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Item # 18
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
June 17, 2025
TOPIC: FY 2024 Emergency Management Performance Grant
AGENDA TITLE
Resolution, Agreement, and Appropriation Adjustment Accepting the FY 2024
Emergency Management Performance Grant (Non-General Fund)
RECOMMENDED ACTION
1. Adopt a resolution authorizing the City Manager to act on behalf of the City of Santa
Ana for obtaining federal funds related to homeland security, emergency management,
and/or disaster recovery provided by the U.S. Department of Homeland Security and
sub-granted through the State of California and the County of Orange.
RESOLUTION NO. 2025-XXX entitled A RESOLUTION OF THE CITY COUNCIL OF
THE CITY OF SANTA ANA AUTHORIZING THE CITY MANAGER OR THE CITY
MANAGER’S DESIGNEE(S) TO OBTAIN 2024 EMERGENCY MANAGEMENT
PERFORMANCE GRANT FUNDS THROUGH THE COUNTY OF ORANGE
2. Authorize the City Manager to execute a two-year agreement with the County of
Orange for the period of July 1, 2024 through June 30, 2026, for the FY 2024
Emergency Management Performance Grant in an amount not to exceed $46,537
(Agreement No. A-2025-XXX).
3. Approve an appropriation adjustment recognizing $46,537 in Law Enforcement Grants
revenue account and appropriating same to the Emergency Management Performance
Grant expenditure account. (Requires five affirmative votes)
GOVERNMENT CODE §84308 APPLIES: No
DISCUSSION
The Emergency Management Performance Grant (EMPG) is funded by the U.S.
Department of Homeland Security and passed through the State of California Office of
Emergency Services. The EMPG grant is designed to assist state and local emergency
management and disaster preparedness programs with employment and development of
emergency management staff, development of emergency plans and procedures, and
preparing cities for disaster response. The EMPG grant is distributed by population to
FY 2024 Emergency Management Performance Grant
June 17, 2025
Page 2
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counties and cities that maintain emergency management staff and meet training,
exercising, and reporting requirements. The County of Orange, Sheriff-Coroner
Department is the lead agency for the county.
In January 2025, the Police Department submitted an initial application for the FY 2024
EMPG Grant and has been awarded $46,537. The Police Department will utilize this
funding to purchase and install one security video camera on Bristol Street to enhance
public safety, as well as to purchase three uninterruptible power supply units for the City
Emergency Operations Center. Existing Police Department funding of the Emergency
Operations Coordinator position fulfills the requirement for matching funds.
In August 2024, the Police Department was awarded FY 2023 EMPG Grant funding for
two security video cameras on Bristol Street. However, the security camera vendor was
unable to complete the project for the contracted amount. Therefore, the grant funding
was terminated. This new grant funding will allow for at least one new camera to be
installed.
ENVIRONMENTAL IMPACT
There is no environmental impact associated with this action.
FISCAL IMPACT
The appropriation adjustment will recognize $46,537 in Law Enforcement Grants,
Reserve Appropriation account (no. 12814002-59011), and appropriate same to EMPG
Grant account as follows:
Fiscal
Year
Accounting Unit
– Account No.
Fund
Description
Accounting Unit,
Account Description Amount
FY 24-25 12814414-69011
Law
Enforcement
Grants
EMPG Grant, Reserve
Appropriation $46,537
Total $46,537
These grant funds are being recognized and appropriated in reserve appropriation and
will be presented to the City Council for approval of carryovers for FY 25-26.
EXHIBIT(S)
1. Resolution
2. FY 2024 EMPG Transfer Agreement with County of Orange
Submitted By: Robert Rodriguez, Police Chief
Approved By: Alvaro Nuñez, City Manager
Resolution No. 2025-XXX
Page 1 of 2
RESOLUTION NO. 2025-xxx
A RESOLUTION OF THE CITY COUNCIL OF THE CITY
OF SANTA ANA AUTHORIZING THE CITY MANAGER
OR THE CITY MANAGER’S DESIGNEE(S) TO
OBTAIN 2024 EMERGENCY MANAGEMENT
PERFORMANCE GRANT FUNDS THROUGH THE
COUNTY OF ORANGE
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SANTA ANA
AS FOLLOWS:
Section 1. The City Council of the City of Santa Ana hereby finds,
determines and declares as follows:
A.The State of California Office of Emergency Services is responsible for
implementing the United States Department of Homeland Security's
Emergency Management Performance Grant Program (EMPG). The
funds cover the salary costs for personnel involved in emergency
management activities as well as the cost of miscellaneous equipment
identified on the OHS approved equipment list.
B.The County of Orange is a subgrantee of the 2024 EMPG funds and
will provide funds to local governments for implementation of
countywide emergency management capabilities.
C.The City of Santa Ana is one of the subrecipients of the EMPG funds
and has been allocated $46,537 of the County of Orange's EMPG
fund.
Section 2. The City Council of the City of Santa Ana hereby authorizes the
City Manager, on terms acceptable to the City Attorney, to execute a subrecipient
transfer agreement (also called a transfer agreement) with the County of Orange
and/or Orange County Sheriff's Department in an amount not to exceed $46,537.
Section 3. The City Council of the City of Santa Ana hereby authorizes and
directs the City Manager or the City Manager’s designee, on terms acceptable to the
City Attorney, to prepare reimbursement agreements for salary costs, equipment,
services, or training with the County of Orange pursuant to the guidelines set for in
the EMPG program and EMPG Articles, Assurances, Certifications, Terms and
Conditions.
Section 4. The City Council of the City of Santa Ana hereby approves an
Appropriation Adjustment recognizing the FY 2024 Emergency Management
Exhibit 1
Resolution No. 2025-XXX
Page 2 of 2
Performance Grant in the amount of $46,537 and appropriates same in the FY 2024
Emergency Management Performance Grant expenditure accounts.
Section 5. This Resolution shall take effect immediately upon the
signing of this Resolution by the City Council and the Clerk of the Council shall
attest to and certify this the vote adopting this Resolution.
SIGNED this day of _______________, 2025.
______________________________
VALERIE AMEZCUA
Mayor
APPROVED AS TO FORM:
Sonia R. Carvalho, City Attorney
By: TAMARA BOGOSIAN
Senior Assistant City Attorney
AYES: Councilmembers
NOES: Councilmembers
ABSTAIN: Councilmembers
NOT PRESENT: Councilmembers
CERTIFICATE OF ATTESTATION AND ORIGINALITY
I, JENNIFER L. HALL, City Clerk, do hereby attest to and certify the attached
Resolution No. 2025-XXX to be the original resolution adopted by the City Council of
the City of Santa Ana on , 2025.
Date:_______________ _____________________________
City Clerk
City of Santa Ana
Exhibit 2
1st July 24
City of Santa Ana
IN WITNESS WHEREOF, the parties hereto have executed this Agreement the date and year
first above written.
ATTEST:CITY OF SANTA ANA
_______________________
JENNIFER L. HALL
City Clerk
_______________________
ALVARO NUNEZ
City Manager
APPROVED AS TO FORM:
SONIA R. CARVALHO
City Attorney
By:
TAMARA BOGOSIAN
Senior Assistant City Attorney
ATTACHMENT A
Preparedness Grants
Manual
FM-207-23-001
April 2024
Preparedness Grants Manual
This page intentionally left blank
Preparedness Grants Manual
Table of Contents
1. Foreword .................................................................................................................................5
1.1.
1.2.
1.3.
1.4.
