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Procurement Authority to Utilize Gsa Federal Grant Results

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					      GPD
  Grant Programs Directorate

          Grants Made Easy:
Awarding and Monitoring Federal Grants

             June 20, 2008




                                         1
                                                      U.S. DEPARTMENT OF HOMELAND SECURITY


                                                                                            SECRETARY                                           Executive
                                                                                          ________________                                      Secretariat
                                                                                                                       Chief of Staff
                                                                                        DEPUTY SECRETARY
                                                                                                                                             Military Advisor




                             SCIENCE &             NATIONAL PROTECTION
  MANAGEMENT                                                                     POLICY                                     LEGISLATIVE AFFAIRS         PUBLIC AFFAIRS
                            TECHNOLOGY                 & PROGRAMS                                    GENERAL COUNSEL                                                           INSPECTOR GENERAL
  Under Secretary                                                           Assistant Secretary                               Assistant Secretary       Assistant Secretary
                            Under Secretary            Under Secretary




  Chief Financial
      Officer
                                                                                                       CITIZENSHIP &
                           HEALTH AFFAIRS            INTELLIGENCE &          OPERATIONS                                                               CIVIL RIGHTS & CIVIL     COUNTERNARCOTICS
                                                                                                       IMMIGRATION              CHIEF PRIVACY
                           Assistant Secretary/         ANALYSIS            COORDINATION                                                                   LIBERTIES             ENFORCEMENT
                                                                                                         SERVICES                  OFFICER
                           Chief Medical Officer      Under Secretary*         Director                                                                       Officer               Director
                                                                                                       OMBUDSMAN




                                                       FEDERAL LAW                                       NATIONAL
                                                                          DOMESTIC NUCLEAR
                                                      ENFORCEMENT                                     CYBER SECURITY
                                                                           DETECTION OFFICE
                                                     TRAINING CENTER                                      CENTER
                                                                                Director
                                                          Director                                        Director




   TRANSPORTATION
       SECURITY               U.S. CUSTOMS & BORDER          U.S. CITIZENSHIP &         U.S. IMMIGRATION &                                      FEDERAL EMERGENCY
                                                                                                                   U.S. SECRET SERVICE                                        U.S. COAST GUARD
    ADMINISTRATION                  PROTECTION             IMMIGRATION SERVICES       CUSTOMS ENFORCEMENT                                       MANAGEMENT AGENCY
                                                                                                                          Director                                                Commandant
   Assistant Secretary /            Commissioner                   Director              Assistant Secretary                                        Administrator
      Administrator




* Under Secretary for Intelligence & Analysis title created by Public Law 110-53, Aug. 3rd, 2007

Approved 3/20/2008




                                                                                                                                                                                                   2
                                                       FEDERAL EMERGENCY MANAGEMENT AGENCY

                                                                                              ADMINISTRATOR
                                                                                            ____________________

                                                                                          DEPUTY ADMINISTRATOR




                           ASSOCIATE DEPUTY
                                                    LAW ENFORCEMENT                                                                                        ASSOCIATE DEPUTY
                            ADMINISTRATOR                                     POLICY & PROGRAM               EXECUTIVE
                                                     ADVISOR TO THE                                                              EXTERNAL AFFAIRS           ADMINISTRATOR
                              GULF COAST                                          ANALYSIS                  SECRETARIAT
                                                     ADMINISTRATOR
                               RECOVERY




                                                                                                                                                              REGIONAL
                                                                                                                                     NATIONAL
                                                      CHIEF FINANCIAL                                                                                      ADMINISTRATORS
                              EQUAL RIGHTS                                       MANAGEMENT                CHIEF COUNSEL          CAPITAL REGION
                                                          OFFICER                                                                                            (10 Regions &
                                                                                                                                   COORDINATION
                                                                                                                                                            Regional Offices)




                                                                                                                                       U.S. FIRE
                                                                                                                                                                 NATIONAL
     LOGISTICS                  DISASTER                  DISASTER                                           NATIONAL             ADMINISTRATION/
                                                                              GRANT PROGRAMS                                                                   CONTINUITY                 MITIGATION
   MANAGEMENT                 ASSISTANCE                OPERATIONS                                         PREPAREDNESS            NATIONAL FIRE
                                                                              Assistant Administrator                                                           PROGRAMS             Assistant Administrator
Assistant Administrator   Assistant Administrator   Assistant Administrator                               Deputy Administrator         ACADEMY
                                                                                                                                                           Assistant Administrator
                                                                                                                                 Assistant Administrator




  Approved 4/1/2007




                                                                                                                                                                                                               3
FEMA Grant Programs Directorate (GPD)

Our Mission…
To provide a unified, solutions oriented approach to federal
financial assistance management in support of FEMA’s
multi-faceted mission, priorities and customer base.


Our Vision…
The recognized leader valued for proactive federal financial
assistance management that prepares the American public
and supports them in their times of greatest need.




