then the auditor should expect to see an adjustment
to reduce eligible costs (44 CFR section 206.205).
Audit
Objective - Determine whether ongoing and completed projects were
accounted for in accordance with the required certification.
Suggested
Audit Procedures
Projects
not completed
a. Select
a sample of ongoing large projects and ascertain if costs submitted
for reimbursement were in compliance with the requirements for eligible
work under the applicable DSR. Testing should consider the differences
in the requirements and approvals required of improved and alternate
projects.
Completed
projects
b. Select
a sample of large projects completed during the audit period and ascertain
if the entity's files document the total costs as allowable costs
and if the costs are for allowable activities under the applicable
DSR. This testing should consider the differences in the requirements
and approvals required of improved and alternate projects.