1.5.
1.6.
Overview of the Federal Emergency Management Agency...........................................5
Overview of the Preparedness Grants Manual’s Intent................................................5
Key Changes....................................................................................................................5
Overview of Preparedness Grant Programs...................................................................6
National Preparedness Goal...........................................................................................8
Strengthening Governance Integration..........................................................................8
2. Award Determination and Obligation ................................................................................... 10
2.1. Federal Award Administration Information................................................................. 10
3. Recipient and Subrecipient Costs........................................................................................ 11
3.1.
3.2.
3.3.
3.4.
3.5.
Funding Restrictions .................................................................................................... 11
Direct Allowable Costs.................................................................................................. 11
Maintenance and Sustainment................................................................................... 15
Management and Administration................................................................................ 16
Procedures for Establishing Indirect Cost Rates........................................................ 16
4. Administrative and National Policy Requirements............................................................... 18
4.1.
4.2.
4.3.
4.4.
4.5.
4.6.
4.7.
4.8.
4.9.
Accessibility Compliance.............................................................................................. 18
Ensuring the Protection of Civil Rights........................................................................ 18
Disability Integration .................................................................................................... 19
Language Access.......................................................................................................... 20
Environmental Planning and Historic Preservation Compliance............................... 20
Davis-Bacon Act Compliance....................................................................................... 23
National Incident Management System Implementation.......................................... 23
SAFECOM Guidance Compliance ................................................................................ 24
Resilient Communications Guidance.......................................................................... 26
4.10. FirstNet ......................................................................................................................... 27
4.11. Department of Homeland Security/FEMA Communications Support Services........ 28
5. Post-Award Management and Implementation.................................................................... 31
5.1.Reporting ...................................................................................................................... 31
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Preparedness Grants Manual
5.2.
5.3.
5.4.
5.5.
5.6.
5.7.
5.8.
Federal Financial Reporting Requirements................................................................ 31
Program Performance Reporting Requirements........................................................ 32
Biannual Strategy Implementation Report ................................................................. 33
Closeout Reporting Requirements.............................................................................. 33
Administrative Closeout............................................................................................... 34
Disclosing Information per 2 C.F.R. § 180.335 ......................................................... 34
Reporting of Matters Related to Recipient Integrity and Performance..................... 35
6. Additional Information.......................................................................................................... 36
6.1.
6.2.
Monitoring and Oversight............................................................................................. 36
Case Studies and Use of Grant-Funded Resources During Real-World Incident
Operations .................................................................................................................... 39
6.3.
6.4.
6.5.
6.6.
6.7.
6.8.
6.9.
Termination Provisions ................................................................................................ 40
Period of Performance Extensions.............................................................................. 40
Conflicts of Interest in the Administration of Federal Awards or Subawards........... 41
Procurement Integrity .................................................................................................. 42
Financial Assistance Programs for Infrastructure...................................................... 46
Records Retention........................................................................................................ 46
Actions to Address Noncompliance............................................................................. 47
6.10. Audits ............................................................................................................................ 48
6.11. Reporting Issues of Fraud, Waste, and Abuse ........................................................... 50
6.12. Payment Information.................................................................................................... 50
6.13. Whole Community Preparedness................................................................................ 50
7. Resources............................................................................................................................. 52
7.1.
7.2.
7.3.
7.4.
7.5.
7.6.
7.7.
7.8.
Department of Homeland Security/FEMA Provided Training and Education........... 52
Training Not Provided by the Department of Homeland Security/FEMA.................. 52
Training Information Reporting System (“Web-Forms”)............................................. 52
FEMA’s National Preparedness Course Catalog ........................................................ 52
Exercises....................................................................................................................... 53
Planning Assistance..................................................................................................... 53
Training Information..................................................................................................... 53
Weblinks ....................................................................................................................... 54
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Preparedness Grants Manual
7.9.Emergency Management Accreditation Program....................................................... 54
8. Homeland Security Grant Program and Tribal Homeland Security Grant Program ............. 55
8.1.
8.2.
8.3.
Alignment to the National Preparedness System (Homeland Security Grant Program,
Tribal Homeland Security Grant Program).................................................................. 55
Reporting on the Implementation of the National Preparedness System (Homeland
Security Grant Program, Tribal Homeland Security Grant Program)......................... 56
Funding Guidelines (Homeland Security Grant Program, Tribal Homeland Security
Grant Program)............................................................................................................. 59
8.4.
8.5.
8.6.
Allowable Costs (Homeland Security Grant Program)................................................ 59
Fusion Centers (Homeland Security Grant Program)................................................. 60
Investment Modifications – Changes in Scope or Objective (Tribal Homeland
Security Grant Program) .............................................................................................. 64
8.7.Continuity Capability (Homeland Security Grant Program, Tribal Homeland Security
Grant Program)............................................................................................................. 65
8.8.
8.9.
Senior Advisory Committee (Homeland Security Grant Program)............................. 65
Urban Area Working Group (Homeland Security Grant Program) ............................. 68
8.10. Supplemental State Homeland Security Program and Urban Area Security Initiative
Guidance (Homeland Security Grant Program).......................................................... 70
8.11. Operation Stonegarden Operational Guidance (Homeland Security Grant Program)
....................................................................................................................................... 71
8.12. Supplemental Resources (Homeland Security Grant Program, Tribal Homeland
Security Grant Program) .............................................................................................. 79
9. Nonprofit Security Grant Program........................................................................................ 83
9.1.
9.2.
Program Funding Guidelines and Priorities................................................................ 83
Nonprofit Security Grant Program Investment Modifications – Changes in Scope or
Objective ....................................................................................................................... 83
9.3.Pass-Through Requirements ....................................................................................... 84
10. Surface Transportation Security Grant Programs (Transit Security Grant Program, Intercity
Passenger Rail Program, Intercity Bus Security Grant Program).................................. 86
10.1. Program Funding Guidelines and Priorities (Transit Security Grant Program, Intercity
Passenger Rail Program, Intercity Bus Security Grant Program) .............................. 86
10.2. Changes in Scope or Objectives (Transit Security Grant Program, Intercity Passenger
Rail Program, Intercity Bus Security Grant Program)................................................. 86
10.3. Security Plan Requirements (Transit Security Grant Program, Intercity Passenger
Rail Program, Intercity Bus Security Grant Program)................................................. 86
10.4. Allowable Cost Guidance ............................................................................................. 89
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11. Port Security Grant Program ................................................................................................ 91
11.1. Program Funding Guidelines and Priorities................................................................ 91
11.2. Allowable Cost Guidance ............................................................................................. 91
11.3. Port-Wide Risk Management Plans............................................................................. 93
11.4. Port Security Grant Program Investment Modifications ............................................ 93
12. Emergency Management Performance Grant Program....................................................... 94
12.1. Alignment of the Emergency Management Performance Grant Program to the
National Preparedness System................................................................................... 94
12.2. Implementation of the National Preparedness System............................................. 95
12.3. Logistics Planning......................................................................................................... 99
12.4. Evacuation Planning...................................................................................................100
12.5. Disaster Housing Planning.........................................................................................101
12.6. State Disaster Recovery Coordinator........................................................................102
12.7. Disaster Financial Management Policies and Procedures......................................102
12.8. Training and Exercises...............................................................................................104
12.9. Reviewing and Updating Planning Products.............................................................108
12.10. Program Performance Reporting Requirements......................................................108
13. Abbreviations and Acronyms.............................................................................................. 109
4
U.S. Department of Homeland Security
Washington, DC 20472
April 12, 2024
MEMORANDUM FOR RECORD
FROM:Pamela S. Williams
Assistant Administrator
Grant Programs Directorate
SUBJECT:Preparedness Grants Manual, April 2024
The Grant Programs Directorate’s Office of Grants Administration (OGA) has developed FEMA
Manual 207-23-001, Preparedness Grants Manual, April 2024. FEMA has developed the
Preparedness Grants Manual (PGM) to guide preparedness grant recipients, including
subrecipients, on how to manage their grants. The preparedness grant programs covered in the
PGM include the following:
Homeland Security Grant Program (comprising the State Homeland Security Grant
Program, the Urban Area Security Initiative, and Operation Stongarden);
Tribal Homeland Security Grant Program;
Nonprofit Security Grant Program;
Transit Security Grant Program;
Intercity Passenger Rail Program;
Intercity Bus Security Grant Program;
Port Security Grant Program; and
Emergency Management Performance Grant Program.
