FISCAL YEAR 2023 HOMELAND SECURITY GRANT PROGRAM FREQUENTLY ASKED QUESTIONS [https://www.fema.gov/grants/preparedness/homeland-security/fy-23-faqs] Release Date: fév 27, 2023 DOWNLOAD A PDF COPY OF THIS WEBPAGE. [https://www.fema.gov/print/pdf/node/652418] The fiscal year (FY) 2023 Homeland Security Grant Program (HSGP) [https://www.fema.gov/grants/preparedness/homeland-security] is one of three grant programs that support the Department of Homeland Security (DHS)/Federal Emergency Management Agency’s (FEMA’s) focus on enhancing the ability of state, local, tribal, and territorial governments, as well as nonprofit organizations, to prevent, prepare for, protect against, and respond to acts of terrorism.  ABOUT THE PROGRAM * WHAT IS THE PURPOSE OF THE FY 2023 HSGP PROGRAM? The Fiscal Year (FY) 2023 Homeland Security Grant Program (HSGP) is one of three grant programs that support the U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency’s (FEMA) focus on enhancing the ability of state, local, tribal, and territorial governments, as well as nonprofit organizations, to prevent, prepare for, protect against, and respond to acts of terrorism and other extremist attacks. These grant programs are part of a comprehensive set of measures authorized by Congress and implemented by DHS to help strengthen the nation’s communities against potential terrorist attacks and other hazards. * WHAT LEGISLATION AUTHORIZED FUNDING FOR THE FY 2023 HSGP? Sections 2002 to 2004 of the _Homeland Security Act of 2002_ (Pub. L. No. 107-296), codified as amended (6 U.S.C. §§ 603-605) and the _Consolidated Appropriations Act_, 2023 (Pub. L. No. 117-328). * HOW MUCH FUNDING IS AVAILABLE UNDER THE FY 2023 HSGP? The total amount of funds distributed under the FY 2023 HSGP will be $1.12 billion. * WHAT ARE THE CHANGES IN FUNDING LEVELS BETWEEN FY 2022 AND FY 2023?   The funding levels for all three programs (SHSP, UASI and OPSG) remain the same as FY 2021. HSGP PROGRAM FY 2023 ALLOCATION SHSP $415 million UASI $615 million OPSG $90 million TOTAL $1.12 BILLION * WHERE IS THE FY 2023 HSGP NOTICE OF FUNDING OPPORTUNITY (NOFO) LOCATED? HOW MUCH FUNDING IS AVAILABLE UNDER THE FY 2023 HSGP? The FY 2023 HSGP NOFO is located online at www.fema.gov/grants [http://www.fema.gov/grants]. * WHO IS ELIGIBLE TO APPLY FOR FY 2023 HSGP FUNDS? The State Administrative Agency (SAA) is the only entity eligible to submit HSGP applications to FEMA, including those applications submitted on behalf of UASI and OPSG applicants. All 56 states and territories, which includes any state of the United States, the District of Columbia, the Commonwealth of Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands, are eligible to apply for SHSP funds. Tribal governments may not apply directly for HSGP funding. However, funding may be available to tribes under SHSP and OPSG by applying through the SAA. Eligible high-risk urban areas for the FY 2023 UASI Program are determined through an analysis of the relative risk of terrorism faced by the 100 most populous metropolitan statistical areas (MSA) in the United States. Subawards will be made by the SAA to the high-risk urban areas that are identified in the FY 2023 HSGP NOFO. In FY 2023, OPSG eligible subrecipients are local units of government at the county level or equivalent level of government and federally recognized tribal governments in states bordering Canada or Mexico and states and territories with international water borders. All applicants must have active ongoing USBP operations coordinated through a CBP sector office to be eligible for OPSG funding. Under the FY 2023 OPSG Program, subrecipients that are eligible to apply for and receive a sub-award directly from the SAA are divided into three tiers: * Tier 1 entities are local units of government at the county level or equivalent and federally recognized tribal governments that are on a physical border in states bordering Canada or Mexico, and states and territories with international water borders. * Tier 2 eligible subrecipients are those not located on the physical border or international water border but are contiguous to a Tier 1 county. * Tier 3 eligible subrecipients are those not located on the physical border or international water border but are contiguous to a Tier 2 eligible subrecipient. The tier structure is only applicable to eligibility. OPSG funding allocations are based on the assessed border security risks as determined by the U.S. Border Patrol. * WHAT ARE THE KEY DATES ASSOCIATED WITH THE FY 2023 HSGP? * February 27, 2023: NOFO released. * May 18, 2023, 5 p.m. Eastern Time (ET): Applications due to FEMA. * WHAT IS THE FY 2023 HSGP PERIOD OF PERFORMANCE?     