Published: April 29, 2020

The Federal Emergency Management Agency’s (FEMA) Public Assistance Program was activated March 13, 2020, when President Trump declared the ongoing coronavirus pandemic an emergency under the Stafford Act. With recent passage of the CARES Act, the program has received an influx of resources available to state and local governments.

Based on our years of experience auditing FEMA public assistance grants and FEMA’s current guidance, we have a few suggestions and resources for you:

Document your expenses

It is critical to have robust documentation of your costs. FEMA provides some information about its expected level of documentation in its frequently asked questions, such as:

  • The information required for your documentation basically describes the “who, what, when, where, why, and how much” for each item of disaster recovery work. 
  • All of the documentation pertaining to a project should be filed together with the corresponding Project Worksheet and maintained by you as the permanent record of the project.
  • It is your responsibility to document all costs associated with your projects. Failure to properly document any project may result in loss of funding for any claimed work.

For a free resource to help you track disaster-related costs, International City/County Management Association (ICMA) strategic partner Haggerty Consulting has provided a toolkit available for download: icma.org/articles/article/tracking-and-managing-coronavirus-recovery-costs

Document your justification of sole source

This fact sheet on emergency procurement includes a template that walks you through how to draft your justification for claiming sole source exception, such as in an emergency circumstance.

www.fema.gov/news-release/2020/03/20/procurement-under-grants-under-exigent-or-emergency-circumstances

Unless you can support a bid exception such as for an emergency, federal grant requirements mandate that you procure using the most restrictive of federal, state or local laws.

Check for federal suspension or debarment

You’ll want to check that those you are entering into contracts with are not prohibited from doing business with the federal government. Make sure you are familiar with this requirement, because you have several options for meeting it. Also, you’ll want to document the steps you took to meet this requirement. It can be as easy as checking the sam.gov/SAM/ website (this shows the suspended and debarred parties) and printing a screenshot that shows the date of your search! Also, it’s a best practice to do this for all procurements just in case you later decide to charge those costs to a federal award.

Schedule of Expenditures of Federal Awards (SEFA) reporting

Because the costs are incurred in different periods than when the FEMA project worksheets are approved, there can be confusion regarding when to report these on your SEFA. In some cases, governments have reported them twice. We want you to know that they should be reported only once: after both the costs are incurred and the project worksheet is approved. You can find more information about preparing the SEFA specifically for FEMA assistance here:

www.sao.wa.gov/bars_gaap/reporting/supplementary-and-other-information/expenditures-of-federal-awards-schedule16/

If you have questions later, please reach out to us using our helpdesk service.

Additional resources

In case you missed it, check out the following blog post for additional resources about federal grants, including FEMA:

www.sao.wa.gov/check-out-these-top-resources-about-federal-assistance-during-covid-19/

Other resources include:

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