Recipients seeking guidance on policies and procedures for managing the aforementioned FEMA
preparedness grants should reference this manual for further information. Chapters 8-12 of the
PGM contain program-specific information and requirements, while the main content of the
PGM (chapters 1-7) contains important information relevant to all preparedness grant programs
unless otherwise noted.
The PGM has been updated pursuant to FEMA Directive 112-12 v2, Development and
Management of FEMA Policy (October 28, 2019), and in collaboration with the Regional Grants
Management Divisions, the OGA program areas and their Department of Homeland Security
counterparts (e.g., the U.S. Coast Guard, the Transportation Security Administration, and the
Cybersecurity and Infrastructure Security Agency), the Office of External Affairs (including
Tribal Affairs), the Office of Chief Counsel, the Office of Environmental and Historic
Preservation, the Office of Resilience Strategy, the Office of Equal Rights, the Office of
Disability Integration and Coordination, the Office of Policy and Program Analysis, and other
financial assistance support offices.
The PGM April 2024 update associated with this memorandum supersedes the previously
published version of the PGM issued on February 27, 2023, for Fiscal Year 2024 and into the
future, and is effective as of the date of this memorandum. An explanation of specific updates to
the PGM can be found in Section 1.3, Key Changes, after the Table of Contents.
Please contact the GPD Office of Enterprise Grants Services Policy Division at fema-gpd-
policy@fema.dhs.gov if you have any questions regarding FEMA Manual 207-23-001,
Preparedness Grants Manual, April 2024.
Preparedness Grants Manual
1. Foreword
1.1.Overview of the Federal Emergency Management Agency
The mission of the Federal Emergency Management Agency (FEMA) is helping people before, during,
and after disasters, and the agency has done so for more than 40 years. FEMA remains committed
to building resilience and developing a culture of preparedness across the country and unifying all
levels of community and government in an integrated approach to emergency management. FEMA is
part of a larger team of federal agencies, state, local, tribal and territorial (SLTT) governments, and
non-governmental partners that share responsibility for emergency management and national
preparedness. Those closest to areas impacted by any emergency or disaster are the true first
responders—individuals, families, neighbors, and local communities. FEMA’s role is to coordinate
federal resources to supplement SLTT capabilities. FEMA does this by coordinating across all levels
of government meaning that states, local governments, Tribal Nations, and territories are FEMA’s
primary partners.
1.2.Overview of the Preparedness Grants Manual’s Intent
FEMA has developed this Preparedness Grants Manual to guide grant recipients, including
subrecipients, on how to manage their grants. Recipients seeking guidance on policies and
procedures for managing FEMA preparedness grants should reference this manual for further
information. The Notice of Funding Opportunity (NOFO) for each program includes information
needed to apply to the grant. This manual and relevant NOFOs can be reviewed and consulted in
tandem.
Chapters 8-12 of this manual contain program-specific information and requirements, while the main
content of this manual (chapters 1-7) contains important information relevant to all preparedness
grant programs unless otherwise noted. Please be sure to read both the main content of this manual
as well as the program-specific chapters, as needed.
All recipients and subrecipients of FEMA grants must comply with all applicable requirements of the
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
located at 2 C.F.R. Part 200. For more information on 2 C.F.R. Part 200, please see Information
Bulletin (IB) 400, FEMA’s Implementation of 2 C.F.R. Part 200, the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Super Circular” or
“Omni Circular”) dated Dec. 23, 2014, regarding FEMA’s implementation of these provisions prior to
the recent 2020 revisions. For information on the recent revisions to these regulations, see 2 C.F.R.
Grants Management Policy Updates.
1.3.Key Changes
Future updates to this manual will include a section on specific line-by-line “key changes” made
since the last update.
This version of the manual has significantly streamlined pertinent recipient/subrecipient information,
lessening the back-and-forth needed between the NOFO and the Preparedness Grants Manual and
more clearly defining that the NOFO focuses on applying for the grant, while the manual focuses on
managing the grant. Between the Fiscal Year (FY) 2023 and FY 2024 versions, the manual has made
the following overarching changes:
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Preparedness Grants Manual
1. Sections 2-7, unless otherwise noted, apply to all eight grant programs featured in the
manual. These sections are considered generic requirements and do not include how to
apply to the grant.
2. Specific direct allowable cost information, previously in program-specific chapters, has been
moved to the NOFOs. General cost information is in Section 3.
3. The Transit Security Grant Program (TSGP), Intercity Bus Security Grant Program (IBSGP), and
Intercity Passenger Rail (IPR) Program Chapters as well as the Homeland Security Grant
Program (HSGP) and Tribal Homeland Security Grant Program (THSGP) Chapters are
combined.
1.4.Overview of Preparedness Grant Programs
FEMA has the statutory authority to deliver numerous disaster and non-disaster (ND) financial
assistance programs in support of its mission, and that of the U.S. Department of Homeland Security
(DHS), largely through grants and cooperative agreements. These programs account for a significant
amount of the federal assistance funds for which FEMA is accountable. FEMA officials are
responsible and accountable for the proper administration of these funds pursuant to federal laws
and regulations, Office of Management and Budget (OMB) circulars, and federal appropriations laws
and principles. FEMA has developed this manual to provide uniform direction on grant policy and
implementation for the following grant programs. If the FEMA grant program you are looking for is not
listed below, please navigate to FEMA.gov to find more information.
1.4.1. HOMELAND SECURITY GRANT PROGRAM
The HSGP includes a suite of risk-based grants to assist SLTT efforts in preventing, preparing for,
protecting against, and responding to acts of terrorism. The grants under HSGP include:
.
.
.
State Homeland Security Program (SHSP): SHSP assists SLTT efforts to build, sustain, and deliver
the capabilities necessary to prevent, prepare for, protect against, and respond to acts of
terrorism.
Urban Area Security Initiative (UASI): The UASI assists high-risk urban areas’ efforts to build,
sustain, and deliver the capabilities necessary to prevent, prepare for, protect against, and
respond to acts of terrorism.
Operation Stonegarden (OPSG): OPSG supports enhanced cooperation and coordination among
U.S. Customs and Border Protection (CBP), United States Border Patrol (USBP), and federal and
SLTT law enforcement agencies to improve overall border security. OPSG provides funding to
support joint efforts to secure U.S. borders along routes of ingress/egress to and from
international borders, to include travel corridors in states bordering Mexico and Canada, as well
as states and territories with international water borders. SLTT law enforcement agencies utilize
their own law enforcement authorities to support the border security mission and do not receive
any additional authority by participating in OPSG.