                                                               4
Scope of FEMA Grant Programs
•   Provide grants management business services

•   50 Grant Programs at FEMA across 7 Directorates; also award and manage
    one-time grant awards (i.e., earmarks)

     – 6 disaster grant programs
     – Disaster and non-disaster grant programs follow different processes

         • Regional grants staff do not award disaster grants, but do manage
           them. Program Staff have award authority per Program
           Regulations.

•   2007 Data
     – Non Disaster
         • 7646 grants awarded (grants not projects)
         • Over $5B awarded
     – Disaster
         • 129 grants awarded (grants not projects)
         • Over $5B awarded


                                                                               5
FY 2007 Grant Awards
Type of Grants                      Number of Awards   FY 2007
Assistance to Firefighters Grants   6436               $    672,280,341

Preparedness                        788                $   3,697,455,785

Disaster Assistance                 129                $   5,471,384,499

Non-Disaster Grants                 422                $    785,490,791

Total Awarded in FY 07              7775               $ 10,626,611,416




                                                                           6
                                                                               6
  FEMA Grant Programs by Directorate

U.S. Fire Administration                             Mitigation
 –    Reimburse Firefighting on                       –   Earthquake Consortium
      Federal Property*                               –   National Dam Safety
 –    Degrees at a Distance*                          –   Cooperating Technical Partners
 –    Training Assistance*                            –   Map Modernization Management Support
 –    State Fire Training Systems Grants              –   Community Assistance Program –State Support
 –    TRADE Grants                                        Services Element
 –    NFA Education Programs*                         –   Flood Mitigation Assistance
 –    EMI Independent Study*                          –   Repetitive Flood Claims
 –    EMI Residential Educational*                    –   Pre-Disaster Mitigation Competitive
 –    EMI Training Assistance*                        –   Hazard Mitigation Grant Program
 –    Fire Service Hazardous Materials                –   Severe Repetitive Loss
 –    PARADE Grants
 –    Safe Kids
                                                      Disaster Operations
                                                      –   Urban Search and Rescue Cooperative Agreements



      Color Code
      HQ Grant Programs
      Currently in Regions

*Direct Federal Assistance, loan, stipend programs




                                                                                                           7
 FEMA Grant Programs by Directorate

Disaster Assistance                                        Grant Programs
 –   Alternative Housing Pilot Program                       –   Assistance to Firefighters Grant (AFG) Program
 –   Debris Removal Insurance                                –   Staffing for Adequate Fire Emergency Response Grant
 –   Disaster Donations Management                               Program (SAFER)
 –   Katrina Case Management                                 –   Homeland Security Grant Program (HSGP)
 –   9/11 Heroes Stamps *                                            • State Homeland Security Program (SHSP)
 –   Emergency Food and Shelter National                             • Urban Areas Security Initiative (UASI)
     Board                                                           • Metropolitan Medical Response Grants (MMRS)
 –   Fire Management Assistance                                      • Citizen Corps Program (CCP)
 –   Public Assistance                                       –   Transit Security Grant Program (TSGP)
 –   Crisis Counseling Program                                       • Intercity Passenger Rail Security (Amtrack)
 –   Individuals and Households - Other Needs                        • Freight Rail Security Grant Program (FRSGP)
 –   Community Disaster Loans *                              –   Port Security Grant Program (PSGP)
 –   Cora Brown Fund *                                       –   Intercity Bus Security Grant Program (IBSGP)
 –   Disaster Unemployment Assistance *                      –   Trucking Security Program (TSP)
 –   Disaster Legal Services *                               –   Buffer Zone Protection Program (BZPP)
 –   Disaster Housing Operations for                         –   Emergency Operations Centers (EOC)
     Individuals and Households *                            –   Operation Stonegarden (OPSG)
 –   Disaster Housing Assistance *                           –   Interoperable Emergency Communication Grants (IECG)
                                                             –   UASI Non-Profit
                                                             –   Public Safety Interoperable Communications (PSIC)
     Color Code                                                  Program
     HQ Grant Programs                                       –   Emergency Management Performance Grant (EMPG)
     Currently in Regions                                    –   Real ID Grant Program

      *Direct Federal Assistance, loan, stipend programs

                                                                                                                       8
     FEMA Grant Programs by Directorate

National Preparedness

 –   System Assessment and Validation for Emergency Responders (SAVER)*
 –   National Training Program
 –   Competitive Training Grant
 –   Homeland Security Preparedness Technical Assistance
 –   Systems Support Grant Program
 –   Chemical Stockpile Emergency Preparedness Program (CSEPP)
 –   Commercial Equipment Direct Assistance Program (CEDAP) *
 –   Regional Catastrophic Preparedness Grant Program




      Color Code
      HQ Grant Programs
      Currently in Regions

 *Direct Federal Assistance, loan, stipend programs


                                                                          9
Evolution of GPD
•   FEMA formed in 1979 to respond to natural disasters and civil
    emergencies

•   Grants Management Branch established within the Office of Chief
    Procurement Officer

