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B.5. Closeout

FEMA will adjust recipient management costs awards to ensure that the amount available for management costs does not exceed the percentage permitted by each program. If the total amount of the grant award is adjusted for any reason, FEMA will de-obligate management costs that exceed allowed amounts. FEMA will adjust subrecipient management cost awards to ensure that available amounts do not exceed the percentage permitted for each program, including approved budget changes or underruns at closeout.

For HMGP, recipient management costs are available for actual documented expenses up to 10% of the total amount of the grant award. The total amount of the grant award means the total amount of contributions based on subapplications submitted when the HMGP application period closes or when the total HMGP ceiling is determined, whichever is later. For HMGP, subrecipients may claim actual documented management costs up to 5% of the actual subaward, inclusive of budget changes.

B.5.1. Closeout Withholding

For HMGP and HMGP Post Fire, FEMA will withhold 3% of the recipient management costs award until closeout to ensure timely management costs closeout. For recipients with an enhanced mitigation plan and who also have a Program Administration by States designation, FEMA will reduce the withholding to 2% of the recipient management costs award. FEMA will provide the withheld assistance after the recipient closes the last non-management cost subaward. The withholding does not apply to the subrecipient’s management costs award, only the recipient’s award.

B.5.2. Availability of Management Costs

For HMGP and HMGP Post Fire, the subrecipient can claim management costs incurred within the subaward period of performance. For HMGP and HMGP Post Fire, the recipient can claim management costs incurred within the award period of performance. Refer to the relevant fiscal year’s NOFO for information regarding the availability of management costs for BRIC and FMA.

The recipient may submit an extension request if additional time is needed to complete management cost activities. The recipient must provide a request that includes the following information:

  • Description of management costs work performed by recipient personnel and or contract support.
  • A cost estimate for the remainder of the award period of performance. The cost estimate must identify costs by budget year (recipient fiscal year or federal fiscal year). The cost estimate must also describe personnel costs by position and number of labor hours anticipated for the activity or general category of activities. The cost categories to include are:
    • Salaries (with overtime).
    • Fringe benefits.
    • Operating expenses.
    • Contracts.
    • One-time expenditures.
    • Equipment.
    • Vehicles.
    • Equipment purchased/leased and the anticipated disposal method.
  • A scope of work and project schedule for remaining period of performance that includes a staffing organizational chart identifying the responsibilities of each position.
  • A copy of scope of work for any contracts used to support recipient management costs activities.
  • A copy of the Administrative Plan. The plan must be updated to include Quarterly Progress Reports procedures so FEMA can adequately measure progress and the plan of action for closing the award and metrics for the number of projects to be closed per year.
  • Accurate current quarterly financial and progress reports.

FEMA analyzes if costs have been incurred outside of the period of performance date and if the Quarterly Progress Report is accurate at the time of the extension request. FEMA may deny a period of performance extension request if payments have been made outside of the period of performance or if the quarterly financial and progress reports are not accurate.