324 Management Questions—Public Assistance Program

Why does the Grantee need to do a budget after it receives the lock-in
amounts when the Grantee has already identified budget considerations in
the State Administration Plan?

The documentation requirement is that a plan must be submitted stating
how the grantee will use the money over the life of the grant.  The plan
should show how the funds will be spent in each year.  Since the 3.34
percent for a major disaster and 3.90 percent for emergencies are caps,
the plan should spread the planned expenditures over the duration of the
disaster so that the funding is not exhausted before the grant is
closed.  There may be overlap between the documentation that must be
submitted to allow obligation of funding for Section 324 Management
Costs and the documentation that is submitted for the State
Administrative Plan.

What does this budget have to look like?  Does it have to identify costs
per major category with specific amount attached to each category or can
the Grantee just list the item it hope to pay for with the available
funds?

The documentation must include a description of activities, personnel
requirements, and other costs for which the grantee will use Section 324
Management Costs funding throughout the disaster; the grantee’s plan
for expending and monitoring the funds provided and ensuring sufficient
funds are budgeted for grant closeout; and, an estimate of the
reasonable percentage or amount of pass-though funds the grantee will
make available to subgrantees, including the basis, criteria, or formula
for the determination. 

(See DAP 9525.9, Section 324 Management Costs and Direct Administrative
Costs, Paragraph VII.C.7. and 44 CFR §207.7(d).)

 

Can the Grantee still send in a percentage of time spent per each
disaster, or does it have to be more specific?

The documentation must be reviewed and approved by the Regional
Administrator prior to the funding of more than 25 percent of the
initial lock-in amount.

Documentation must include a description of activities, personnel
requirements, and other costs for which the grantee and subgrantees will
use Section 324 Management Costs funding throughout the disaster.  The
documentation must include proposed management costs such as utility
costs to be apportioned to the disaster, personnel (position titles and
percentage of time for each position), equipment rentals and purchases,
purchases of supplies, and acquisition of other equipment, such as cell
phones.  (See 44 CFR §207.7 and DAP 9525.9, Section 324 Management
Costs and Direct Administrative Costs, Paragraph VII.C.7. for additional
documentation requirements.)

 



How will the Grantee apply for reimbursements from FEMA?

The grantee will submit its initial Section 324 Management Costs funding
request to the Regional Administrator using a Project Worksheet.  Upon
receipt of the Project Worksheet and in accordance with 44 CFR
§207.7(b) and (c), the Regional Public Assistance Branch Chief will
obligate 25 percent of the estimated lock-in amount.  As required by
regulation, the State Administrative Plan must be amended to include
procedures for subgrantee management costs amount or percentage
determination, pass through, closeout, and audit before management funds
will be provided.  (See 44 CFR §207.5(b)(1) and 44 CFR §207.7(b).)  To
simplify processing and tracking, Standard Project 853-Section 324
Management Costs has been established as the project title in the
National Emergency Information Management System (NEMIS) and the
Emergency Management Mission Integrated Environment (EMMIE).  The
Project Worksheet will be processed under category Z.  (See DAP 9525.9,
Section 324 Management Costs and Direct Administrative Costs, Paragraph
VII.C.6.)

Does the Regional Office still have authority to approve reimbursement
request amounts up to $150,000 or does everything have to go to FEMA
National?

The funding process is different from the past way of operating.  FEMA
Headquarters does not review requests in the way it formerly did.  The
FEMA Chief Financial Officer issues lock-in letters that are sent to the
Regional Administrator.  They are issued at 30-35 days (preliminary
lock-in), six months (interim lock-in) and 12 months (final lock-in)
from the date of the declaration.  The Regional Administrator will
inform the grantee of the lock-in amount.  (See DAP 9525.9, Section 324
Management Costs and Direct Administrative Costs, Paragraph VII.C.4. and
44 CFR §207.5(b).)

   

Is there anything the Grantee should have done/be doing when it receives
the 30-day, six-month and 12-month lock-in amounts?

The State Administrative Plan must be amended before management costs
can be funded.  (See 44 CFR §207.7(b).)  In order to receive Section
324 Management Costs funding, the grantee must request funding upon
notification of the preliminary lock-in (initial funding request) and
upon notification of the final lock-in (final funding request).  (See
44 CFR §207.7(b), (c), and (f).)  With a demonstration of need, the
grantee also may request interim funding upon notification of the
six-month interim lock-in (interim funding request).  (See DAP 9525.9,
Section 324 Management Costs and Direct Administrative Costs, Paragraph
VII.C.5. and 44 CFR §207.7(e).)

The grantee must develop the information for the amendment to the State
Administrative Plan as required by 44 CFR §207.7(b) prior to requesting
management cost funding.  When the State Administrative Plan is amended,
the grantee submits its initial Section 324 Management Costs funding
request to the Regional Administrator using a Project Worksheet.  Upon
receipt of the Project Worksheet and in accordance with 44 CFR
§207.7(b) and (c), the Regional Public Assistance Branch Chief will
obligate 25 percent of the estimated lock-in amount.  (See also
44 CFR §207.5(b)(1) and 44 CFR §207.6(c).)  To simplify processing
and tracking, Standard Project 853-Section 324 Management Costs has been
established as the project title in the National Emergency Information
Management System (NEMIS) and the Emergency Management Mission
Integrated Environment (EMMIE).  The Project Worksheet will be processed
under category Z.  (See DAP 9525.9, Section 324 Management Costs and
Direct Administrative Costs, Paragraph VII.C.6.)

What are the specifics on allowable costs and cost share for state
management under the new guidance?

