A.2. HMGP: Administrative Plan

The HMGP Administrative Plan (Administrative Plan) is a procedural guide that details how the recipient will administer HMGP awards and subawards. Recipients must have a current Administrative Plan approved by FEMA before receiving HMGP assistance. The Administrative Plan may become an annex or chapter of the state’s or tribe’s overall emergency response and operations plan or comprehensive mitigation program strategy. At a minimum, the Administrative Plan must:

• Designate the agency that will act as recipient.
• Identify the applicant’s hazard mitigation officer or designated representative.
• Identify staffing requirements and resources, including a procedure for expanding staff temporarily following a disaster, if necessary.
• Establish procedures to guide implementation activities, including recipient management costs and distribution of subrecipient management costs.
• Establish procedures for monitoring and reporting on subrecipient management costs.
• Comply with any other requirements outlined in 44 CFR § 206.437.

Recipients must complete the HMGP Administrative Plan Checklist and submit for FEMA’s review as part of the review of the plan.

Typically, the agency designated to act as the recipient (i.e., state, tribe or territory) manages the responsibilities for federal and state/tribal/territorial disaster assistance and is responsible for meeting the mitigation planning requirement. Although a single agency may administer the assistance, the governor may establish an interagency mitigation team to manage the state/tribal/territorial mitigation program.

The recipient’s hazard mitigation officer, or designated representative, is typically responsible for managing the recipient’s mitigation program, coordinating the mitigation team and developing and implementing the hazard mitigation plan. The recipient’s hazard mitigation officer must also make funds available for planning and provide assistance and training to local governments applying for funds and developing mitigation plans.^[286] Recipients often rely on staff from the emergency management agency or other state or tribal agencies to be the hazard mitigation officer’s staff following a disaster.

The Administrative Plan must identify the positions and the minimum number of personnel needed to implement HMGP. Key positions may include clerical, administrative and financial managers; grants managers; engineers and/or architects; and mitigation, community and environmental planners. These positions support mitigation planning and administration and the implementation of mitigation activities. However, the staff organizational structure should remain flexible as it may be augmented as needed with emergency management agency staff, staff from other agencies or temporary staff or contractors hired to administer HMGP effectively. The hazard mitigation officer should build capacity and resilience by using both community and mitigation planners. The Administrative Plan should include a procedure for expanding staff resources and using HMGP management costs.

The mitigation team may include representatives of agencies involved with emergency management, natural resources, floodplain management, environmental issues, historic preservation and archaeology, soil conservation, transportation, planning and zoning, housing and economic development, building regulations, infrastructure regulations or construction, public information, insurance, regional and local government, academia, businesses and nonprofit organizations. With the varied backgrounds and specialized expertise of members, the team creates interagency, interdisciplinary insight regarding risks and potential solutions. The interagency aspect of the team can diffuse political pressure on the recipient agency and increase the availability of resources.

The mitigation team may support the recipient agency by:

• Developing a comprehensive mitigation implementation strategy based on the FEMA‑approved mitigation plan.
• Supporting development and implementation of state, local, tribal and territorial mitigation plans.
• Communicating with local governments regarding mitigation priorities found in mitigation plans and updates based on the disaster activity.
• Coordinating with community planning and capacity-building, recovery planning, HMGP and Public Assistance mitigation.
• Building public and business/industry support for mitigation initiatives.
• Reviewing, assigning priority and recommending mitigation actions for implementation.
• Seeking assistance for implementation of mitigation measures using a wide range of public and private resources in accordance with the National Mitigation Investment Strategy.

The Administrative Plan must establish procedures to:

• Identify and notify potential subapplicants of the availability of HMGP assistance.
• Provide potential subapplicants with information on the application process, management costs, program eligibility and deadlines.
• Determine subapplicant eligibility.
• Provide information, training and technical assistance on mitigation planning requirements.
• Provide information for environmental and historic preservation (EHP) and floodplain management reviews in conformance with FEMA Directive 108-1, Environmental Planning and Historic Preservation Responsibilities and Program Requirements (Oct. 10, 2018).
• Process requests for advances of assistance and reimbursements.
• Monitor and evaluate the progress and completion of mitigation activities.
• Monitor subrecipient management costs.
• Review and approve cost overruns.
• Process appeals.
• Provide technical assistance as required to subrecipients.
• Comply with the administrative requirements of 44 CFR § 206.437 and 2 CFR Part 200.
• Comply with audit requirements of 2 CFR Part 200, Subpart F.
• Provide Quarterly Progress Reports to FEMA on mitigation activities.

A recipient may forward a new or updated Administrative Plan to FEMA for approval at any time. A recipient should review and update their plan annually and must review and update the plan following a major disaster declaration if required to meet current policy guidance or changes to the administration of the program. If a review indicates there will be no changes to the current Administrative Plan, the recipient should notify FEMA within 90 calendar days of the major disaster declaration.