•   Office of Justice Programs (OJP) establishes the Office for Domestic
    Preparedness (ODP)

•   Homeland Security Act of 2002 – ODP transferred to DHS March 1, 2003

•   2003 – Office of State and Local Government Coordination and
    Preparedness (SLGCP)

•   2005 – SLGCP is incorporated under the Preparedness Directorate as the
    Office of Grants & Training (G&T)

•   Post Katrina Emergency Management Reform Act (PKEMRA) of 2006 –
    Preparedness to FEMA as of April 1, 2007

•   Grants Management Branch, Preparedness Programs Division (PPD),
    Office of Grant Operations (OGO) combined to form the Grant Programs
    Directorate

                                                                             10
                    Grant Programs Directorate (GPD)
                                     Office of the Assistant
                                      Administrator for
                                       Grant Programs
                                      W. Ross Ashley III


    Grant Development &             Business Support & Data     Financial Accountability &
Administration Division (GD&A)      Analysis Division (BSDA)    Oversight Division (FAO)
           T. Trautman                      L. Lewis                     L. Lewis



     Assistance to Firefighters                Systems                    Operations
              B. Cowan                       B. Costa (A)                 J. Capps (A)




    Transportation Infrastructure      Reporting and Analysis        Financial Monitoring
              Security
                                             C. Toro (A)                 N. Baugher (A)
          M. McNamara (A)



                                       Regional Operations &                 Audit
   Homeland Security Programs            Business Support                M. Lloyd (A)
                                             J. Cramer (A)
           E: J. Hampton
          C: M. Larson (A)
            W: J. Marks
                                              Training
                                           D. Simmons (A)
      Program Development
          Stacey Street (A)


                                                                                             11
Grant Development & Admin. – GD&A


                        Grant Development and
                        Administration (GD&A)




                                       Regional Operations
 Assistance to   Transportation        Homeland Security
                                       & Business Support     Program
  Firefighters   Infrastructure             Programs
                                                             Development
                    Support
GD&A - Assistance to Firefighters (AFG)

• Oversee funding for firehouses
  and EMS rescue organizations

• Develop grant guidance and
  reports

• Administer and programmatically monitor grants (e.g.
  award, execution, closeout)




                                                         13
GD&A - Transportation Infrastructure Security

• Programmatic grant oversight for the majority
  of Infrastructure Protection Program (IPP)
  components

• Key programs include
  IBSGP, PSGP
  and TSGP




                                                  14
GD&A - Homeland Security Programs

• Programmatic grant
  oversight for Homeland
  Security Preparedness
  Programs

• Key programs include
  EMPG and HSGP (CCP,
  MMRS, SHSP, and UASI)



                                    15
GD&A - Program Development


• Establish program
  guidance for new and
  existing grant programs

• Provide programmatic grant program
  administration activities as related to award
  execution and closeout for technical
  assistance elements of HSPTAP


                                                  16
               BSDA and FAO


Business Support & Data    Financial Accountability &
Analysis Division (BSDA)    Oversight Division (FAO)




          Systems                   Operations




  Reporting and Analysis       Financial Monitoring




   Regional Operations &               Audit
     Business Support




          Training




                                                        17
BSDA/FAO has 7 Functional Areas


 •   Policy
 •   Regional Operations
 •   Operations (HQ)
 •   Systems
 •   Training
 •   Reporting and Analysis
 •   Audit (A-133)



                                  18
Functional Areas

• Each functional area plays a unique and
  interrelated role in the organization.

• All require extensive knowledge of the Federal
  requirements for all grants as outlined in
  legislation, OMB Circulars, Regulations.

• Every functional area ensures compliance,
  standardization, and internal controls.


                                                   19
Compliance

 –   Federal Grant and Cooperative Agreement Act
 –   Authorizing Legislation (i.e. 9-11 Act, Stafford Act)
 –   Appropriations Language
 –   Appropriations Law
 –   Federal Regulations (i.e. 44 CFR)
 –   Program Guidance
 –   OMB Circulars (Administrative Requirements, Cost
     Principles, and Audit)
      • State and Local Governments: A-102, A-87, A-133
      • Educational Institutions: A-110, A-21, A-133
      • Non-Profits: A-110, A-122, A-133
      • For Profit: A-110, FAR 31.2, A-133


                                                             20
Standardization

 • We ensure that FEMA applies Federal
   requirements listed above evenly across all
   grant programs.

 • We ensure standardization of processes and
   procedures wherever possible.

 • We standardize the implementation,
   application, review, award/obligation,
   management, and closeout of grants.


                                                 21
Internal Controls

  • We are the officials with the delegation of authority to
    obligate FEMA in legally binding non-disaster grant
    agreements.