Allowable costs include equipment, materials, contracts, and other costs
required to manage the grant.  Section 324 Management Costs are 100
percent federally funded.  Direct costs tied to specific projects are
cost-shared at the prevailing cost-share rate for the declaration. (See
DAP 9525.9, Section 324 Management Costs and Direct Administrative
Costs, Paragraphs VII.C.4 and VII.D.5.) 

What are acceptable methods to allocate costs to the benefiting
disasters?  How does the Grantee prorate such costs as utilities when it
has several active disasters working?

For each disaster, costs must be allocated to assure that funding is not
exhausted prior to the closeout of the disaster.  As long as this is
done, prorating costs among active disasters may be done by any method
acceptable to the Regional Administrator.  

What is the current report format to request quarterly reimbursement? 
What specific information should be included in each request?

There will not be quarterly reimbursements.  Once the final lock-in
amount has been established, the grantee can request that the full
amount of funding be obligated.  However, quarterly progress reports to
the Regional Administrator are required.  (See 44 CFR 207.8(c) and DAP
9525.9, Section 324 Management Costs and Direct Administrative Costs,
Paragraph VII.C.15.)  The quarterly reports should address the amount
and percentage of management costs expended relative to the percentage
of work completed on the disaster.  

When can the Grantee expect to see any state management funds in
Smartlink?  What steps must be completed to get the money flowing?

The Project Worksheets are processed in the same method as other Project
Worksheets.  

Explain the difference between indirect/direct costs.  What other types
of items are chargeable under indirect besides salaries?

Indirect costs are costs a grantee or subgrantee incurs for a common or
joint purpose benefiting more than one cost objective that are not
readily assignable to the cost objectives specifically benefited.  (See
44 §CFR 207.2 and DAP 9525.9, Section 324 Management Costs and Direct
Administrative Costs, Paragraph VII.A.3.)

Direct administrative costs are costs incurred by the grantee or
subgrantee that can be identified separately and assigned to a specific
project.  In accordance with OMB Circular No. A-87, treatment of direct
costs must be consistent across all Federal awards and other activities
of the grantee and subgrantee.  Such costs can include staff’s time to
conduct an initial inspection, prepare and submit a Project Worksheet,
and make interim and final inspections of the project, travel expenses,
material, equipment, and supplies.  (See DAP 9525.9, Section 324
Management Costs and Direct Administrative Costs, Paragraph VII.A.2.)

How does the Grantee claim costs for other items, such as cell phones,
office utilities, supplies, and equipment, etc.?  And, does the Grantee
need the region’s approval before submitting them?

These are indirect costs covered by the Section 324 Management Costs
funding.  (See 44 CFR §207.2 and DAP 9525.9, Section 324 Management
Costs and Direct Administrative Costs, Paragraph VII.A.3.)  Items such
as these must be included in the documentation that is submitted to the
Regional Administrator for approval no later than 120 days after the
date of the declaration. 

 The Grantee has four small disasters with little management costs
funding.  Since the percentage is only 3.34%, what happens when all
management funds are spent and additional money is needed to finish out
the program?

The amount of funding available cannot exceed the amount calculated in
accordance with 

44 CFR §207.5(b)(4).  (See also DAP 9525.9, Section 324 Management
Costs and Direct Administrative Costs, Paragraph VII.B.2.). 

How can the Grantee get reimbursed for its direct administration that is
chargeable to each Project Worksheet for the Grantees which is under
$1,000?  Realistically, the Grantee cannot claim $1,000 for every
Project Worksheet and because of this it would be out of a lot of
personnel time and money (travel, per diem, OT) for the time it spent in
the field with the FEMA project officers, and other work with the
applicants.  This includes extra help (ADAT/reservists program).  Any
alternative?  The indirect is not an option because of limited funding.

Direct costs on a project must be accounted for on that project.  The
direct cost on multiple Project Worksheets cannot be grouped.  A
Category Z Project Worksheet with an estimate less than $1,000 is not
eligible. (See DAP 9525.9, Section 324 Management Costs and Direct
Administrative Costs, Paragraph VII.D.7.h.)

Is the final lock-in (12 months) the final estimate or can additional
lock-in amounts be requested if the Grantee has cost overruns on large
projects.  The past has shown that the disaster estimate can increase
after 12 months.

The grantee can submit a written request to the Regional Administrator
to change the amount of the lock-in, and the time at which lock-in
amount is determined.  The Regional Administrator will forward his/her
recommendation to the FEMA Chief Financial Officer for approval.  (See
44 CFR §207.5(d) and DAP 9525.9, Section 324 Management Costs and
Direct Administrative Costs, Paragraph VII.C.11.)

What is the benefit/reasoning behind lock-in amounts?  Does this give
the Grantee an opportunity to use the funds sooner and send supporting
documentation later?

The lock-in system benefits grantees by expediting funding for indirect
costs and by expanding on the types of costs that were eligible with the
previous Administrative Allowance (also known as the sliding scale or
Statutory Administrative Costs).  No management costs may be funded
until the grantee complies with the requirements of 44 CFR §207.7(b),
that is, until the grantee provides the information for the amendment to
the State Administrative Plan.  Since the lock-in letter is issued
within 30-35 days of the declaration, the Project Worksheet requesting
the initial funding (up to 25 percent of the lock-in amount) may be
prepared and approved prior to the submission of the required management
cost documentation which is due within 120 days of the declaration. 
(See 44 CFR §207.7(b) and (d) and DAP 9525.9, Section 324 Management
Costs and Direct Administrative Costs, Paragraph VII.C.7.)

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