Y.2. PAS: Data Needed in Recipient Request Letter

The amounts and types of data needed to support the recipient’s request will vary based on the types of delegated activities selected. Recommended data elements are noted in each table and the list following them. Recipients may submit other data they determine may be necessary to support their request. FEMA will supplement its review of the request with grants management data for the recipient.

Step 1: Review and approve HMGP and HMGP Post Fire subapplications and pre-award amendment requests using FEMA’s expedited application approval process for obligating assistance. Recipients can select one or all the following:

• Project subapplicants (all projects or selected projects).
• Planning subapplications.
• Management costs.

Note: If a recipient chooses a subset of project types, FEMA will only evaluate related subapplications. For example, FEMA would only review structural elevation subapplications when the recipient requests delegated review limited to structural elevation subapplications.

Step 2: Approve finding of pre-award planning and project costs incurred by subrecipients.

The following listhighlights the data needed to demonstrate past performance of application review when requesting delegation of application review activities (Steps 1 and 2 above) along with the measurable target(s) associated with each item:

• Administrative Plan: List of declared disasters, HMGP and HMGP Post Fire awards and plan approval dates. The Administrative Plan is approved by FEMA within 90 calendar days of the declaration date.
• Electronic data systems: List of subapplications and document applications that were submitted electronically. All applications are entered into FEMA’s electronic application systems.
• Application eligibility and completeness: List of subapplications and amendments for HMGP, HMGP Post Fire, Building Resilient Infrastructure and Communities (BRIC) and Flood Mitigation Assistance (FMA); date the application was submitted by the recipient; date approved by FEMA; and notation of whether the eligibility checklist or equivalent documentation was provided to FEMA.
  • A complete eligibility checklist for planning or project subapplications or equivalent documentation is prepared for all subapplications. Recipients may develop and use their own checklists if approved by FEMA and the recipient.
  • All subapplications are determined to be complete by FEMA within 90 calendar days of submittal or selection for further review. Required EHP reviews and consultations will not be included in the 90-day time frame calculation.
• Grant application extensions: List of HMGP, HMGP Post Fire, BRIC, FMA and Pre-Disaster Mitigation (PDM) awards; application deadline date, if applicable; and date the request of extension was requested, if applicable. Any request to extend the HMGP or HMGP Post Fire application period was submitted at least 30 calendar days prior to the end of the expiration of the application period.
• Training: Staffing organizational chart or roster and a summary listing of training completed within the past five years as provided by recipient’s hazard mitigation officer, designated representative or training officer.
  • Staff managing application development under PAS have completed FEMA Emergency Management Institute E0212: Unified Hazard Mitigation Assistance: Developing Quality Application Elements Course and other HMA–related courses.
  • Staff managing application development under PAS have completed FEMA Emergency Management Institute IS-253.A Overview of FEMA's Environmental and Historic Preservation Review course.

Step 1: Review and approve BCA submitted by subrecipients without FEMA review.

Step 2: Prepare own BCA without FEMA review.

The following list highlights the data needed to demonstrate past performance of BCAs when requesting delegation of BCA activities (Steps 1 and 2 above) along with the measurable target(s) associated with each item:

• BCA: List of subapplications (HMGP, HMGP Post Fire, BRIC, PDM and FMA), date BCA submitted, date reviewed and accepted as correct by FEMA. All applications are determined to be completed by FEMA within 90 calendar days of submittal or selection for further review, including all data requested by FEMA to support cost-effectiveness determinations. Required EHP review and consultations will not be included in the 90-day review time frame calculation.
• Training: Staffing organizational chart or listing and a summary listing of training completed within the past five years as provided by the hazard mitigation officer (or designated representative) or training officer.
  • Recipient staff who will prepare or review BCAs under PAS Agreement have completed a FEMA BCA course (IS-276.A, Benefit-Cost Analysis Fundamentals or its equivalent). Staff should complete modules for project types or hazards anticipated. Completion of all modules is not required.
  • Recipient staff who have prepared BCA documentation have completed course E0212 or its equivalent.

Step 1: Approve post-award subrecipient scope of work modifications (that have no change to the project activity and no resulting need for additional federal assistance) without FEMA review. Submit an updated Minimum Eligibility Criteria Checklist or equivalent documentation and project summary via electronic data systems provided by FEMA. Recipients may develop and use their own checklists if approved by FEMA. Update Quarterly Progress Reports accordingly.

Step 2: Approve time limit extensions for subawards with no impact to the HMGP and HMGP Post Fire award period of performance. Document these changes in Quarterly Progress Report and electronic data systems.

Step 3: Administer HMGP and HMGP Post Fire for specific project types submitted by the subrecipient, including property acquisition and structure demolition, wildfire mitigation, safe rooms, structural elevation or other eligible hazard mitigation project type.

