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Qualifying for Federal Reimbursement

Federal regulations allow for a state to qualify for federal reimbursement under the FMAGP in one of two ways; either by meeting the “Individual Fire Cost Threshold,” or by meeting the Calendar year “Cumulative Fire Cost Threshold.”

The state’s individual threshold is tied to a per capita figure, which is subject to change yearly based on inflation. For 2011, the individual threshold for the FMAGP is $1,038,855. In other words, any declared fire that meets this threshold in regard to eligible response costs is eligible for reimbursement under the FMAGP.

By rule, the state’s cumulative threshold is three times the individual threshold, and costs to be compared to the threshold include all eligible response costs for wildfires throughout the state for the entire calendar year to that point in time. This means that for 2011, the cumulative threshold for the FMAGP is $3,116,564. In other words, for a Declared wildfire burning today, sum up all eligible response costs for all wildfire responses that have occurred in the state since January 1. If this sum is greater than the cumulative threshold, all wildfire response costs for declared wildfires throughout the state for the remainder of the calendar year will be eligible for reimbursement under the FMAGP.

Eligible Work

In order for work to be eligible for reimbursement, it must be associated with the declared fire and must have occurred within the approved incident period.
Eligible work may include costs for:

  • Labor, including overtime of permanent or reassigned state and local employees, and regular time and overtime for temporary and contract employees hired to perform fire-related activities;
  • Operation and maintenance of equipment used in eligible firefighting activities;
  • Equipment and supplies, including tools, materials, expended, or lost (less insurance proceeds);
  • Personal comfort and safety items for firefighter health and safety;
  • Travel and per diem;
  • Field camps and meals in lieu of per diem.
  • Emergency work (evacuations and sheltering, police barricading, and traffic control);
  • Evacuations and sheltering, search and rescue;
  • Operating the state Emergency Operations Center (usually used as a Unified Command Center);
  • Mobilization and demobilization;
  • Mitigation, management, and control of declared fires burning on co-mingled Federal land, when such costs are not reimbursable by another Federal agency;
  • Temporary repair of damage caused by firefighting activities; and
  • Pre-positioning of Federal and out-of-State resources for up to 21 days when used in response to declared fire and approved by the Regional Director.
  • Temporary restoration costs for fences, plow lines, roads, base camps, etc. if conducted within 30 days after the close of the Declared Fire Incident Period.

Application Process

Once a fire management assistance declaration has been issued by FEMA, the following documents must be submitted to the FEMA Regional Office by the state as part of the grant application process:

  • FEMA-State Agreement and/or Indian tribal Agreement signed by the Governor/Indian tribal government and the Regional Director. The agreement defines necessary terms and conditions consistent with the provisions of applicable laws and Executive Orders. The agreement is amended for each fire declaration.
  • Standard State Mitigation Plan that addresses wildfire risks and mitigation measures.
  • State Administrative Plan that describes the Grantee’s procedures for administering FMAGP.
  • Request for Federal Assistance (RFA) (Form SF 424) the formal request by the State or Indian tribal government for FMAGP funding assistance.
  • Assurances and Certifications (FEMA Form 20-16) is submitted along with the SF 424.
  • Request for Fire Management Assistance Subgrant (RFMAS) (FEMA Form 90-133) identifies applicants requesting sub-grant FMAGP assistance.
  • Project Worksheet (PW) (FEMA Form 90-91) describes the scope of work eligible for reimbursement.
  • Financial Status Report (FSR) (FEMA Form 20-10) reports all costs incurred within the incident period and all administrative costs incurred within the performance period.

FMAGP Submission Requirements Timeframes

Request for FMA Declaration
(44 CFR §204.22)

GAR submits verbal or written request for FMA declaration to regional point of contact and immediately follows up with FF-90-58.

Incident Period
(44 CFR §204.3)

The time interval during which the declared fire occurs. The RD, in consultation with the GAR and the Principal Advisor, will establish the incident period.

Performance Period
(44 CFR §204.3)

The time interval designated in block #13 on the SF-424 for the Grantee and subgrantees to submit eligible costs and have those costs processed, obligated, and closed-out by FEMA.

Temporary Repair of damage caused by eligible firefighting activities
(44 CFR §204.42(g))

All temporary repair work must be completed within 30 days of the close of the incident period for the declared fire.

Preparing & Submitting and  Application
(44 CFR §204.51(a))

After approval of a fire management assistance declaration, the State may submit an application package, which includes the SF-424 and FF-20-16, and additional supporting documentation. The application should be submitted within 9 months of the declaration. Upon receipt of the written request from the State, the RD may grant an extension for up to 3 months.

Request for Fire Management Assistance
(44 CFR§204.52(a)(l)) (RFMA)

Applicants applying for subgrants under an approved fire management assistance grant must submit a RFMA to the Grantee in accordance with State procedures and within timelines set by the Grantee, but no longer than 30 days after the closure of
this incident period.