For additional information about the HSGP not found in the NOFO, manual, or other program-specific
guidance, contact FEMA-Grants-News@fema.dhs.gov.
1.4.2. TRIBAL HOMELAND SECURITY GRANT PROGRAM
The THSGP provides funding directly to eligible tribes to strengthen their capacity to prevent, prepare
for, protect against, and respond to potential terrorist attacks.
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Preparedness Grants Manual
.For additional information about the THSGP not found in the NOFO, manual, or other program-
specific guidance, contact FEMA-THSGP@fema.dhs.gov.
1.4.3. NONPROFIT SECURITY GRANT PROGRAM
The Nonprofit Security Grant Program (NSGP) provides funding for physical security enhancements
and other security-related activities to nonprofit organizations that are at high risk of a terrorist or
other extremist attack. The NSGP also seeks to integrate the preparedness activities of nonprofit
organizations with broader state and local preparedness efforts.
.For additional information about the NSGP not found in the NOFO, manual, or other program-
specific guidance, contact FEMA-NSGP@fema.dhs.gov.
1.4.4. TRANSIT SECURITY GRANT PROGRAM
The TSGP provides funds to eligible public transportation systems (which include intra-city bus,
ferries, and all forms of passenger rail) to protect critical transportation infrastructure and the
travelling public from terrorism, and to increase transportation infrastructure resilience.
.For additional information about the TSGP not found in the NOFO, manual, or other program-
specific guidance, contact FEMA-TISB-rail-and-transit@fema.dhs.gov.
1.4.5. INTERCITY BUS SECURITY GRANT PROGRAM
The IBSGP provides funds to eligible private operators of intercity over-the-road buses to protect
critical transportation infrastructure and travelling public from acts of terrorism, and to increase
transportation infrastructure resilience.
.For additional information about the IBSGP not found in the NOFO, manual, or other program-
specific guidance, contact FEMA-IBSGP@fema.dhs.gov.
1.4.6. INTERCITY PASSENGER RAIL PROGRAM - AMTRAK
The IPR Program provides funds to the National Railroad Passenger Corporation (Amtrak) to protect
critical transportation infrastructure and the travelling public from terrorism, and to increase
transportation infrastructure resilience.
.For additional information about the IPR Program not found in the NOFO, manual, or other
program-specific guidance, contact FEMA-TISB-rail-and-transit@fema.dhs.gov.
1.4.7. PORT SECURITY GRANT PROGRAM
The Port Security Grant Program (PSGP) provides funding to port authorities, facility operators, and
state and local agencies for activities associated with implementing Area Maritime Security Plans
(AMSP), facility security plans, and other port-wide risk management efforts.
.For additional information about the PSGP not found in the NOFO, manual, or other program-
specific guidance, contact FEMA-GPD-PSGP@fema.dhs.gov.
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1.4.8. EMERGENCY MANAGEMENT PERFORMANCE GRANT PROGRAM
The Emergency Management Performance Grant (EMPG) Program provides funds to assist SLTT
emergency management agencies in obtaining the resources required for implementation of the
National Preparedness System and the National Preparedness Goal of a secure and resilient nation.
.For additional information about the EMPG Program not found in the NOFO, manual, or other
program-specific guidance, contact FEMA-EMPG@fema.dhs.gov.
1.5.National Preparedness Goal
The National Preparedness Goal (the Goal) is “[a] secure and resilient Nation with the capabilities
required across the whole community to prevent, protect against, mitigate, respond to, and recover
from the threats and hazards that pose the greatest risk.” The Goal essentially defines what it means
for all communities to be prepared collectively for the threats and hazards that pose the greatest risk
to the nation. The Goal identifies 32 distinct activities, called core capabilities, needed to address
the risks. The Goal organizes these core capabilities into five categories, called mission areas. Some
core capabilities apply to more than one mission area. For example, the first three core capabilities—
Planning, Public Information and Warning, and Operational Coordination—are cross-cutting
capabilities, meaning they apply to each of the five mission areas. The Goal’s five mission areas
include:
.
.
Prevention: Prevent, avoid, or stop an imminent, threatened, or actual act of terrorism.
Protection: Protect our citizens, residents, visitors, and assets against the greatest threats and
hazards in a manner that allows our interests, aspirations, and way of life to thrive.
.
.
Mitigation: Reduce the loss of life and property by lessening the impact of future disasters.
Response: Respond quickly to save lives, protect property and the environment, and meet basic
human needs in the aftermath of an incident.
.Recovery: Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural,
historic, and environmental fabric of communities affected by an incident.
The mission areas and core capabilities organize the activities and tasks performed before, during,
and after disasters into a framework for achieving the goal of a secure and resilient Nation.
Resilience is the desired outcome, defined in the Goal as the “ability to adapt to changing conditions
and withstand and rapidly recover from disruption due to emergencies.”
Recipients will use the National Preparedness System to build, sustain, and deliver these core
capabilities. The components of the National Preparedness System are Identifying and Assessing
Risk; Estimating Capability Requirements; Building and Sustaining Capabilities; Planning to Deliver
Capabilities; Validating Capabilities; and Reviewing and Updating. Additional details regarding the
National Preparedness System and how it is supported by preparedness grant programs can be
found in the program-specific chapters.
1.6.Strengthening Governance Integration
FEMA preparedness grant programs are intended to support the core capabilities across the five
mission areas of Prevention, Protection, Mitigation, Response, and Recovery that are necessary to
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prepare for incidents that pose the greatest risk to the Nation’s security. Each program reflects the
Department’s intent to build and sustain an integrated network of national capabilities across all
levels of government and the whole community.
Recipients must coordinate activities across preparedness disciplines and levels of government,
including SLTT governments. A cohesive planning framework should incorporate FEMA resources, as
well as those from other federal and SLTT entities, the private sector, and faith-based community
organizations. Disparate governance structures must be integrated and refined to ensure resources
are targeted to support the most critical needs of a community based on risk-driven, capabilities-
based planning. Strong and inclusive governance systems better ensure that disparate funding
streams are coordinated and applied for maximum impact. Inclusive governance can effectively
support a whole community approach to emergency preparedness and management and the
enhancement of core capabilities.
FEMA requires that all governance processes that guide the allocation of preparedness grant funds
adhere to the following guiding principles:
.Coordination of Investments: Resources must be allocated to address the most critical capability
needs and coordinated among affected preparedness stakeholders, including appropriate
representatives of at-risk, underserved communities.
.
.
Transparency: Stakeholders must be provided visibility on how preparedness grant funds are
allocated and distributed, and for what purpose.
Substantive Local Involvement: The tools and processes that are used to inform the critical
priorities, which FEMA grants support, must include local government representatives. At the
recipient level, local risk assessments must be included in the overarching analysis to ensure
that all threats and hazards are accounted for. Primary focus should be on the needs of socially
vulnerable and underserved populations—including rural populations—as well as ensuring equity
for those most at risk relative to disaster preparedness, response, and recovery.
.
.
Accountability: FEMA recognizes that unique preparedness gaps exist at the local level. Grant
recipients are responsible for ensuring the effective use of funds to address those gaps and for
maintaining and sustaining existing capabilities, particularly when it comes to serving the needs
of at-risk, underserved communities.
Support of Regional Coordination: Inter/intra-government entity partnerships and dependencies
at the state, territorial, tribal, and regional levels, including those within metropolitan areas, must
be recognized.
