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<br />Preparedness Grants Manual <br />.Subrecipients that renovate their facilities after submitting their application in cases where the <br />subsequent renovations would affect the vulnerability/risk assessment upon which the IJ is <br />based. <br />NSGP project funding is based on the ability of the proposed project to mitigate the risk factors <br />identified in the IJ. For this reason, FEMA may reject requests to significantly change the physical <br />security enhancements that are purchased with NSGP funding where FEMA believes approval of the <br />request would change or exceed the scope of the originally approved project. FEMA will consider all <br />requests to deviate from the security project as originally proposed on a case-by-case basis, <br />consistent with 2 C.F.R. § 200.308(c)(1). <br />Subrecipients may not proceed with implementing any scope/objective changes until the SAA <br />receives written approval from FEMA through FEMA GO and until the SAA has made any required <br />subaward modifications. <br />If a subrecipient is simply making changes to its own budget without impacting the scope or <br />objective of the subaward, and where the budget changes do not involve other prior approval <br />requirements listed in 2 C.F.R. § 200.407, then the subrecipient does not need the prior approval of <br />the SAA or FEMA. See 2 C.F.R. § 200.308. Instead, the subrecipient is only required to report to the <br />SAA the budget changes. Similarly, the SAA should report those budget changes to FEMA. <br />9.3.Pass-Through Requirements <br />Pass-through funding is required under this program. Awards made to the SAA for the NSGP carry <br />additional pass-through requirements. Pass-through is defined as an obligation on the part of the <br />state to make subawards to selected nonprofit organizations. The SAA must provide funds awarded <br />under NSGP to subrecipients within 45 days of receipt of the funds. A letter of intent (or equivalent) <br />to distribute funds is not sufficient. Award subrecipients that are selected for funding under this <br />program must be provided with funding within 45 days from the date the funds are first made <br />available to the recipient so that they can initiate implementation of approved investments. <br />For the SAA to successfully meet the pass-through requirement and provide funding to the <br />subrecipients, the SAA must meet the following four requirements: <br />. <br />. <br />. <br />. <br />There must be some action by the SAA to establish a firm commitment to award the funds to the <br />selected nonprofit organization; <br />The action must be unconditional on the part of the SAA (i.e., no contingencies for availability of <br />SAA funds); <br />There must be documentary evidence of the commitment of the award of funding to the selected <br />nonprofit organization; and <br />The SAA must communicate the terms of the subaward to the selected nonprofit organization. <br />If a nonprofit organization is selected for an NSGP award and elects to decline the award, the SAA <br />must notify their FEMA Preparedness Officer. The SAA may not re-obligate to another subrecipient <br />without prior approval. “Receipt of the funds” occurs either when the SAA accepts the award or 15 <br />calendar days after the SAA receives notice of the award, whichever is earlier. SAAs are sent <br />notification of NSGP awards via the FEMA GO system. If an SAA accepts its award within 15 calendar <br />days of receiving notice of the award in the FEMA GO system, the 45-calendar day pass-through <br />period will start on the date the SAA accepted the award. Should an SAA not accept the NSGP award <br />84