Item 35 - FY 2022 Emergency Management Performance Grant

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28 Section 6 ‒ Post Award Requirements | 2022 Closeout Cont. •Completing a review to confirm the accuracy of reported information; •Reconciling actual costs to subawards, modifications and payments; and •Verifying the Subrecipient has submitted a final BSIR showing all grant funds have been expended. Records Retention The records retention period is three years from the date of the Cal OES Grant Closeout letter, or until any pending litigation, claim, or audit started before the expiration of the three-year retention period has been resolved and final action is taken. The Cal OES Grant Closeout Letter will notify the Subrecipient of the start of the records retention period for all programmatic and financial grant-related records. For indirect cost rate proposals, cost allocation plans, or other rate computation records, the start of the record retention period is dependent on whether the proposal, plan, or other computation is required to be submitted to the federal government (or to the pass-through entity) for negotiation purposes. See 2 C.F.R. § 200.334(f). In order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g). If the State Administrative Agency award remains open after the Subrecipient’s submission of the final BSIR, Cal OES will complete any additional BSIR reporting required under the award on behalf of the Subrecipient. Closed grants may still be monitored and audited. Failure to maintain all grant records for the required retention period could result in a reduction of grant funds, and an invoice to return costs associated with the unsupported activities. If documents are retained longer than the required retention period, FEMA, the DHS Office of Inspector General, Government Accountability Office, and pass-through entity have the right to access these records as well. See Title 2 C.F.R § 200.334 and 200.337.