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2. Award Determination and Obligation
2.1.Federal Award Administration Information
2.1.1. NOTICE OF AWARD
Before accepting the award, the Authorized Organizational Representative (AOR) and recipient
should carefully review the award package. The award package includes instructions on
administering the grant award and the terms and conditions associated with responsibilities under
federal awards. Recipients must accept all conditions in the applicable program NOFO, as well as
this manual, in addition to any special terms and conditions in the Notice of Award to receive an
award under the applicable program.
Beginning in FY 2024, notification of award approval is made through the FEMA Grants Outcomes
(FEMA GO) system through an automatic electronic mail to the recipient’s authorized official listed in
the initial application. The award date will be the date that FEMA approves the award. The recipient
should follow the directions in the notification to confirm acceptance of the award.
Recipients must accept their awards within the time specified in the program-specific NOFO. The
recipient shall notify FEMA within this timeframe of its intent to accept and proceed with work under
the award or provide a notice of intent to decline through the FEMA GO system. For instructions on
how to accept or decline an award in the FEMA GO system and for more information on FEMA GO
generally, please see the FEMA GO page on FEMA.gov. Funds will remain on hold until the recipient
accepts the award through the FEMA GO system and all other conditions of the award have been
satisfied or until the award is otherwise rescinded. Failure to accept a grant award within the NOFO-
specified timeframe may result in a loss of funds.
2.1.2. PASS-THROUGH REQUIREMENTS
Please see the applicable program-specific NOFO and chapter of this manual for information on
pass-through requirements for that program.
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3. Recipient and Subrecipient Costs
3.1.Funding Restrictions
All costs charged to awards covered by this manual must comply with the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements at 2 C.F.R. Part 200, unless otherwise
indicated in this manual, the applicable program NOFO, or the terms and conditions of the award.
This includes, among other requirements, that costs must be incurred, and products and services
must be delivered, within the period of performance (POP) of the award. See 2 C.F.R. § 200.403(h)
(referring to budget periods, which for FEMA preparedness grant awards is the same as the POP).
In general, the Cost Principles establish standards for the allowability of costs, provide detailed
guidance on the cost accounting treatment of costs as direct or administrative costs, and set forth
allowability principles for selected items of cost. More specifically, except as otherwise stated in the
applicable program chapter to this manual, the program NOFO, or the terms and conditions of an
award, costs charged to awards covered by this manual must be consistent with the Cost Principles
for Federal Awards located at 2 C.F.R. Part 200, Subpart E. To be allowable, all costs charged to a
FEMA award or applied to the cost share must be reasonable in nature and amount and allocable to
the FEMA award.
Additionally, all costs charged to awards must comply with the grant program’s applicable statutes,
policies, NOFOs, and requirements in this manual, as well as with the terms and conditions of the
award. If FEMA staff identify costs that are inconsistent with any of these requirements, these costs
may be disallowed, and FEMA may recover funds as appropriate, consistent with applicable laws,
regulations, and policies.
As part of those requirements, grant recipients and subrecipients may only use federal funds or
funds applied to a cost share for the purposes set forth in this manual, applicable NOFOs, and the
terms and conditions of the award, and those costs and must be consistent with the statutory
authority for the award. Grant funds may not be used for matching funds for other federal
grants/cooperative agreements, lobbying, or intervention in federal regulatory or adjudicatory
proceedings. In addition, federal funds may not be used to sue the federal government or any other
government entity.
3.2.Direct Allowable Costs
Specific investments made in support of the funding priorities discussed in the NOFOs generally fall
into one of the following eight allowable expense categories:
1. Construction;
2. Equipment;
3. Exercises;
4. Management & Administration (M&A);
5. Organization;
6. Operational Activities;
7. Planning; and
8. Training.
As this list is not exhaustive, refer to the relevant program-specific NOFO, this manual, and the
program-specific point of contact for more information on allowable costs, funding restrictions,
funding priorities, and these categories.
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3.2.1. AUTHORIZED EQUIPMENT LIST
The Authorized Equipment List (AEL) is a list of approved equipment types allowed under FEMA’s
preparedness grant programs. The intended audience of this tool is emergency managers, first
responders, and other homeland security professionals. The list consists of equipment categories
divided into categories, sub-categories, and then individual equipment items.
Grant funds must comply with FEMA Policy #207-22-0002, Prohibited or Controlled Equipment
Under FEMA Awards and may not be used for the purchase of the following unallowable equipment:
firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or vehicles of
any kind with weapons installed. Contact your Preparedness Officer with questions on the AEL.
3.2.2. REQUIREMENTS FOR SMALL UNMANNED AIRCRAFT SYSTEMS
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must
comply with FEMA Policy #207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards,
and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to, or otherwise
use the sUAS equipment. sUAS policies are not required at the time of application but must be
received and approved by FEMA prior to obligating grant funds. All grant-funded procurements must
be executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 –
200.327. For recipients that use grant funds for sUAS, FEMA advises that there is a general privacy
concern related to the use of this equipment if the data the devices collect is transmitted to servers
not under the control of the operator. It has been reported that some manufacturers of sUAS encrypt
data and send that data to servers outside the United States. DHS’s Privacy Office suggests the
recipient fully explore data transmission and storage issues with vendors to reduce the possibility of
data breaches.
Additionally, the Senate Report accompanying the FY 2024 DHS Appropriations further requires
recipients to certify they have reviewed the Industry Alert on Chinese Manufactured Unmanned
Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-made
sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreign-
made versus domestic sUAS.
Acquisition and Use of Technology to Mitigate Unmanned Aircraft Systems (Counter-
Unmanned Aircraft System)
In August 2020, DHS, the Department of Justice, the Federal Aviation Administration, and the
Federal Communications Commission issued the Interagency Legal Advisory on Unmanned Aircraft
Systems (UAS) Detection and Mitigation Technologies. The purpose of the advisory guidance
document is to help non-federal public and private entities better understand the federal laws and
regulations that may apply to the use of capabilities to detect and mitigate threats posed by UAS
operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor
do they conduct legal reviews of commercially available product compliance with those laws. The
advisory does not address state and local laws nor potential civil liability, which UAS detection and
mitigation capabilities may also implicate.
It is strongly recommended that, before the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and
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state criminal, surveillance, and communications laws. Entities should conduct their own legal and
technical analysis of each UAS detection and/or mitigation system and should not rely solely on
vendors’ representations of the systems’ legality or functionality. Please also see the DHS press
release on this topic for further information: Interagency Issues Advisory on Use of Technology to
Detect and Mitigate Unmanned Aircraft Systems. For training on the application of UAS technology in
emergency management programs, please refer to the National Preparedness Course Catalog and
search ‘UAS’ on the website.
The Cybersecurity and Infrastructure Security Agency (CISA) offers several resources that detail the
UAS threat environment and security protocols on the Unmanned Aircraft Systems Resources page
on CISA.gov. Additional resources may be found on the Homeland Security Information Network –
Critical Infrastructure (HSIN-CI) site.