  • We ensure the proper separation of duties between
    the program office that determines eligibility and the
    fiduciary agent that determines reasonableness,
    allowability and allocability of grant dollars.

  • We provide the review, oversight and documentation
    required by all FEMA offices to legally bind the
    Federal government in a grant agreement.



                                                               22
Outreach to Minority Institutions




                                    23
GPD Outreach to Minority Institutions
  Increase capacity of Minority Colleges and Universities (MCU) to
   compete effectively for grants.


 Federal Agencies Are Required to Support:


  Executive Order 13256 – President’s Board of Advisors on
   Historically Black Colleges and Universities (HBCU)

  Executive Order 13230 – President’s Advisory Commission on
   Educational Excellence for Hispanic Americans (HSI)

  Executive Order 13270 – Tribal Colleges and Universities (TCU)



                                                                      24
GPD Outreach to Minority Institutions
  GPD Goal

   Implement a strategic plan for the next three fiscal years to
    support Historically Black Colleges and Universities (HBCU),
    Hispanic Serving Institutions (HSI), and Tribal Colleges and
    Universities (TCU) as outlined below.

  Three-Phased Approach

  1) Establish partnerships

  2) Utilize campus facilities

  3) Visit campuses to attend job fairs and conduct workshops for
     faculty about FEMA grant funding opportunities



                                                                    25
GPD Outreach to Minority Institutions
  1)    Establish Partnerships Between:
        FEMA Headquarters and Regional Offices
        HBCU, HSI and TCU
        Non-Federal Organizations

  2)   Utilize Space at HBCU, HSI, and TCU for Meetings
       and Workshops attended by GPD staff and grant
       recipients.

  3)    Visit Campuses
        Attend Job Fairs
        Conduct Grant Workshops for Faculty
        Disseminate FEMA Materials

                                                          26
Locations of FEMA Regional Offices




              = Regional Office




                                     27
GPD Outreach to Minority Institutions

  Select at least one minority institution per HBCU,
   HSI, and TCU as a site for an event to support three
   minority institutions per fiscal year.

 Next Steps

 1) Identify event or activity planned for each institution.
 2) Set date for event or activity.
 3) Determine cost of event or activity.




                                                               28
           Distribution of HBCUs, TCUs and HSIs
      AK


                                 WA
                                                    MT          ND
                                                                                                                      VT      ME        I
                                      X                                    MN                                  II                   NH
                            OR
                                          ID
                                                         VIII    SD                  WI                              NY             MA
                                                     WY                                         MI                                  RI
                                                                                           V                    PA
                                                                                                                              CT
                                                                                                                                            Puerto Rico
                            IX                                   NE         IA
                                 NV                                                                  OH                            NJ
                                                                                                                                            Virgin Islands
                                                                  VII
                                                                                      IL   IN                               DE
                                               UT                                                         WV
                                                         CO
                                                                                                           III
                                                                                                                 VA           MD
                            CA                                    KS            MO               KY
                                                                                                                NC         DC (HSI and HBCU)
                                                                      OK                    TN
                                          AZ                                    AR                          SC
                                                     NM
                                                                                      MS    IV
                                                              VI TX                         AL        GA

             HI
                                                                                 LA                        FL

 American Samoa
 Guam
 U.S. Trust Territory of
the Pacific Islands
                                      Key
                                  HBCU = Historically Black Colleges and Universities
                                  HSI = Hispanic Serving Institutions
                                  TCU = Tribal Colleges and Universities


                                                                                                                                                             29
FEMA Grant Program Eligibility
 Universities are Eligible to Be Grantees of:

    Competitive Training Grants Program
    Fire Prevention & Safety

 Universities are Eligible as Sub-Grantees for:

    Homeland Security Grant Program
    Pre-Disaster Mitigation Program
    Public Assistance Grant Program




                                                  30
Workshop Overview




                    31
Workshop Objectives

• Build Team Approach

• Understand the Business Practices

• Develop Networks Among Recipients and
  Subrecipients

• Problem Solve on Specific Issues



                                          32
FEMA Grants Management
     From the Top




                         33
Grants Management Business Process


• Applies to All Grant Programs

• Manages Resources

• Creates Common Framework and
  Communication




                                     34
Business Process = The Grants Cycle

 Funding              Program             Subrecipient         Subrecipient
Acquisition         Establishment         Solicitation          Selection




             Project                                     Application
                                  Monitoring
           Modification                                  and Award




                                                                 Close-
Payments              Reporting                Audits
                                                                  Out




                                                                              35
Business Process = The Grants Cycle

 • Fundamentals for Any Grant Program

 • Processes are Not Mutually Exclusive

 • Cycle Sequence is Important

 • Starts with Pre-Award and Ends with Post-
   Award


                                               36
Pre-Award Business Practices


 Funding        Program       Subrecipient   Subrecipient   Application
Acquisition   Establishment   Solicitation    Selection     and Award