The following list highlights the data needed to demonstrate past performance of grants management when requesting delegation of grants management activities (steps 1, 2 and 3 above) along with the measurable target(s) associated with each item:

• Grant extensions: List of HMGP, HMGP Post Fire, BRIC, PDM and FMA awards and period of performance deadlines. Date of extension requests, if applicable. All work as part of HMA subawards must be completed by the end of the period of performance as described in the HMA Guide. All extension requests must be complete, on time and with adequate justification as described in guidance.
• Recipient progress reports: Dates progress reports were submitted to FEMA for all HMA awards. Documentation of extension approvals, if applicable. All progress reports must be complete and submitted on time. Information in the reports must accurately describe grant activities, including data related to the completion of individual property acquisitions. Incomplete progress reports that do not provide information on all open awards and subawards or include all information required by the HMA Guide are not considered on time.
• Subaward closeout activities: Listing of all HMGP, HMGP Post Fire, BRIC, PDM and FMA subawards that were closed out by the recipient. Hazard mitigation officer certifies subawards were closed out within 90 calendar days from the end of the period of performance. Because these data are found in recipient files, FEMA will review findings from FEMA monitoring and closeout reports.
  • All subaward closeout activities, including financial reconciliation, are completed within 90 calendar days from the end of the period of performance.
  • Actual expenditures have been documented and are consistent with Standard Form (SF) 424A, Budget Information for Non-Construction Programs, or SF-424C, Budget Information for Construction Programs.^[506]
• Award closeout: Dates documents were submitted to FEMA. Period of performance deadlines for respective HMGP, HMGP Post Fire, BRIC, PDM and FMA awards.^[507]
  • Complete SF-425: Federal Financial Report and progress reports were submitted within 120 calendar days from the end of the period of performance.
  • Statement submitted that approved scope of work and all EHP requirements have been satisfied.
  • SF-270: Request for Advance or Reimbursement or request to de-obligate assistance is completed, if applicable because of cost underruns.
  • No late drawdowns were requested or performed after the liquidation period ended.

Step 1: Without prior approval from FEMA, approve post-award budget changes using assistance available because of cost underruns from other approved subawards. This assistance can be moved to approved subawards with cost overruns. Assistance can only be used within the same HMGP or HMGP Post Fire award.

Step 2: Prior to approval, determine whether the project meets eligibility requirements, including cost-effectiveness and cost share. Submit an updated Minimum Eligibility Criteria Checklist or equivalent documentation and project summary via electronic data systems provided by FEMA. Update Quarterly Progress Reports accordingly. Recipients may develop and use their own checklists if approved by FEMA.

Step 3: Determine the eligible amount of reimbursement for each subaward claim and process payment without approval from FEMA.

The following list highlights the data needed to demonstrate past performance of fiscal management when requesting delegation of fiscal management activities (Steps 1, 2 and 3 above) along with the measurable target(s) associated with each item:

• SF-425 prepared by recipient: Dates SF-425 was submitted to FEMA. Documentation of extension approvals, if applicable. All federal financial reports are submitted on time. Information in reports projects an accurate picture of grant activities.
• Recipient financial management systems: Narrative describing financial management. Recipient consistently complies with the financial management standard requirements described in 2 CFR §§ 200.300 - 309.
• Recipient financial statement audit: Date of last audit; summary of findings for HMA programs, if applicable; narrative on how recipient addressed findings, if applicable. No major findings on last single audit obtained by the recipient related to HMA programs. For recipients without HMA awards, FEMA will review other federal grants prepared by the responsible agency (i.e., state, tribal or territorial emergency management agency).
• Closeout activities: Date closeout documentation was submitted to FEMA. Period of performance deadline for respective HMA awards.
  • All award closeout activities, including financial reconciliation are completed within 120 calendar days from the end of the period of performance, including:
    • Final SF-425 and Quarterly Progress Reports were submitted within 120 calendar days from the end date of the period of performance.
    • Statement that scope of work(s) has been completed as approved and all EHP requirements have been satisfied.
    • SF-270 (or request to de-obligate assistance is completed, if applicable because of cost underruns) was submitted on time.
    • Other documentation as required in the HMA Guide.
    • No drawdowns requested or performed after the liquidation period has ended.

Step 1: Approve local mitigation plans using the process described below; FEMA will send final approval letters in accordance with the Local Mitigation Planning Policy Guide. FEMA will continue to send final approval letters to tribal communities when included in a multi-jurisdictional plan.