Table 1: Unmanned Aircraft System Allowability
Grant Program
HSGP (SHSP, UASI)
HSGP (OPSG)
THSGP
Allowed
Yes
Yes
Yes
NoNSGP
TSGP Yes
Yes
No
IPR Program
IBSGP
PSGP Yes
YesEMPG Program
3.2.3. PROHIBITIONS ON EXPENDING GRANT OR COOPERATIVE AGREEMENT FUNDS
FOR CERTAIN TELECOMMUNICATIONS AND VIDEO SURVEILLANCE SERVICES OR
EQUIPMENT
Recipients and subrecipients of FEMA federal financial assistance are subject to the prohibitions
described in section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year
2019 (FY 2019 NDAA), Pub. L. No. 115-232 (2018) and 2 C.F.R. §§ 200.216, 200.327, 200.471,
and Appendix II to 2 C.F.R. Part 200. Beginning Aug. 13, 2020, the statute—as it applies to FEMA
recipients, subrecipients, and their contractors and subcontractors—prohibits obligating or expending
federal award funds on certain telecommunications and video surveillance products and contracting
with certain entities for national security reasons.
Guidance is available in FEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for
Covered Telecommunications Equipment or Services.
Additional guidance is available in the Contract Provisions Guide: Navigating Appendix II to Part
200 – Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.
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Effective Aug. 13, 2020, FEMA recipients and subrecipients may not use any FEMA funds
under open or new awards to:
.
.
.
Procure or obtain any equipment, system, or service that uses covered telecommunications
equipment or services as a substantial or essential component of any system, or as critical
technology of any system;
Enter, extend, or renew a contract to procure or obtain any equipment, system, or service that
uses covered telecommunications equipment or services as a substantial or essential
component of any system, or as critical technology of any system; or
Enter, extend, or renew contracts with entities that use covered telecommunications equipment
or services as a substantial or essential component of any system, or as critical technology as
part of any system.
Replacement Equipment and Services: FEMA grant funding may be permitted to procure
replacement equipment and services impacted by this prohibition, provided the costs are otherwise
consistent with the requirements in this manual and the applicable NOFO.
Covered Communications
Per section 889(f)(2)-(3) of the FY 2019 NDAA and 2 C.F.R. § 200.216, covered telecommunications
equipment or services means:
.Telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation,
(or any subsidiary or affiliate of such entities);
.For the purpose of public safety, security of Government facilities, physical security surveillance
of critical infrastructure, and other national security purposes, video surveillance and
telecommunications equipment produced by Hytera Communications Corporation, Hangzhou
Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or
affiliate of such entities);
.
.
Telecommunications or video surveillance services provided by such entities or using such
equipment; or
Telecommunications or video surveillance equipment or services produced or provided by an
entity that the Secretary of Defense, in consultation with the Director of National Intelligence or
the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or
controlled by, or otherwise connected to, the People’s Republic of China.
Examples of the types of products covered by this prohibition include phones, internet, video
surveillance, and cloud servers when produced, provided, or used by the entities listed in the
definition of “covered telecommunications equipment or services.” See 2 C.F.R. § 200.471.
3.2.4. FUNDING FOR CRITICAL EMERGENCY SUPPLIES
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are
an allowable expense under the HSGP (SHSP and UASI only), THSGP, and EMPG Program. Each
state, urban area, or tribe must have FEMA’s approval of a five-year viable inventory management
plan prior to allocating grant funds for stockpiling purposes. The Inventory Management Plan should
address how critical supplies will be maintained and sustained by the grant recipient and include a
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distribution strategy and related sustainment costs if the grant expenditure for these items is over
$100,000. The Inventory Management Plan is associated with but distinct from the Distribution
Management Plan, which addresses how supplies will be distributed in an emergency. For more
information on distribution management planning, see FEMA’s Distribution Management Plan Guide
2.0.
If grant expenditures exceed the minimum threshold, the five-year inventory management plan will
be developed by the recipient and monitored by FEMA. FEMA will provide program oversight and
technical assistance (TA) as it relates to the purchase of critical emergency supplies. FEMA will
establish guidelines and requirements for the purchase of these supplies and monitor development
and status of the recipient’s inventory management plan.
Recipients are strongly encouraged to consult with their respective FEMA Regional Logistics Chief
regarding disaster logistics-related issues. States are further encouraged to share their FEMA
approved plan with local jurisdictions and tribes.
Table 2: Critical Emergency Supplies Allowability
Grant Program
HSGP (SHSP, UASI)
HSGP (OPSG)
THSGP
Allowed
Yes
No
Yes
NSGP No
Surface Transportation
Security Grants (TSGP,
IBSGP, IPR Program)
No
PSGP No
EMPG Program Yes
3.3.Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts or agreements, warranty
coverage, repair or replacement costs, licenses, upgrades, and user fees are allowable under all
active and future grant awards, unless otherwise noted in the program-specific NOFO. These
contracts may exceed the POP if they are purchased incidental to the original purchase of the system
or equipment as long as the original purchase of the system or equipment is consistent with that
which is typically provided for, or available through, these types of agreements, warranties, or
contracts. When purchasing a stand-alone warranty or extending an existing maintenance contract
on an already-owned piece of equipment system, coverage purchased may not exceed the POP of
the award used to purchase the maintenance agreement or warranty. As with warranties and
maintenance agreements, this extends to licenses and user fees as well.
Preparedness grant funds are intended to support the Goal and fund activities and projects that
build and sustain the capabilities necessary to prevent, protect against, mitigate the effects of,
respond to, and recover from those threats and hazards that pose the greatest risk to the security of
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the Nation. To assist recipients in meeting this objective, the policy set forth in IB 379: Guidance to
State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding
allows for the expansion of eligible maintenance and sustainment costs, which must be:
1. In direct support of existing capabilities;
2. An otherwise allowable expenditure under the applicable grant program;
3. Tied to one of the core capabilities in the five mission areas contained within the Goal; and
4. For the HSGP (SHSP and UASI) and EMPG Program only, shareable through the Emergency
Management Assistance Compact (EMAC).
Additionally, eligible costs may also be in support of equipment, training, and critical resources that
have previously been purchased with either federal grant funding or any other source of funding
other than FEMA preparedness grant program dollars.
For the HSGP, stand-alone warranties can only cover equipment purchased with HSGP funds or for
equipment dedicated for HSGP-related purposes.
For the PSGP, maintenance and sustainment are focused specifically on the repair and replacement
of existing equipment and does not include routine activities such as oil changes or
washing/cleaning existing equipment.
For more information on maintenance and sustainment costs, see the program-specific NOFO.
3.4.Management and Administration
M&A costs are for activities directly related to the management and administration of the award,
such as financial management, reporting, and program and financial monitoring. 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. Characteristics of M&A
expenses can include the following: 1) direct costs that are incurred to administer a particular
federal award; 2) identifiable and unique to each federal award; 3) charged based on the activity
performed for that federal award; and 4) not duplicative of the same costs that are included in the
approved Indirect Cost Rate Agreement, if applicable.
Some examples of M&A costs include grants management training for M&A staff, equipment and
supplies for M&A staff to administer the grant award, travel costs for M&A staff to attend
conferences or training related to the grant program, travel costs for the M&A staff to conduct
subrecipient monitoring, contractual services to support the M&A staff with M&A activities, and
auditing costs related to the grant award to the extent required or permitted by statute or 2 C.F.R.
Part 200. For additional program-specific M&A information, please refer to the relevant program-
specific NOFO.