                                                                          37
Post-Award Business Practices


               Project                             Audits and
Monitoring   Modification   Payments   Reporting   Close-out




                                                                38
Business Process = The Grants Cycle



     Funding
     Acquisition




                                      39
Award and Terms & Conditions


• Award Notification to Grantee

• Terms & Conditions

• Sign Award and Special Conditions




                                      40
        Setting Program Priorities
          for the State/Territory
• Determining Priorities and Capabilities

• Support Homeland Security Strategic Goals

• Identifying Initiatives, Investments and Projects

• Consensus from State/Territory Advisory Board



                                                      41
        Setting Program Priorities


• Establish Subrecipient Grant Period

• Determine Competitive/Non-Competitive
  Application Process




                                          42
Business Process = The Grants Cycle




    Program
    Establishment




                                      43
Establishing Policies and Procedures

  • All Grant Stages

    – Application

    – Award

    – Administration

    – Review


                                       44
Establishing Your Program

• Roles and Responsibilities
  – Policy, Program and Grants

• Setting Goals and Priorities

• First 100 Days




                                 45
Establishing Your Program

• Physical Location

• Information Technology Requirements/Needs

• Communication…External

  – Public
  – Media Relations
  – Attorneys…State, County, Other
  – Subrecipients…Your Customers

                                              46
Establishing Your Program

• Communication…Internal

  – Written Policies/Procedures

  – Regular Staff Meetings

  – Dialogue with Senior Management




                                      47
Establishing Your Program

• Information Management

  – Accessible…Shared with All Disciplines
  – Retrievable…eGMS
  – Analyze Data to Improve Decision-making
  – Data Calls
  – Supportable




                                              48
Establishing Your Program

• Strong Financial Management System

• Staffing Needs and Structure…Key Positions

• Integrating Policy, Program and Financial

• Assistance from Other Agencies…
  Memorandum of Understanding (MOU)


                                               49
Establishing Your Program

• Hiring Personnel

  – Management and Administrative (M&A)
    Costs vs. Planning Costs
  – Position Descriptions
  – Posting Jobs and Interviewing
  – Background Checks - Time is $
  – Consultant Contracts



                                          50
Establishing Your Program

• Training Personnel

  – Cross-training
  – Retention and Career Development
  – M&A Use for Online Courses
  – M&A Budget…Travel for Staff Training
  – Document and Evaluate Annually




                                           51
Business Process = The Grants Cycle



     Subrecipient
     Solicitation




                                      52
Prepare Applications and Guidelines


• Integrate Priorities

• Require Budget and Program Narratives

• Incorporate Required Elements




                                          53
 Prepare Applications and Guidelines

• Include Grant Terms and Conditions

• Required Signatures

• Include Example of Subgrant Application




                                            54
Announce Funding and Priorities

• Publish Funding Availability and Deadlines

• Consider Conditional Grant Awards

• Conduct Grant Application Workshops




                                               55
Business Process = The Grants Cycle



     Subrecipient
      Selection




                                  56
Develop Criteria, Review and Select

• Policy, Program and Financial Grant Staffing

• Compare Project with Goals

• Supports Approved Initiatives and Investments

• Cost Analysis of Budget, including Narrative




                                                  57
Develop Criteria, Review and Select

• Necessity, Reasonableness, Appropriateness

• Review by Program Office (PO)

• Review Prior Subrecipient Performance




                                               58
Business Process = The Grants Cycle



   Application
   and Award




                                  59
Subawards and Release of Funds
• Subrecipient Special Conditions

• State Policies and Procedures

• Reporting Forms and Instructions

• Program Evaluation

• Audit and Close-out Forms and Instructions

                                               60
 Financial Management

• Organizing for Receipt of Federal Funds

• Program v. Financial-Not Mutually Exclusive

• Understanding Federal Requirements

• Establishing Policies and Procedures




                                                61
Financial Management Systems

• Minimum Requirements for Financial System

  – Provide Financial/Performance Data
     • Required by A-102 and 2 CFR Part 215

  – Associate Grant Expenditures to Specific Funding
    Source

  – Provide Clear Audit Trail

  – Manage Cash Effectively


                                                       62
Financial Management Systems

• “Adequate” Accounting Systems Require

  – Internal Controls
  – Ability to Test Internal Control
  – Chart of Accounts
  – Compliance with CMIA
  – Procedures Minimizing Federal Cash-on-Hand




                                                 63
Financial Management Systems

• “Adequate” Accounting Systems Require

  – Track Expenditures (Budget Control)

  – Track both Financial and Program Budgets

  – Ensure Allowability of Costs Charged to Grants



                                                     64
Financial Management Systems

• “Adequate” Accounting Systems Require

  – Documentation for All Grant-related
    Expenditures

     • Broken Down by Award

  – Fulfill Government-required Financial Reporting




                                                      65
Financial Management Systems

• Must Record and Report Grant Funds

  – Receipt

  – Obligation

  – Expenditure




                                       66
 OMB Circulars: Which Do I Follow?

• State, (Territories), Local Governments and Indian Tribes

   – A-87 for Cost Principles

   – A-102 for Administrative Requirements

   – A-133 for Audit Requirements




                                                              67
OMB Circulars: Which Do I Follow?

• Educational Institutions, Hospitals and Non-Profits

   – A-21 for Cost Principles (Educ. & Hospitals Only)

   – A-122 for Cost Principles (Non-Profits Only)

   – A-110 for Administrative Requirements

   – A-133 for Audit Requirements




                                                         68
 Policies and Procedures

• What?