A national panel composed of FEMA headquarters and regional mitigation planning staff will review the state’s initial request for delegation of local mitigation plan approval. The following list highlights the data needed to demonstrate past performance of mitigation planning when requesting delegation of mitigation planning activities (Step 1 above) along with the measurable target(s) associated with each item:

• Plans are approvable pending adoption: List of local mitigation plans submitted to FEMA, noting which plans were approvable pending adoption (no required revisions). All local mitigation plan reviews are approvable pending adoption (no required revisions) following their initial review by FEMA. If fewer than six plans have been submitted within the last four quarters, the six most recent plan reviews will be used to make this determination.
• Mitigation planning training: Staffing organizational chart or listing and a summary listing of staff who have completed training within the past five years as provided by the hazard mitigation officer (or designated representative) or training officer. A summary of staff experience or education can be provided to document equivalent experience. Staff who will be performing or managing local mitigation plan review under the PAS Pilot have completed E-318/G-318, Local Hazard Mitigation Planning;IS-318, Mitigation Planning for Local and Tribal Communities; and IS-328, Plan Review for Local Mitigation Plans or their equivalents as approved by the FEMA National Mitigation Planning Program.
• Guidance and regulations: Staffing organizational chart or listing and summary of staff experience as documented by the hazard mitigation officer (or designated representative) or manager of mitigation planning review. States document that staff dedicated to mitigation planning understand and have experience interpreting and implementing mitigation planning guidance and 44 CFR Part 201 mitigation planning regulations.
• Administration of mitigation planning activities: Mitigation planning regulations include standards for managing states, where mitigation planning regulations refer to Section 404(c) of the Stafford Act for provisions for PAS.^[508] Under this pilot, states will be required to address these standards. Provide narrative as needed.
  • Resources: The state has documented the funding used to develop local mitigation plans, including HMA.^[509]
  • Staff: The state has documented the capacity and capability of the mitigation planning staff to adequately provide consistent plan review, satisfactorily determine plans are approved pending adoption and provide technical assistance.
  • Technical assistance and training program: The state has documented the process used to (1) conduct plan review and provide technical assistance and training to local planners and (2) build local mitigation capability.^[510]
  • Administration: The state has documented how it will conduct local mitigation plan reviews within the 45-day review period and will, whenever possible, provide a copy of the plan and a monthly status report to FEMA that includes plan approval status, status of plan reviews, technical assistance activities and training scheduled.^[511]

The review of Commitment to Mitigation has two parts. The first part addresses the recipient’s ability to manage the HMGP, HMGP Post Fire and Mitigation Planning programs. The second part addresses the recipient’s ability to support mitigation practices and activities statewide.

In the request letter, a recipient should provide information to support that they:

• Staff HMGP and HMGP Post Fire such that there are in-house or contract staff responsible for all elements, including delegated activities throughout the HMGP and HMGP Post Fire award lifecycles.
• Manage HMGP and HMGP Post Fire resources so they can conduct the standard and delegated activities throughout the HMGP and HMGP Post Fire award cycles.
• Provide technical assistance to communities and eligible subapplicants such that they are then able to perform the function for which they requested assistance.
• Use an effective management plan to administer HMGP, HMGP Post Fire and Mitigation Planning such that post-disaster mitigation activities derive from mitigation planning, and that these activities are executed in a systematic, organized fashion that ensures compliance with HMGP and HMGP Post Fire requirements and regulations.

In the request letter, a recipient should provide information to support that they:

• Staff the Mitigation Planning program such that there are in-house or contract staff to adequately provide training, technical assistance, and plan review and approvals.
• Manage HMA program resources so they can provide assistance to develop and update local mitigation plans.
• Provide training and technical assistance to communities and eligible subapplicants such that they are then able to develop an approvable local mitigation plan.
• Use an effective management plan to administer Mitigation Planning programs to identify long-term, broadly supported strategies for risk reduction and identify implementation approaches for future HMGP/HMGP Post Fire awards.

In the request letter, a recipient should indicate whether they have a standard or enhanced mitigation plan and provide the date the plan was approved by FEMA.

Recipients with a standard mitigation plan must:

• Provide information that describes an existing comprehensive mitigation program that might include but is not limited to examples listed in the mitigation planning regulation 44 CFR § 201.5(b)(4). A “comprehensive mitigation program” means a broad range of recipient-supported initiatives and activities that:
  • Target risk reduction for each of the identified hazards in the recipient’s plan.
  • Are inclusive of various governmental agencies and sectors with mitigation capabilities and resources.
  • Are coordinated to increase the state, tribe or territory’s resilience from the adverse impacts of future hazard events.

Initiatives and activities that demonstrate commitment include but are not limited to a combination of current training, partnerships, leadership initiatives, assistance, technical assistance, codes and ordinances, or other activities that reduce risk.