3.5.Procedures for Establishing Indirect Cost Rates
Indirect costs (per 2 C.F.R. § 200.1) are incurred for a common or joint purpose benefitting more
than one cost objective, and not readily assignable to the cost objectives specifically benefitted,
without effort disproportionate to the results achieved. Indirect costs are allowable under all
programs covered by this manual. The requirements and procedures for establishing indirect cost
rates are the same for all the preparedness programs covered by this manual. The process for
establishing the indirect cost rate (per 2 C.F.R. § 200.414) varies based on the type of entity and the
amount of funding they receive:
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.If the entity is a non-governmental entity (e.g., Institutions of Higher Education/hospital, nonprofit
organization, etc.), and is a subrecipient, indirect cost rate procedures are outlined in 2 C.F.R. §
200.332(a)(4) and Appendices III, IV, IX to Part 200. These types of entities may either use the
de minimis rate or negotiate a rate with the pass-through entity.
.If the subrecipient is a state or local governmental entity, indirect cost rate procedures are
established in Appendix VII to Part 200.
o Per Paragraph D.1.b. of Appendix VII, state or local governmental entities receiving grant
funds must develop an indirect cost rate proposal.
‒If the state or local entity receives more than $35 million in grant funding in a fiscal year,
the proposal must be approved by the cognizant agency.
‒If a state or local entity receives $35 million or less in grant funding in a fiscal year, they
must develop an indirect cost rate proposal, but that indirect cost rate proposal does not
need to be approved by the cognizant agency.
.If a state or local governmental entity wants to use the de minimis rate (instead of developing an
indirect cost rate proposal), they can request a case-by-case exception from FEMA (per 2 C.F.R. §
200.102(b)).
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4. Administrative and National Policy Requirements
In addition to the requirements in this section and the applicable NOFO, FEMA may place specific
terms and conditions on individual awards in accordance with 2 C.F.R. Part 200.
All grant recipients for FEMA grants and cooperative agreements are required to comply with the
DHS Standard Terms and Conditions.
The applicable DHS Standard Terms and Conditions will be those in effect at the time the award was
made. The specific terms and conditions that will apply for the award will be clearly stated in the
award package at the time of award.
4.1.Accessibility Compliance
Preparedness grant program recipients using funds to build or alter buildings must comply with the
applicable accessibility requirements under their local building codes, as well as the Section 504
Rehabilitation Act of 1973, 29 U.S.C. § 794, the Architectural Barriers Act of 1968 (ABA), and the
Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12101 et seq., to ensure individuals with
disabilities have access to such buildings. State and local governments are required to provide
qualified individuals with disabilities equal access to their programs, services, or activities, unless
doing so would fundamentally alter the nature of their programs, services or activities or would
impose an undue burden. Accessibility standards under the ABA and ADA are highly similar.
Additional information regarding compliance with the ABA is available at Chapter 1: Using the ABA
Standards on access-board.gov.
4.2.Ensuring the Protection of Civil Rights
As the Nation works toward achieving the Goal, it is important to continue to protect the civil rights of
individuals. Recipients must carry out their programs and activities, including those related to the
building, sustainment, and delivery of core capabilities, in a manner that respects and ensures the
protection of civil rights for protected populations.
Federal civil rights statutes, such as Section 308 of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (Stafford Act), Section 504 of the Rehabilitation Act of 1973, and Title VI
of the Civil Rights Act of 1964, Age Discrimination Act, along with DHS and FEMA regulations,
prohibit discrimination on the basis of race, color, national origin, sex, religion, age, disability, limited
English proficiency, or economic status in connection with programs and activities receiving federal
financial assistance from FEMA as applicable.
Recipients must complete the DHS Civil Rights Evaluation Tool within 30 days of receiving the first
award that fiscal year, not for every award. After initial submittal, an updated submission is due once
every two years during which a recipient has an active award. Information about this requirement
and a fuller list of the civil rights provisions that apply to recipients can be found in the DHS Standard
Terms and Conditions. Additional information on civil rights provisions is available at the Civil Rights
Resources for Recipients of DHS Financial Assistance page on DHS.gov and the Office of Equal
Rights page on FEMA.gov.
Subrecipients are not required to complete or submit the DHS Civil Rights Evaluation tool. However,
subrecipients have the same obligations as their primary recipients to comply with applicable civil
rights requirements and should follow their primary recipient’s procedures regarding the submission
of civil rights information.
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Monitoring and oversight requirements in connection with recipient compliance with federal civil rights
laws are also authorized pursuant to 44 C.F.R Part 7.
In accordance with civil rights laws and regulations, recipients and subrecipients must ensure the
consistent and systematic fair, just, and impartial treatment of all individuals, including individuals
who belong to underserved communities that have been denied such treatment. A full list of Civil
Rights Authorities at FEMA can be found at the External Civil Rights Division page on FEMA.gov.
Recipients and subrecipients (or representatives of such parties) who believe that discrimination has
occurred in awarding or receiving FEMA financial assistance may file a complaint with the Office of
Equal Rights (OER) at FEMA-CivilRightsOffice@fema.dhs.gov. A complaint must be filed no later than
180 days from the date of the alleged discrimination unless the filing deadline is extended by the
Director of the OER or their designee.
4.3.Disability Integration
Pursuant to Section 504 of the Rehabilitation Act of 1973, recipients of FEMA financial assistance
must ensure that their programs and activities do not discriminate against otherwise qualified
individuals with disabilities.
Preparedness grant recipients should engage with the whole community to advance individual and
community preparedness and to work as a nation to build and sustain resilience. In doing so,
recipients should consider the needs of individuals with disabilities into the activities and projects
funded by the grant.
FEMA expects that the integration of the needs of people with disabilities will occur at all levels,
including planning; alerting, notification, and public outreach; training; purchasing of equipment and
supplies; protective action implementation; and exercises/drills.
Section 508 of the Rehabilitation Act of 1973, 29 U.S.C. § 794d, requires federal agencies to
provide individuals with disabilities equal access to electronic information and data comparable to
those who do not have disabilities. Although Section 508 does not impose requirements on federally-
funded recipients, we encourage recipients to use Section 508 best practices to ensure that persons
with disabilities have equal access to web-based products/services. For more information, see the
Accessibility of State and Local Government Websites to People with Disabilities page on ADA.gov.
The following are examples that demonstrate the integration of the needs of people with disabilities
in carrying out FEMA awards:
.Include representatives of organizations that work with/for people with disabilities on planning
committees, work groups and other bodies engaged in development and implementation of the
grant programs and activities.
.
.
Hold all activities related to the grant in locations that are accessible to persons with physical
disabilities to the extent practicable.
Acquire interpretation services appropriate for the population being served, including American
Sign Language or Puerto Rican Sign Language, that provide public information across the
community and in shelters.
.Ensure shelter-specific grant funds are in alignment with FEMA’s Guidance on Planning for
Integration of Functional Needs Support Services in General Population Shelters.
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.If making alterations to an existing building to a primary function area utilizing federal funds,
complying with the most recent codes and standards, and making path of travel to the primary
function area accessible to the greatest extent possible.
.
.
Implement specific procedures used by public transportation agencies that include evacuation
and passenger communication plans and measures for individuals with disabilities.
Identify, create, and deliver training to address any training gaps specifically aimed toward
whole-community preparedness. Include and interact with individuals with disabilities, aligning
with the designated program capability.
.Establish best practices in inclusive planning and preparedness that consider physical access
and information access. Examples of effective communication access for individuals with
disabilities include providing auxiliary aids and services such as sign language interpreters and
materials in Braille or alternate formats.
FEMA grant recipients can fund projects toward the resiliency of the whole community, including
people with disabilities, such as training, outreach, and safety campaigns, provided that the project
aligns with the applicable NOFO, this manual, the applicable chapter to this manual, and the terms
and conditions of the award. For specific guidelines on funding a disability inclusive project, please
refer to the relevant NOFO.