  – Integrate Federal and State Policies

  – Develop Internal and External Forms and
    Procedures

  – Publish Formally



                                              69
Policies and Procedures

• Why?

  – Provides Documentation and Authorization
  – Tracks Modifications
  – Provides Accountability and Audit Compliance

• Who?

  – Obtain Support Prior to Implementation


                                                   70
 Procurement

• Review Financial Guides and OMB Circulars

• Identify Conditions Requiring Prior Approval

• Develop Forms for Prior Approval




                                                 71
Procurement

• Understand Differences Between Types

  – Competitive

  – Federal (GSA) or State Contract

  – Sole Source-Use is Discouraged
     • Emergency or Uniqueness



                                         72
Procurement
– Sole Source requirements in 44 Code of Federal
  Regulations (CFR) Part 13:

      – Item only available from one source
      – Emergency
      – Awarding agency authorizes
      – After solicitation of a number of sources,
        competition deemed inadequate

– Project Director and Local Procurement Official
  Signatures




                                                     73
  Fiscal Matters
“Show Me the Money”




                      74
Fiscal Matters…Proceed with Caution

• Allowable vs. Unallowable
  Costs

• Prior Approval Costs

• Renovations and
  Construction

• Travel Authorizations


                                      75
Fiscal Matters…Proceed with Caution

 • Time and Effort

 • Overtime and Backfill

 • Direct Costs

 • Indirect Costs



                                      76
Fiscal Matters…Proceed with Caution

• Supplantation
• Consultants
  – Fair Market Value-cautious
    on sole sourcing contractors
• Interest Earned/Program
  Income
• Match




                                      77
Fiscal Matters…Proceed with Caution

• Cash Advance
  – Interest Earned (CMIA)
• Outstanding Purchase
  Orders
• Excessive Spending
  Near End of Grant Period
• Records Retention




                                      78
Business Process = The Grants Cycle



     Monitoring




                                      79
              Monitoring Visit

• Conducted by Program Analyst


• Two Types


  – Desk…Administrative Monitoring
  – On-site…Strategic Monitoring



                                     80
   Program Monitoring Visit
Desk…Administrative Monitoring

• Office Based


• Review Recipient’s Signed Grant Award


• Review Signed Application (SF-424



                                          81
 DHS Program Monitoring Visit
Desk…Administrative Monitoring

• National Environmental Policy Act (NEPA)
  Letter


• Copies of Modifications / Amendments


• Follow-up Letter with Findings


                                             82
  DHS Program Monitoring Visit
  On-site…Strategic Monitoring
• Pre-visit

  – Review DHS Guidance (National Priorities,
    Planning Scenarios, TCL, etc.)
  – Review Current Fiscal Year Investments
  – Review Financial Monitoring Report(s) and
    Performance Report(s) for Follow-up


                                                83
  DHS Program Monitoring Visit
  On-site…Strategic Monitoring

• Final Steps

  – Post-visit Letter (15 days)


  – Monitoring Report (30 days)




                                  84
GPD Financial Monitoring Visit

Mission: Ensure Stewardship over
     Federal Funds Awarded




                                   85
GPD Financial Monitoring Visit

• GPD Does Not Conduct Audits

• GPD Does Conduct
  – On-site Financial Reviews
  – Desk-based Financial Reviews
  – Resolution of Audit Reports
  – Technical Assistance to Grantees



                                       86
GPD Financial Monitoring Visit

• Pre-Visit Letter to Recipient
  – All Financial and Administrative Grant Files

  – List of Awardees and Files for Each
    Subaward Related to Each Grant

  – Policies and Procedures Manuals




                                                   87
GPD Financial Monitoring Visit

• Pre-Visit Letter to Recipient
  – Detailed General Ledger (G/L) Reports
     • All Expenditures Charged to Each Grant
       Award

  – Financial Status Reports (SF-269a)

  – G/L Reconciliations for Each Quarter




                                                88
GPD Financial Monitoring Visit

• Pre-Visit Letter to Recipient
  – Supporting Documentation for All Expenditures
     • Invoices
     • Receipts
     • Purchase orders
     • Contracts




                                                    89
GPD Financial Monitoring Visit

• Pre-Visit Letter to Recipient
  – Supporting Documentation for All Expenditures
     • Travel Authorization Forms/Travel Vouchers
     • Timecards
     • Payroll Registers