Submitting a Project Worksheet
(CFR 44 §204.52 (c)(l))

Applicants should submit all claims for PW development through the Grantee for approval by the RD. The
Grantee will determine the deadline for an Applicant to submit claims, but the deadline must be no later than 6 months from the close of the incident period.

Approval of State’s Grant Application
(44 CFR §204.51(c))

The RD has 45 days from receipt of the State’s grant application, to review and approve or deny the grant application or to notify the Grantee of a delay in processing funds.

Reporting and Audit Requirements
( 44 CFR §204.64(a))

Within 90 days of the performance period expiration date, the State will submit a final financial status report (FF-20-10), which reports all costs incurred within the performance period.

Appeal of FMA Declaration Denial
(44 CFR §204.26)

The Governor may appeal the denial of the request for a Fire Management Assistance declaration within 30 days of the date of the letter denying the request, or submit a
request for a time extension to the Recovery Division Director through the RD. The Recovery Division Director has 90 days to render determination or request additional information.

Appeals of Eligibility
(44 CFR §204.54)

Appeals of eligibility must be submitted within 60 days after receipt of notice of the action that is being appealed. The Grantee will review and forward from an eligible applicant, with a written recommendation, to the RD within 60 days of receipt.  Within 90 days following receipt of the appeal, the RD (for the first appeal) or the Recovery Division Director (for the second appeal) will notify the Grantee in writing of the disposition of the appeal or the need for additional information. A request for additional information will include a date by which the information must be provided. Within 90 days following receipt of additional information the Grantee will be notified in writing of the disposition of the appeal.

Applicant Record-Keeping Guidelines

General Information:

It is essential that local responders accurately document the expenses incurred during the incident period if reimbursement is to be sought for responding to a wildfire.

In the event that a federal declaration occurs, accurate documentation will help you to: 

  • Recover all eligible costs.
  • Be prepared to provide information for the Project Officer to prepare the FEMA Project Worksheet.
  • Have source documents and summaries readily available for validation by the Project Officer.
  • Assist the state and FEMA to review project worksheet(s) for approval.
  • Provide a brief narrative describing the eligible work performed by the applicant.
  • Be ready for future audits or other financial reviews.

Forms and Reports:

While there are many ways to organize records, it is important the information is readily available and in a useable format; i.e., spreadsheets, invoices, financial reports, etc.  Important:  FEMA has a set of five Summary Record form available an applicant may use to summarize project costs.  Please note that these forms serve as a guide, and it is not necessary to use the FEMA forms as long as whatever forms are used contain the information below. If an agency can provide the same or similar summaries from an existing accounting system it is not necessary to use FEMA forms.  The FEMA forms are available in Excel format at: http://www.fema.gov/media-library/assets/documents/26237

The summary record forms are:      

  • Force Account Labor Summary Record (90-123) -- To record agency permanent or temporary labor costs.
  • Material Summary Record (90-124) -- Used to record the supplies and materials that is used out of stock or purchased.
  • Rented Equipment Summary Record (90-125) -- Used to record the costs of rented or leased equipment.
  • Contract Work Summary Record (90-126) -- Used to record the costs of work done by contract.
  • Force Account Equipment Summary Record (90-127) -- To record applicant-owned equipment costs. 

Documentation Samples:
Types of documentation the state and FEMA will review during the site visit includes:

  • A sampling of timesheets to include permanent or temporary staff, vendor or contractor invoices, and other similar labor-reporting documentation.
  • A summary spreadsheet or report with which timesheets, invoices and other documentation that needs to be reviewed can be compared.
  • Source documents which will remain on file at the agency (time reports, vehicle records, purchase receipts, etc.).
  • Definitions of personnel classification groups (for example: permanent, seasonal, career, temporary, etc…).
  • Sample copies of pertinent contracts, cooperative agreements, mutual aid or cost-share agreements.
  • Complete "Applicants Benefit Calculation Worksheets" for each classification.
  • Other documentation determined to be needed by the Project Officer.
  • A map of the fire area showing agency jurisdiction.

Additional documentation that may be required to claim reimbursement for donated resources:

  • Copies of sign-in and sign-out logs showing dates and hours of service for each person.
  • Call or dispatch logs that document the use, location and function provided by donated resources.
  • For donated supplies or equipment, provide an invoice or letter from the vendor or other party showing the date of use and customary charges for the resource.
  • For personnel, provide a copy of an invoice or letter from an organization that shows the cost for the use of the organizations personnel.

Project Worksheets: 
A State Public Assistance Coordinator (State PAC) will be assigned to assist responding agencies in developing their claim for reimbursement on a Project Worksheet. As in other types of disasters, different Project Worksheets will be written for each category of work in which reimbursement is sought. For the FMAGP, the following categories of work are utilized:

  • B – Emergency Protective Measures
  • H – Firefighting Activities
  • Z – Grants Management Costs

Updated:
March 11, 2016 14:41

 

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