Management costs are indirect costs, direct administrative costs or other administrative expenses associated with a specific project or mitigation activity. The amounts, allowable uses, and procedures for HMGP Post Fire management costs are established in Section 324 of the Stafford Act,[316] as amended by Section 1215 of the Disaster Recovery Reform Act.[317] For more information on indirect costs, refer to Part 13.
Management costs are provided outside of, and separate from, the HMGP Post Fire available assistance amount. The total allowable management costs are up to 15%, of which up to 10% may be used by the recipient and up to 5% by the subrecipient. The subrecipient cannot request more than 5% of the total amount of the grant subaward. FEMA will obligate management cost assistance applied for by recipients and subrecipients in accordance with strategic funds management. There is no additional cost share requirement for HMGP Post Fire management costs.
For the recipient management cost calculation, the “total amount of the HMGP Post Fire award” means the total amount of contributions based on applications submitted when the HMGP Post Fire application period closes or when the total HMGP Post Fire available assistance amount is determined, whichever is later. The total amount of the HMGP Post Fire award includes the 75% federal share plus the required 25% non-federal share. In cases where the recipient submits subapplications totaling more than the HMGP Post Fire available assistance amount, FEMA will only calculate management costs on subapplications up to the final HMGP Post Fire available assistance amount. Figure 13 highlights how HMGP Post Fire management costs are calculated.
FEMA will provide management costs under HMGP Post Fire in accordance with HMGP management costs outlined in Part 10.A.9, except that FEMA will not provide multiple estimates of the amount of management costs available. Instead, it will provide one estimate of the management costs available under HMGP Post Fire for the first fire for which assistance was provided under Section 420 of the Stafford Act, which will be included in the formal funding notification. The estimate will subsequently be increased as appropriate for each FMAG event that is aggregated.
The recipient and subrecipients will be reimbursed for actual management costs incurred. All assistance exceeding the incurred costs will be returned to FEMA.
Recipients cannot receive an additional 5% for management costs if also acting as a subrecipient. Management costs cannot be duplicated. However, other state and territorial agencies (other than the agency designated in the award agreement) who submit subapplications may apply for subrecipient management costs. Additional information regarding specific management costs activities can be found in Part 13.
If the recipient does not apply for the full HMGP Post Fire available assistance amount, FEMA must adjust the amount of available or obligated management costs based on the total amount of subapplications submitted by the end of the application period. If the HMGP Post Fire available assistance amount is adjusted after the application period has closed, FEMA may provide additional management costs based on budget amendments applied to existing subapplications.
Regardless of when subawards are obligated, if the total amount of the award is adjusted for any reason, FEMA will de-obligate management costs that exceed the 15% cap (10% for recipient and 5% for subrecipient) based on updated calculations at the end of the application period or if the HMGP Post Fire available assistance amount is adjusted, whichever is later.