                                                    90
GPD Financial Monitoring Visit

• Create Monitoring Profile
  – Program Office Monitoring Report
  – Audit Findings
  – Grant File Review
  – Pass-through Requirements
  – SF269 Analysis
  – Match Requirements



                                       91
GPD Financial Monitoring Visit

• ANALYZE, REVIEW and EVALUATE
  – Procurement Practices
  – Subrecipient Files (Programmatic and
    Financial)
  – Subrecipient Monitoring
  – Accounting System
  – Management and Administration (M&A)
  – Inventory



                                           92
GPD Financial Monitoring Visit

• ANALYZE, REVIEW and EVALUATE
  – Policies and Procedures
  – Flow of Funds
  – Pass-through Requirements
  – File Documentation
  – SF269 Analysis
  – Payroll
  – Travel



                                 93
 GPD Financial Monitoring Visit
   Top Monitoring Findings
• Inventory Management Deficiencies

• Inadequate Subrecipient Monitoring

• Excess Cash on Hand

• Grantee Has No Written Procedures



                                       94
    GPD Financial Monitoring Visit
      Top Monitoring Findings
• Project Period Expired
  • No Grant Adjustment Approving Extension

• Failure to Manage Audit Results

• Inadequate Accounting Procedures




                                              95
    GPD Financial Monitoring Visit
      Top Monitoring Findings
 Financial Status Reports Fail To Agree With
  Accounting Records

• Questioned Expenditures

• Untimely Submission of SF-269a Financial
  Status Reports




                                                96
    Case Study: Monitoring
Assistance to Firefighters Grant (AFG)
              Program




                                         97
Assistance to Firefighters Grant (AFG) Program

 • Financial Assistance directly to Fire Departments and
   non-affiliated EMS Organizations

 • $560 million for FY 2008

 • Fire Prevention & Safety

 • Staffing for Adequate Fire & Emergency Response
   (SAFER)




                                                           98
         AFG Site Visit Preparation

• Criteria for Selecting Grantees
  – State
  – Dollar Threshold
  – Diverse Sample


• Contact and Correspondence
  – Confirmation Letter and Reviewer Checklist



                                                 99
AFG Monitoring PPPE

• Procurement

• Personnel

• Property

• Expenditures


                      100
AFG Monitoring: Procurement

• Local or State Written Procurement Policy

• Specs, Bids, & Quotes

• Single Source Justification

• Conflict of Interest




                                              101
AFG Monitoring: Personnel

• Time & Attendance (Fire Prevention & SAFER)

• Overtime Records (Training)

• Rosters




                                                102
AFG Monitoring: Property


• Inventory & Maintenance Records

• Fixed Asset Threshold

• Physical Inventory of Equipment




                                    103
AFG Monitoring: Expenditures

• Evidence of Expenditures to Include Purchase
  Orders, Receipts, and Canceled Checks

• Tracking / Flow of Funds

• A-133 Audit




                                                 104
Subrecipient Program and
  Financial Monitoring




                           105
Subrecipient Monitoring: Purposes

• Periodic Monitoring Required

• Information Sharing and Gathering

• Reinforce Priorities and Policies




                                      106
Subrecipient Monitoring: Benefits

  • Technical Assistance

  • Subrecipients Identify/Showcase Successes

  • Ensure Projects are on Track

  • Improve Communications/Process

  • Correct Shortfalls and Offer Solutions


                                                107
    Subrecipient Monitoring
Different Approaches and Types

• Desk

  – Provides Documentation
  – Used When Staff Size is Limited
  – Short-Term Approach
  – Captures Limited Information




                                      108
     Subrecipient Monitoring
Different Approaches and Types

• Site Visits

   – Staff/Team Approach
   – Direct Contact with Stakeholders
      • Projects and Players
   – Visual Project Status…Big Picture
   – Requires Follow-up


                                         109
      Subrecipient Monitoring
       Tools and Resources

• Federal Guidelines
   – OMB Circulars
   – Program Guidance (by Federal Fiscal Year)

• State Requirements

• Monitoring Checklist…for Consistency



                                                 110
Getting Started…Take the Temperature




                                       111
       Subrecipient Monitoring:
           What to Expect
• Determine General “Health”
  – Project Goals and Project Management

• Staff Make Advance Notes
  – Areas Needing Special Attention

• All Staff Talk (Policy, Program and Financial)
  – Most Recent Status



                                                   112
         Subrecipient Monitoring
             What to Expect

• Pre-Monitoring Letter/Email

  – Confirm Location, Date and Time
  – Name of Staff Conducting Monitoring
  – Subrecipient Representatives Required
     • Project Director and Financial Officer
     • Authorized Official…Procurement Official(s)


                                                     113
        Subrecipient Monitoring
            What to Expect
• Pre-Monitoring Letter/Email
  – Monitoring Objectives
  – Materials/Equipment Necessary for Monitoring
     • Inventory Inspection…Location
     • Grant File(s)
     • Programmatic and Financial Records
     • Grant-funded Personnel



                                                   114
        Subrecipient Monitoring
            What to Expect

• Compare Grant Files…Yours and Theirs
  – Signed Grant Award
  – Final Application (Program/Financial Pages)
  – Met Special Conditions
  – Personnel Status…Position Descriptions?,
    Interviewing?, Hiring?
  – Status of Procurement, Revisions, etc.