The period of performance is 36 months. * HOW WILL THE FY 2023 HSGP FUNDS BE ALLOCATED? The FY 2023 allocation process for SHSP, UASI, and OPSG will be as follows: SHSP ALLOCATIONS For FY 2023, FEMA will award SHSP funds based on risk as determined by FEMA’s relative risk methodology and statutory minimums pursuant to the Homeland Security Act of 2002 as amended. Each state’s allocation is published in the FY 2023 HSGP NOFO. UASI ALLOCATIONS For FY 2023, FEMA will award UASI funds based on risk as determined by FEMA’s relative risk methodology pursuant to the Homeland Security Act of 2002, as amended. Each eligible urban area’s allocation is published in the FY 2023 HSGP NOFO. OPSG ALLOCATIONS For FY 2023, FEMA will award OPSG funds based on risk and the anticipated effectiveness of the proposed use of grant funds. The FY 2023 OPSG risk assessment is designed to identify the risk to border security and to assist with the distribution of funds for the grant program. Entities eligible for funding are state, local, and tribal law enforcement agencies that are located along the border of the United States. Final award amounts will be based on FEMA’s evaluation of the effectiveness of proposed investments and projects. For additional information, see Section B of the FY 2023 HSGP NOFO. * WHAT OTHER RESOURCES ARE AVAILABLE TO ADDRESS PROGRAMMATIC, TECHNICAL, AND FINANCIAL QUESTIONS? * For additional program-specific information, please contact the FEMA Grants Information Desk at fema-grants-news@fema.dhs.gov OR at (800) 368-6498. Hours of operation are from 9 a.m. – 5 p.m. ET, Monday through Friday. * For support regarding financial grant management and budgetary technical assistance, applicants may contact the DHS/FEMA Award Administration Help Desk via e-mail at ASK-GMD@fema.dhs.gov. * HOW DO WE ENSURE THAT WE ARE RECEIVING THE LATEST INFORMATION, UPDATES AND GUIDANCE FROM FEMA ON THE STATUS OF THE PREPAREDNESS GRANTS? All communications will be sent to our state and urban area partners via the fema-grants-news@fema.dhs.gov e-mail address and posted on the www.fema.gov/grants [http://www.fema.gov/grants] website. If you are not receiving these e-mails, please send a request to your assigned Preparedness Officer or directly to the fema-grants-news@fema.dhs.gov e-mail address and you will be added to the distribution list. NATIONAL PRIORITY AREA (NPA) PROJECTS * WHAT ARE THE NPAS FOR THE FY 2023 SHSP AND UASI PROGRAMS, AND ARE THERE MINIMUM SPEND REQUIREMENTS? There are six National Priority Areas (NPA) for FY 2023, consistent with the six NPAs in FY 2022. Overall, the required minimum spend on the FY 2023 NPAs for the SHSP and UASI programs remains consistent with the FY 2022 requirement – 30% as a percentage of the total SHSP and UASI allocation. Each SHSP and UASI applicant must dedicate the minimum spend (identified below where applicable) as a percentage of the total SHSP and UASI allocation per NPA. For the “enhancing cybersecurity” NPA with no minimum spend requirement, DHS strongly encourages recipients to make investments in this area as it is of critical national concern. 15% IS MANDATED IN MINIMUM SPENDING ACROSS FIVE OF THE SIX NPAS, BUT THERE IS FLEXIBILITY ON THE REMAINING 15% REQUIRED TO MEET THE OVERALL 30% MINIMUM SPEND REQUIREMENT.  The six NPAs, along with the relevant minimum spend percent, are: * Enhancing the protection of soft targets/crowded places – 3% minimum spend; * Enhancing information and intelligence sharing and analysis – 3% minimum spend; * Combating domestic violent extremism – 3% minimum spend; * Enhancing cybersecurity – no minimum spend requirement; * Enhancing community preparedness and resilience – 3% minimum spend; and * Enhancing election security – NEW 3% minimum spend. For those NPAs that have an associated minimum spend, all projects related to meeting the minimum spend for those NPAs must be included in the same Investment Justification (IJ). See Question #14 for more information.  * WHAT ARE EXAMPLES OF PROJECTS FOR EACH OF THE NPAS? Soft Targets/Crowded Places: * Operational overtime * Physical security enhancements * Closed-circuit television security cameras * Security screening equipment for people and baggage * Lighting * Access controls * Fencing, gates, barriers, etc. Information and Intelligence Sharing: * Fusion center operations * Information sharing with all DHS components; fusion centers; other operational, investigative, and analytic entities; and other federal law enforcement and intelligence entities * Cooperation with DHS officials and other entities designated by DHS in intelligence, threat recognition, assessment, analysis, and mitigation * Identification, assessment, and reporting of threats of violence * Joint intelligence analysis training and planning with DHS officials and other entities designated by DHS Domestic Violent Extremism: * Open source analysis of misinformation campaigns, targeted violence and threats to life, including tips/leads, and online/social media-based threats * Sharing and leveraging intelligence and information, including open source analysis * Execution and management of threat assessment programs to identify, evaluate, and analyze indicators and behaviors indicative of domestic violent extremists * Training and awareness programs (e.g., through social media, suspicious activity reporting indicators and behaviors) to help prevent radicalization * Training an awareness programs (e.g., through social media, suspicious activity reporting indicators and behaviors) to educate the public on misinformation campaigns and resources to help them identify and report potential instances of domestic violent extremism Community Preparedness and Resilience: * Establish, train, and maintain Community Emergency Response Teams (CERT) and Teen CERT, with a focus on historically underserved communities, including procurement of appropriate tools, equipment and training aides: * Local delivery of CERT train-the-trainer and CERT Program Manager to build local program training and maintenance capacity * Provide continuity training, such as FEMA’s Organizations Preparing for Emergency Needs training, to faith-based organizations, local businesses, and community-based organizations such as homeless shelters, food pantries, nonprofit medical providers and senior care facilities to bolster their resilience to all hazards * Partner with local school districts to deliver the Student Tools for Emergency Planning curriculum or other educational programming to guide students on how to create emergency kits and family communications plans * Partner with key stakeholders to assist with completing the Emergency Financial First Aid Kit or a similar tool to bolster the disaster centric financial resilience of individuals and households * Execute _You are the Help Until the Help Arrives_ [https://community.fema.gov/until-help-arrives]_ _workshops in concert with community based organizations to bolster individual preparedness * Target youth preparedness using FEMA programming such as Prepare with Pedro resources and Ready2Help * Promote community planning, coordination, and integration of children’s needs during emergencies through workshops like FEMA’s Integrating the Needs of Children * Community Mapping: identify community resources and characteristics in order to identify gaps in resources, identify hazards and vulnerabilities, and inform action to promote resilience Cybersecurity: * Cybersecurity risk assessments * Migrating online services to the “.gov” internet domain * Projects that address vulnerabilities identified in cybersecurity risk assessments * Improving cybersecurity of critical infrastructure to meet minimum levels identified by the Cybersecurity and Infrastructure Security Agency * Cybersecurity training and planning Election Security: * Physical security planning support * Physical/site security measures – e.g., locks, shatter proof glass, alarms, etc. * General election security navigator support * Cyber navigator support * Cybersecurity risk assessments, training, and planning * Projects that address vulnerabilities identified in cybersecurity risk assessments * Iterative backups, encrypted backups, network segmentation, software to monitor/scan, and endpoint protection * Distributed Denial Of Service protection * Migrating online services to the “.gov” internet domain * ARE STATES, TERRITORIES AND ELIGIBLE URBAN AREAS REQUIRED TO SUBMIT INVESTMENT JUSTIFICATIONS (IJS) FOR EACH OF THE SIX NPAS FOR SHSP AND UASI WITH THEIR APPLICATIONS? No. States, territories, and eligible urban areas must submit one IJ with at least one project for each of the five required NPAs (Soft Targets/Crowded Places, Intelligence and Information Sharing, Domestic Violent Extremism, Community Preparedness and Resilience, Election Security) with a minimum spend, as part of their application. All projects related to meeting the minimum spend for those NPAs must be included in the same IJ. While encouraged, an IJ is not required for the “Enhancing Cybersecurity” NPA with no minimum spend requirement.  * CAN I SUBMIT PROJECT LEVEL DETAILS FOR THE NPA IJS WITH MY SHSP AND UASI APPLICATION? Yes. All projects submitted by the application deadline will undergo a federal review to ensure the effectiveness of the proposed projects in addressing the NPAs. The goal is to have the federal review for effectiveness completed in a timely manner to minimize both the amount of funding on hold and length of time for those holds related to the NPAs. If the federal effectiveness review determines that one or more projects are not effective in addressing the NPAs, then funding will be placed on hold for those projects, and FEMA will work with the recipient to revise those projects until they are deemed effective, and the funding holds removed.   * IF I DO NOT SUBMIT COMPLETE SHSP AND UASI PROJECT-LEVEL INFORMATION WITH MY APPLICATION ON JANUARY 30, 2024, WHEN IS THIS INFORMATION DUE? Project-level information for the FY 2023 SHSP and UASI Programs for all Investments must be submitted with the Biannual Strategy and Implementation Report (BSIR) report due by January 30, 2024. However, any state or urban area that elects to submit NPA project-level details at the time of the BSIR submittal and not with their FY 2023 HSGP application will have funding related to the NPAs placed on hold (up to 30% of the total SHSP and UASI award) until after the effectiveness reviews have concluded in early 2024. * IF ONE OR MORE OF MY FY 2023 SHSP OR UASI NPA PROJECTS IS DEEMED INEFFECTIVE, WILL I LOSE FUNDING? Recipients and subrecipients will not be permitted to expend funding under the NPA(s) until the effectiveness of the proposed projects has been reviewed and confirmed by FEMA. Funding may be placed on hold if not enough projects to meet the minimum spend required under the NPA(s) are deemed effective. * WILL FUNDING FOR THE PROJECTS NOT INCLUDED AS PART OF THE NPA IJS FOR SHSP AND UASI BE AVAILABLE AT THE TIME OF AWARD? Yes, funds for these projects will be available for use at the time of award. However, as in past years, project-level information for these funds must be provided with the first BSIR report, which is due on JANUARY 30, 2024. FEMA may place a hold on those funds at that time should any of the projects be deemed ineffective during their review or for other reasons as authorized by the _Homeland Security Act of 2002_ and 2 C.F.R. Part 200 as part of the standard award process. * SHOULD THE NPA IJS INCLUDE ALL RELATED PROJECTS? All projects related to meeting the minimum spend for those NPAs that require a minimum spend must be included in the same IJ. Activities that support more than one NPA may be included under only one NPA IJ but still count towards the 30% minimum spend without having to be broken out into separate projects or activities in more than one IJ. As a reminder, applicants are not required to submit project-level detail at time of application, and instead can submit this detail as part of the BSIR due JANUARY 30, 2024 However, any state or urban area that elects to submit project-level detail with the BSIR may have all funding related to the applicable NPA(s) placed on hold (up to 30% of the total SHSP and UASI award) until after the effectiveness reviews have concluded. APPLICATION DEVELOPMENT AND SUBMISSION * IS THERE A STAND-ALONE FUSION CENTER IJ REQUIRED IN FY 2023? No, there is no requirement to provide a stand-alone fusion center IJ this year for SHSP and UASI. * SHOULD THE ADDITIONAL EFFECTIVENESS INFORMATION THAT WILL BE DELINEATED IN SECTION E.2 OF THE NOFO BE INPUT BY APPLICANTS UNDER THE PROJECT DESCRIPTION FIELD IN THE GRANT REPORTING TOOL? * Yes. However, because the Grant Reporting Tool’s project description fields are limited to 4,000 characters, states and territories may submit narrative addenda that can be uploaded to ND Grants. There is a two-page limit per project and addenda should meet the following criteria: * Font: Arial or Times New Roman * Font Size: 11 point (11 pt.) or larger * Page Dimensions: Page dimensions must be 8.5" x 11" or smaller * Margins: All margins (top, bottom, left, and right) must be at least 1" * File Name: File names should be in the following format: State_Urban Area_IJ #_National Priority_Project Title * IS IT STILL A REQUIREMENT THAT ANY STATE THAT RETAINS A PORTION OF AN UASI ALLOCATION (UP TO 20%) FOR PROJECTS THAT DIRECTLY SUPPORT THE URBAN AREA MUST INCLUDE AN IJ FOR THE STATE-RETAINED FUNDS? Yes. The state must create an IJ for state-retained funds as part of the applicable UASI’s IJ submission, except if the state proposes to use funding under one of the six NPAs (Soft Targets/Crowded Places, Intelligence and Information Sharing, Domestic