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Vehicle Mileage Allowance
Appeal Brief
Appeal Letter
Citation: FEMA-1015-DR-PA; DSR 66956; PA ID 000-92051
Cross
Reference: January-February 1994 storm and flood; vehicle mileage allowance.
Summary: The Pennsylvania State Police (PSP) applied for assistance for providing emergency protective service during the disaster. FEMA approved DSR 94921 for $1,283,558 including $868,978 for overtime pay and benefits and $414,580 for vehicle mileage. OIG auditors reviewed the records and recommended denial of the payment of the vehicle mileage portion because PSP did not have documentation to support the mileage. The mileage PSP claimed was extracted from the Motor Vehicle Inventory Report (MVIR) which it claimed was its official record. PSP compiled the MVIR by making monthly visual inspections and entering the mileage of vehicles. The MVIR simply recorded the miles vehicles traversed monthly and was used for informational purposes only. The records did not include information pertaining to where, when or how the mileage was accumulated, and no other documentation existed to show the purpose for each trip made by the vehicles to determine what mileage was disaster emergency-related. FEMA's Regional Director deobligated the mileage allowance and PSP is appealing the determination.
Issue: Should PSP be funded for vehicular mileage based on the MVIR records even though these records did not record the miles that were attributable to performing emergency work?
Findings: PSP did not justify that the mileage it claimed was for performing emergency actions during the disaster. This was caused by the disaster lasting an extraordinarily long time rendering PSP hard pressed to perform its emergency functions and introduce a system to record emergency mileage. Capturing the data at this time will present an unreasonable administrative burden and FEMA will accept its computation of 34% of total miles.
Rationale: 44 CFR 206.226 provides for emergency work in disasters and provides for mileage allowance for vehicles used in emergencies.
Appeal Brief
| Disaster | FEMA-1015-DR |
| Applicant | Pennsylvania State Police |
| Appeal Type | Second |
| PA ID# | 000-92051 |
| PW ID# | 66956 |
| Date Signed | 1998-03-10T05:00:00 |
Citation: FEMA-1015-DR-PA; DSR 66956; PA ID 000-92051
Cross
Reference: January-February 1994 storm and flood; vehicle mileage allowance.
Summary: The Pennsylvania State Police (PSP) applied for assistance for providing emergency protective service during the disaster. FEMA approved DSR 94921 for $1,283,558 including $868,978 for overtime pay and benefits and $414,580 for vehicle mileage. OIG auditors reviewed the records and recommended denial of the payment of the vehicle mileage portion because PSP did not have documentation to support the mileage. The mileage PSP claimed was extracted from the Motor Vehicle Inventory Report (MVIR) which it claimed was its official record. PSP compiled the MVIR by making monthly visual inspections and entering the mileage of vehicles. The MVIR simply recorded the miles vehicles traversed monthly and was used for informational purposes only. The records did not include information pertaining to where, when or how the mileage was accumulated, and no other documentation existed to show the purpose for each trip made by the vehicles to determine what mileage was disaster emergency-related. FEMA's Regional Director deobligated the mileage allowance and PSP is appealing the determination.
Issue: Should PSP be funded for vehicular mileage based on the MVIR records even though these records did not record the miles that were attributable to performing emergency work?
Findings: PSP did not justify that the mileage it claimed was for performing emergency actions during the disaster. This was caused by the disaster lasting an extraordinarily long time rendering PSP hard pressed to perform its emergency functions and introduce a system to record emergency mileage. Capturing the data at this time will present an unreasonable administrative burden and FEMA will accept its computation of 34% of total miles.
Rationale: 44 CFR 206.226 provides for emergency work in disasters and provides for mileage allowance for vehicles used in emergencies.
Appeal Letter
March 10, 1998
Mr. Charles F. Wynne
Governor's Authorized Representative
Pennsylvania Emergency Management Agency
P.O. Box 3321
Harrisburg, Pennsylvania 17105
Dear Mr. Wynne:
This is in response to your August 7, 1997, letter forwarding the Pennsylvania State Police's (PSP's) second appeal of the Federal Emergency Management Agency's (FEMA's) deobligation of funds from damage survey report (DSR) 94921. DSR 94921 was written on May 4, 1994, to authorize funding of $1,283,558 to PSP for providing emergency protective services during the severe winter weather in January-February 1994. The funds included $868,978 for police overtime pay and benefits plus $414,580 for mileage allowance for the use of vehicles. A subsequent audit performed by the Inspector General's Office (OIG) under the provisions of OMB Circular A-128 found that there was a lack of source documentation to support the vehicle mileage claimed and FEMA wrote supplemental DSR 66956 to deobligate the funding for mileage costs.
The vehicular mileage PSP claimed was based on a percentage of the mileage recorded in the Motor Vehicle Inventory Report (MVIR), a centralized database maintained by the state into which PSP reads and enters the mileage on all vehicles under its control once a month. PSP informed the auditors that it maintained no other documentation to support that any of the mileage reported on the MVIR was associated with performing disaster-related emergency work. The OIG, therefore, recommended that these costs were ineligible for funding because they were undocumented. PSP submitted its first appeal of the deobligation on November 25, 1996, which you forwarded to FEMA's Region III Director on December 16, 1996. On June 10, 1997, the Regional Director denied the appeal reiterating that the auditors were unable to find any source documentation to support the mileage for emergency work reported in the MVIR.