                                                  115
        Subrecipient Monitoring
            What to Expect

• Review Grant File(s) Folder
  – Previous Monitoring Reports/Correspondence
  – Compliance with Deadlines
  – Progress and Financial Reports
  – Fiscal Information
     • Invoices, Payments, Backup, POs




                                                 116
     Subrecipient Monitoring
   Suggested Grant File Format
Label each tab




                                       1. Correspond.
 1. Correspondence
 2. Blank Forms, POC Info.
 3. Financial-Payments-Special Cond.
 4. Application, Signed Award, GANs
 5. Review & Audit Resolution
 6. Progress & Monitoring Reports




                                                        117
        Subrecipient Monitoring
            What to Expect

• Post Monitoring Letter (Desk or On-site)
  – Agreed-upon Modifications
  – Remaining Compliance Issues
  – Recommendations for Improvements




                                             118
     Subrecipient Monitoring
   What to Expect from the SAA?

• Post Monitoring Letter (Desk or On-site)
  – Recognition of Progress and Successes
  – Deadline for Response, if Applicable
  – Copied to Authorized Official




                                             119
Business Process = The Grants Cycle



     Project
     Modification




                                      120
Project Modification

• Change in Budget or Project Scope/Focus
• Grant Revisions and Grant Extensions
  – Examples:
     • Programmatic: Change in Strategy
       Objectives
     • Financial: Re-budgeting Remaining Funds




                                                 121
Project Modification
• Grant Revisions and Grant Extensions
  – Requires Pre-Approval from awarding Agency
  – Must Meet Original Program Intent
  – Allowable Costs from FY Program Guidance
  – Strong Justification for Review/Approval




                                                 122
    Project Modification
•   Document Approval
•   Compliant with OMB Circulars
•   Federal Guidelines
•   Allowable, Allocable, Reasonable




                                       123
    Project Modification
•   Comply with Grant Terms and Conditions
•   Program Restrictions
•   Unallowable Costs
•   Be Prepared to Extend Grant Periods




                                             124
Business Process = The Grants Cycle



     Payments




                                  125
Reimbursement

• Funds Disbursed as Costs Incurred

• Based upon Immediate Disbursement and
  Reimbursement
  – Limit Cash on Hand




                                          126
Reimbursement

• Subrecipient Requests for Reimbursement

• Not Exceed Total Grant Award or
  Unallowable Cost




                                            127
Advance

• Cash Management Improvement
  Act
 – Interest-Bearing Account
   • $100 Annually for State/Local; $250 for
     Non-profits
 – Remit Earned Interest Quarterly




                                               128
Things to Consider

• Provide Examples
  – Invoices
  – Purchase Orders
  – Requests for Reimbursement
  – Unallowable Costs, etc.




                                 129
Things to Consider

• Withhold Payments: Advance or
  Reimbursement

  – Subrecipient’s Inability to Submit Reliable
    and/or Timely Reports

  – Improper Administration of Subawards




                                                  130
Secrets for Success




                      131
Secrets for Success

• Your Role in Grant Administration

• Administrative Tools


• Resources




                                      132
Secrets for Success

• Partnership - Partnership – Partnership

• Clear and Concise Communication

• Develop Policies and Procedures

• Participate in Training Opportunities
  (Workshops)



                                            133
 Secrets for Success

• Keep Your Eye on Strategy
  – Goals, Objectives, and Priorities

• Focus on What Matters Most

• Be a Change Agent




                                        134
 Secrets for Success

• Set Realistic Goals

• Cross Train Personnel

• Use Technology – Preferably Someone Else's

• Scan Your Environment



                                               135
Workshop Conclusions

• You Understand the Business Practices

• You Know the Critical Events

• You Learned to Problem Solve




                                          136
 Workshop Conclusions

• You Can Build a Team Approach

• You Identified Promising Practices

• You Developed Networking Methods




                                       137
Contact Information

• Donna Simmons, FEMA/GPD Acting Training Branch
  Chief
   – (202) 786-9579
   – Donna.Simmons@dhs.gov

• Vanessa Pert, FEMA/GPD Grants Management
  Specialist
   – (202) 786-9564
   – Vanessa.Pert@dhs.gov

• FEMA Centralized Scheduling and Information Desk
   – 1-800-368-6498



                                                     138
Questions




            139

				
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Description: Procurement Authority to Utilize Gsa Federal Grant Results document sample