Normal federal grant guidance and rules also apply to Stafford Act grants. These are in addition to the normal FEMA rules that may be more familiar emergency management professionals.
Prior to Hurricane Katrina, FEMA and TDEM were much more focused on rules found in the guidance on specific FEMA programs. After Hurricanes Katrina, Rita and Ike and the passage of the Improper Payment Elimination and Recovery Act of 2010 (IPERA), there has been a greater focus placed on compliance with all federal grant and procurement rules. [The IPERA was passed in 2010 and requires federal agencies to conduct expanded and more rigorous recovery audits to identify and recapture improper payments, including payments without proper supporting documentation.]
Federal grants come with a wide variety of rules and regulations that must be followed. Some of the most important of these are:
Title 44 of the Code of Federal Regulations Part 13 - Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments.
Title 2 of the Code of Federal Regulations Part 200 - OMB Circulars A-21, A-87, A-102, A-110, A-122 include information on Federal Cost Principles
and A-133 contains rules on requirements for Audits of States, Local Governments and Non-Profit Organizations
Having financial and procurement professionals involved in disaster response and recovery can be instrumental in ensuring that financial rules and regulations related to federal grants are followed.
It is vitally important that the accounting and procurement professionals are on the ground as part of the overall team when disaster strikes. Emergency managers should be working with their finance and procurement office and, if they have one, their grant office when dealing with FEMA disaster grants. These offices can assist in:
During preliminary damage assessments (PDAs) accounting and procurement professionals can assist with:
Working with grant and accounting professionals once disaster grants are written and scope and deadlines have been established can help with:
Working with your procurement staff related to disaster response and recovery can be vital in following these important concepts required of procurements made with federal funds:
Your inventory staff can assist you entity in:
Both FEMA and TDEM are being required to account more closely and strictly to oversight authorities and they are in turn passing on those compliance standards to entities receiving disaster grant funds. I cannot stress enough how important financial and procurement professionals are in making sure an entity can maximize federal disaster grant reimbursements.
Please bring your financial and procurement professionals into your Emergency Management Team before the next disaster strikes.