In its July 27, 1997, second appeal to the Executive Associate Director, PSP commented on the importance of the MVIR that it used for strategic planning purposes in determining vehicle acquisition, use and disposition. PSP defended the reliability of the data that the MVIR provided stating that it was a source document, and challenged the Regional Director's statement that the information it provided in the first appeal showed that there was no source document to verify the mileage claimed. You forwarded the appeal under cover of your August 7, 1997, letter requesting FEMA's reconsideration of eligibility.
The issue in this appeal is whether the MVIR is considered sufficient documentation to support PSP's requests for reimbursement of $414,580 for vehicle mileage costs. The OIG questioned these costs because the MVIR did not correlate the mileage claimed to eligible activities performed or to eligible employees. FEMA acknowledged that the PSP performed eligible emergency work by approving $868,978 for police overtime. FEMA also acknowledged that PSP uses vehicles to perform its duties. PSP's MVIR only records the total mileage traveled. It does not record the drivers of the vehicles or the purpose of each trip driven. The incident period for this disaster was 52 days and the disaster affected most of the state. It would have been an administrative burden to require the PSP to provide extensive documentation that its administrative system does not normally capture. The PSP estimates that 34% of the total miles driven during the 52-day disaster incident period were related to eligible emergency activities. I have determined that this estimate is reasonable and the costs are eligible for reimbursement.
By copy of this letter, I am asking the Regional Director to take appropriate action to implement this decision. Please inform the applicant of my determination on this appeal.
Sincerely,
/S/
Lacy E. Suiter
Executive Associate Director
Response and Recovery Directorate
cc: Rita A. Calvan
Regional Director
Region III
Mr. Charles F. Wynne
Governor's Authorized Representative
Pennsylvania Emergency Management Agency
P.O. Box 3321
Harrisburg, Pennsylvania 17105
Dear Mr. Wynne:
This is in response to your August 7, 1997, letter forwarding the Pennsylvania State Police's (PSP's) second appeal of the Federal Emergency Management Agency's (FEMA's) deobligation of funds from damage survey report (DSR) 94921. DSR 94921 was written on May 4, 1994, to authorize funding of $1,283,558 to PSP for providing emergency protective services during the severe winter weather in January-February 1994. The funds included $868,978 for police overtime pay and benefits plus $414,580 for mileage allowance for the use of vehicles. A subsequent audit performed by the Inspector General's Office (OIG) under the provisions of OMB Circular A-128 found that there was a lack of source documentation to support the vehicle mileage claimed and FEMA wrote supplemental DSR 66956 to deobligate the funding for mileage costs.
The vehicular mileage PSP claimed was based on a percentage of the mileage recorded in the Motor Vehicle Inventory Report (MVIR), a centralized database maintained by the state into which PSP reads and enters the mileage on all vehicles under its control once a month. PSP informed the auditors that it maintained no other documentation to support that any of the mileage reported on the MVIR was associated with performing disaster-related emergency work. The OIG, therefore, recommended that these costs were ineligible for funding because they were undocumented. PSP submitted its first appeal of the deobligation on November 25, 1996, which you forwarded to FEMA's Region III Director on December 16, 1996. On June 10, 1997, the Regional Director denied the appeal reiterating that the auditors were unable to find any source documentation to support the mileage for emergency work reported in the MVIR.
In its July 27, 1997, second appeal to the Executive Associate Director, PSP commented on the importance of the MVIR that it used for strategic planning purposes in determining vehicle acquisition, use and disposition. PSP defended the reliability of the data that the MVIR provided stating that it was a source document, and challenged the Regional Director's statement that the information it provided in the first appeal showed that there was no source document to verify the mileage claimed. You forwarded the appeal under cover of your August 7, 1997, letter requesting FEMA's reconsideration of eligibility.
The issue in this appeal is whether the MVIR is considered sufficient documentation to support PSP's requests for reimbursement of $414,580 for vehicle mileage costs. The OIG questioned these costs because the MVIR did not correlate the mileage claimed to eligible activities performed or to eligible employees. FEMA acknowledged that the PSP performed eligible emergency work by approving $868,978 for police overtime. FEMA also acknowledged that PSP uses vehicles to perform its duties. PSP's MVIR only records the total mileage traveled. It does not record the drivers of the vehicles or the purpose of each trip driven. The incident period for this disaster was 52 days and the disaster affected most of the state. It would have been an administrative burden to require the PSP to provide extensive documentation that its administrative system does not normally capture. The PSP estimates that 34% of the total miles driven during the 52-day disaster incident period were related to eligible emergency activities. I have determined that this estimate is reasonable and the costs are eligible for reimbursement.
By copy of this letter, I am asking the Regional Director to take appropriate action to implement this decision. Please inform the applicant of my determination on this appeal.
Sincerely,
/S/
Lacy E. Suiter
Executive Associate Director
Response and Recovery Directorate
cc: Rita A. Calvan
Regional Director
Region III