Violent Extremism, Community Preparedness and Resilience, Cybersecurity, and Election Security). Those projects shall be included in the applicable NPA IJ, ensuring the project name includes the word “STATE” to indicate the activity is a proposed state funded UASI project. * WHAT IS THE SET-ASIDE REQUIREMENT FOR LAW ENFORCEMENT TERRORISM PREVENTION ACTIVITIES (LETPAS) UNDER SHSP AND UASI? For FY 2022, the amount of funding that must support LETPA is 35%, which is an increase from 25% in the previous year. Investments that support LETPAs can also support an NPA (e.g., an investment can be counted as supporting both the Soft Targets/Crowded Places and LETPA minimum allocation requirements, if applicable). * IN THE PAST, FEMA REQUIRED STATES AND URBAN AREAS TO SUBMIT ONE CONSOLIDATED EMERGENCY COMMUNICATIONS IJ. THIS IJ INCLUDED ALL EMERGENCY COMMUNICATIONS INVESTMENTS AND DESCRIBED HOW SUCH ACTIVITIES ALIGNED WITH THEIR STATEWIDE COMMUNICATION INTEROPERABILITY PLAN. WILL FEMA STILL REQUIRE STATES AND URBAN AREAS TO SUBMIT ONE EMERGENCY COMMUNICATIONS IJ EVEN IF PROJECTS ALIGN WITH ONE OF THE SIX NPAS?  In FY 2023, states and urban areas are not required to submit one consolidated Emergency Communications IJ. States and urban areas may still submit an Emergency Communications IJ. However, Emergency Communications projects that fall under one of the six NPAs (Soft Targets/Crowded Places, Intelligence and Information Sharing, Domestic Violent Extremism, Community Preparedness and Resilience, Cybersecurity, and Election Security) should be included under the applicable NPA’s IJ. * HOW WILL FY 2023 HSGP APPLICATIONS BE SUBMITTED?  Applying for an award under the HSGP is a multi-step process and requires time to complete. Applicants are encouraged to register early as the registration process can take four weeks or more to complete. Therefore, registration should be done in sufficient time to ensure it does not impact the ability to meet required submission deadlines. Please refer to Section D _Application and Submission Information _in the FY 2023 HSGP NOFO for detailed information and instructions. * Eligible applicants must submit their initial application through the grants.gov portal at least seven days before the final application deadline at www.grants.gov [https://www.grants.gov]. Applicants needing grants.gov support should contact the customer support hotline at (800) 518-4726. * Eligible applicants will be notified by FEMA and asked to proceed with submitting their complete application package in the Non-Disaster (ND) Grants System. Applicants needing technical support with the ND Grants System should contact ndgrants@fema.dhs.gov or (800) 865-4076, Monday-Friday from 9 a.m. to 6 p.m. ET. * WHO DO I CONTACT IF I HAVE QUESTIONS? You may reach out to your assigned Preparedness Officer or contact the FEMA Grants Information Desk by e-mail at fema-grants-news@fema.dhs.gov OR by phone at (800) 368-6498, Monday through Friday, 9 a.m. – 5 p.m. ET. APPLICATION REVIEWS * WILL ALL PROJECTS UNDERGO AN EFFECTIVENESS REVIEW, OR WILL ONLY THOSE SUBMITTED UNDER THE SIX NPAS RECEIVE THIS REVIEW? Only those projects designated as making up the 30% required across all NPA investments will undergo the enhanced effectiveness review and could be subject to a hold for that purpose. However, as in past years, all applications are still subject to the review process described in the funding notice and highlighted in the remaining FAQs. * CAN FEMA PROVIDE ADDITIONAL DETAILS TO HELP APPLICANTS BETTER UNDERSTAND HOW EFFECTIVENESS WILL BE DETERMINED FOR THE NPA INVESTMENTS? Section B.2. of the NOFO will outline the effectiveness criteria that will be used to assess the NPA IJs. FEMA recommends including as much supporting detail as possible to demonstrate how projects and IJs are addressing the NPAs in an effective manner. Supporting details when drafting narratives could include: * How the project/investment descriptions support and align to the proposed budget; * How/why a project has a nexus to terrorism; * How/why a project will influence/address the NPA; * How/why the projects/investments/priorities align and build upon each other for an overall investment strategy that addresses the NPA; * Current and future partners and external entities (state and local units of government, tribal, for-profit, nonprofit) and their geographic area/scope (local, regional, state, federal) that will be engaged to address grant objectives and the NPA; * How you currently engage and collaborate with partners and any efforts to improve and/or expand engagement in the future; * How you measure and evaluate success, improvement, outcomes, impacts (quantitatively and/or qualitatively); * How you use capability gaps, standardized targets, and other results identified in the Threat and Hazard Identification and Risk Assessment/Stakeholder Preparedness Review process to measure and evaluate improvement; and * How you maximize cost effectiveness of grant expenditures through oversight processes and/or other strategies throughout the grant life cycle.   * WHAT ARE THE ADMINISTRATIVE AND ELIGIBILITY CRITERIA THAT FEMA WILL USE TO VERIFY COMPLIANCE FOR ALL PROPOSED INVESTMENTS THAT ARE NOT IN THE NPA IJS?  FEMA will evaluate all applications for completeness, adherence to programmatic guidelines, and feasibility of the proposed investments. This review applies to all projects, including those in the NPA IJs. In addition, for SHSP and UASI projects, FEMA’s review will include verification that each project: * Has a demonstrated nexus to preventing, preparing for, protecting against and responding to acts of terrorism; * Aligns with at least one core capability identified in the National Preparedness Goal; * Demonstrates how investments support closing capability gaps or sustaining capabilities identified in the THIRA/SPR process; and * Supports a National Incident Management System-typed resource, and whether those assets are deployable/shareable to support emergency or disaster operations per existing Emergency Management Assistance Compact agreements. FEMA is also using the same administrative and eligibility review conducted in past several funding cycles. FEMA is required by 31 U.S.C. § 3354, as enacted by the Payment Integrity Information Act of 2019, Pub. L. No. 116-117 (2020); 41 U.S.C. § 2313; and 2 C.F.R. § 200.206 to review information available through any Office of Management and Budget-designated repositories of government-wide eligibility qualification or financial integrity information. Application evaluation criteria may include the following risk-based considerations of the applicant: (1) financial stability; (2) quality of management systems and ability to meet management standards; (3) history of performance in managing federal awards; (4) reports and findings from audits; and (5) ability to effectively implement statutory, regulatory, or other requirements. * WILL PROJECTS BE REVIEWED INDIVIDUALLY?   Yes, projects will be reviewed individually. AWARD ADMINISTRATION * ARE SAAS STILL REQUIRED TO PASS THROUGH AT LEAST 80% OF THE FUNDS AWARDED UNDER SHSP AND UASI TO LOCAL OR TRIBAL GOVERNMENTS WITHIN 45 CALENDAR DAYS OF RECEIPT OF THE FUNDS?  Yes. To meet this requirement, the SAA must issue sub-awards to local or tribal governments in an amount that accounts for at least 80 percent of the SHSP or UASI award, in a manner consistent with the FY 2023 HSGP NOFO. The SAA may issue sub-awards for funding under one or more of the NPAs during the 45-day period and apply that funding to the 80% pass-through requirement. The SAA may issue these sub-awards even if the effectiveness review has not been completed. The subrecipient, however, will not be permitted to expend SHSP or UASI funding under the NPAs until that effectiveness review has been completed and any funds on hold are released by FEMA. For example, if an SAA receives a $10 million SHSP award, it must pass through at least $8 million to local or tribal governments within 45 days. If any of that $8 million is subject to the NPA effectiveness review, the SAA would issue applicable subawards covering that portion, but the subrecipients could not expend that funding that remains subject to the NPA effectiveness review until the review is completed. * ONCE THE EFFECTIVENESS OF A NPA IJ OR PROJECT IS REVIEWED AND CONFIRMED AND ANY FUNDS ON HOLD ARE RELEASED BY FEMA, MAY THE RECIPIENT OR SUBRECIPIENT INCUR COSTS UNDER THAT IJ OR PROJECT DATING BACK TO THE START OF THE AWARD’S PERIOD OF PERFORMANCE, EVEN IF THOSE COSTS WERE INCURRED PRIOR TO THE COMPLETION OF THE EFFECTIVENESS REVIEW? Technically, yes. H; however, recipients and subrecipients are cautioned that they will only be reimbursed for NPA IJs and projects that are deemed effective. If the recipient or subrecipient incurs costs prior to completion of the effectiveness review, it runs the risk that those costs will not be reimbursed with SHSP or UASI funds if that project or portion of the project is deemed not effective. Once the effectiveness of an IJ or project is confirmed by FEMA, recipients may charge allowable costs to the SHSP or UASI award that are incurred at any point during the award’s period of performance.