Item 35 - FY 2022 Emergency Management Performance Grant

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HSGP Appendix | 2023 Page A-9 •OPSG funding for temporary or term appointments may pay for salary only. Benefits are not allowable expenses for term or temporary employees; •OPSG remains a non-hiring program. Appropriate uses of temporary or term appointments include: o To carry out specific enforcement operations work for ongoing OPSG-funded patrols throughout the Sector Area of Operation; o To staff operations of limited duration, such as OPSG-enhanced enforcement patrols targeting specific locations or criminal activity; and o To fill OPSG positions in activities undergoing transition or personnel shortages and local backfill policies (medical/military deployments). •OPSG term and temporary appointments must have all necessary certifications and training to enforce state and local laws. OPSG funds will not be used to train or certify term or temporary appointments except as otherwise stated in this Manual and the HSGP Notice of Funding Opportunity (NOFO); and •FEMA provides no guarantee of funding for temporary or term appointments. In addition to the terms of this Manual and the HSGP NOFO, subrecipients must follow their own applicable policies and procedures regarding temporary or term appointments. Management and Administration Management and administration (M&A) costs are allowed. Recipients may use a maximum of up to 5% of HSGP funds awarded for their M&A, and any funds retained are to be used solely for M&A purposes associated with the HSGP award. Subrecipients may also retain a maximum of up to 5% of the funding passed through by the state solely for M&A purposes associated with the HSGP award. M&A activities are those directly relating to the management and administration of HSGP funds, such as financial management and monitoring. M&A expenses must be based on actual expenses or known contractual costs. M&A requests that are simple percentages of the award, without supporting justification, will not be allowed or considered for reimbursement. M&A costs are not operational costs. They are the necessary costs incurred in direct support of the grant or as a result of the grant and should be allocated across the entire lifecycle of the grant. Examples include preparing and submitting required programmatic and financial reports, establishing and/or maintaining equipment inventory, documenting operational and equipment expenditures for financial accounting purposes, responding to official informational requests from state and federal oversight authorities, including completing the Civil Rights Evaluation Tool as required by DHS, and grant performance measurement or evaluation activities. Recipients or subrecipients may apply or credit M&A funding toward the recipient’s requirement to allocate funding toward the National Priority Areas. For example, if a recipient spends $5,000 to manage or administer its funding dedicated toward its protection of soft targets/crowded places investment, the recipient may credit that funding toward its requirement to allocate at least 3% of its award to the protection of soft targets and crowded places National Priority Area. A state’s HSGP funds for M&A calculation purposes includes the total of its SHSP, UASI, and OPSG awards. While the SAA may retain up to 5% of this total for M&A, the state must still ensure that all subrecipient award amounts meet the mandatory minimum pass-through requirements that are applicable to each HSGP program. To meet this requirement, the percentage of SHSP and UASI funds passed through to local or tribal jurisdictions must be based on the state’s total HSG P award prior to withholding any M&A.