4.4.Language Access
As per FEMA Policy #256-23-001, Language Access, personnel shall take reasonable steps to
provide individuals with limited English proficiency (LEP) with meaningful access to all programs or
activities conducted both by FEMA and by entities receiving funding from FEMA, including grant
recipients. This policy is based upon the principle that it is the responsibility of FEMA—not the LEP
individual—to take reasonable steps to ensure communications are not impaired because of the
limited English proficiency of the individual.
The following are examples that demonstrate the integration of the needs of LEP individuals in
carrying out FEMA awards:
.Establish best practices in inclusive planning and preparedness that consider language access
for LEP individuals.
4.5.Environmental Planning and Historic Preservation Compliance
FEMA must consider the effects of its actions on the environment and historic properties to ensure
that all activities and programs funded by FEMA, including grant-funded projects, comply with federal
Environmental Planning and Historic Preservation (EHP) regulations, laws, and Executive Orders (EO),
as applicable.
Recipients and subrecipients proposing projects that have the potential to impact the natural or built
environment, including, but not limited to, the construction of communication towers; modification or
renovation of existing buildings, structures, and facilities; new construction, including replacement or
relocation of facilities; and some training activities, must participate in the FEMA EHP review
process. The EHP review process involves the submission of a detailed project description along with
any supporting documentation requested by FEMA to determine whether the proposed project has
the potential to impact environmental resources including, but not limited to, threatened or
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endangered species and historic properties; and identify mitigation measures and/or alternative
courses of action that may lessen any impact to those resources. FEMA may recommend mitigation
measures and/or alternative courses of action to lessen any impact to environmental resources and
bring the project into compliance with EHP requirements.
In some cases, FEMA is also required to consult with other regulatory agencies and the public to
complete the review process. The EHP review process must be completed before funds are released
to carry out the proposed project; otherwise, FEMA may not be able to fund the project due to
noncompliance with EHP laws, EOs, regulations, and policies.
DHS and FEMA EHP policy is found in directives and instructions available on Environmental and
Historic Preservation Guidance for FEMA Grant Applications page on FEMA.gov, which includes
documents regarding EHP responsibilities and program requirements, including implementation of
the National Environmental Policy Act and other EHP laws, regulations, and EOs. DHS and FEMA EHP
policy is also found in the EHP Directive & Instruction.
An EHP Screening Form and supporting documentation for preparedness projects requiring EHP
review should be submitted to gpdehpinfo@fema.dhs.gov and your assigned Preparedness Officer.
Additionally, all recipients under this funding opportunity are required to comply with the FEMA EHP
Policy Guidance, FEMA Policy #108-023-1, Grant Programs Directorate Environmental and Historic
Preservation Policy Guidance.
4.5.1. CONSTRUCTION AND RENOVATION
All construction and renovation projects require EHP review. Recipients and subrecipients are
encouraged to have completed as many steps as possible for a successful EHP review in support of
their proposal for funding (e.g., coordination with their State Historic Preservation Office to identify
potential historic preservation issues and to discuss the potential for project effects, compliance with
all state and local EHP laws and requirements). Projects for which the recipient believes an
Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-
01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the
FEMA HQ Preparedness Officer within 6 months of the award and completed EHP review materials
must be submitted no later than 12 months before the end of the POP. EHP policy guidance and the
EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to
gpdehpinfo@fema.dhs.gov.
Refer to the program-specific NOFO for information on construction and renovation allowability and
restrictions.
Construction and Floodplains
All FEMA actions, including grant-funded actions, must comply with National Flood Insurance
Program (NFIP) criteria or any more restrictive federal, state, or local floodplain management
standards or building codes (44 C.F.R. § 9.11(d)(6)).
All FEMA-funded non-critical actions in 1% annual chance floodplains (also known as 100-year
floodplains) that involve new construction or substantial improvement of structures must be
elevated, at a minimum, to the lower of:
.Two feet above the 1% annual chance flood elevation (also known as the base flood elevation),
in accordance with the Federal Flood Risk Management Standard (FFRMS) FVA; or
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.The 0.2% annual chance flood elevation. Where 0.2% annual chance flood elevations are not
available, such actions must be elevated to at least two feet above the 1% annual chance flood
elevation.
All FEMA-funded critical actions in 1% annual chance floodplains or 0.2% annual chance floodplains
(also known as 500-year floodplains) that involve new construction or substantial improvement of
structures must be elevated, at a minimum, to the higher of:
.
.
Three feet above the 1% annual chance flood elevation (also consistent with the FVA); or
The 0.2% annual chance flood elevation. Where 0.2% annual chance flood elevations are not
available, such actions must be elevated to at least three feet above the 1% annual chance flood
elevation.
See EO 11988, Floodplain Management, as amended by EO 13690, Establishing a Federal Flood
Risk Management Standard and a Process for Further Soliciting and Considering Stakeholder Input.
For additional information, see the Guidelines for Implementing EO 11988 and EO 13690.
4.5.2. ENVIRONMENTAL JUSTICE
EO 14096, Revitalizing our Nation's Commitment to Environmental Justice for All and EO 14008,
Tackling the Climate Crisis at Home and Abroad rearticulate and strengthen the environmental
justice framework articulated in 1994 in EO 12898, Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations. Specifically, Section 1 of EO
14096states that: “To fulfill our Nation’s promises of justice, liberty, and equality, every person must
have clean air to breathe; clean water to drink; safe and healthy foods to eat; and an environment
that is healthy, sustainable, climate-resilient, and free from harmful pollution and chemical exposure.
Restoring and protecting a healthy environment—wherever people live, play, work, learn, grow, and
worship—is a matter of justice and a fundamental duty that the Federal Government must uphold on
behalf of all people.”
Some projects funded by FEMA’s grant programs could have environmental justice impacts. New
construction (including communication towers), renovation, demolition, and relocation of buildings
and other structures may have disproportionately high and adverse effects on minority and low-
income populations. FEMA acknowledges the important role that FEMA recipients and subrecipients
play in advancing and achieving environmental justice by identifying low-income and minority
populations within a proposed project’s affected area as early as possible, assessing a project's
impact on existing environmental and human health burdens to account for cumulative effects, and
taking steps to mitigate any harmful impacts.
FEMA will review and evaluate potential projects for environmental justice concerns. If FEMA
determines that a proposed project would have a disproportionately high and adverse effect on
minority or low-income populations, FEMA will consult with recipients and subrecipients to discuss
the feasibility of revising the scope of work to avoid these adverse impacts, or otherwise applying
mitigation measures to alleviate these effects. In addition, FEMA may work with other recipients and
subrecipients to solicit public input on the proposed projects for a more informed decision-making
process. To learn more about how FEMA environmental justice responsibilities might affect your
project, go to the EO 12898: Environmental Justice page on FEMA.gov.
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4.5.3. COMMUNICATION TOWERS
For the purposes of the limitations on funding levels only, communication towers are not considered
construction. When applying for construction funds, including communications towers, recipients
must submit evidence of approved zoning ordinances, architectural plans, and any other locally
required planning permits at the time of application.
All construction of communication towers requires EHP review. When applying for funds to construct
communication towers, recipients and subrecipients must submit evidence that the Federal
Communication Commission’s Section 106 of the National Historic Preservation Act, Pub. L. No. 89-
665, as amended, review process has been completed and submit all documentation resulting from
that review to FEMA with an EHP Screening Form and supporting materials for EHP review. Recipients
and subrecipients are encouraged to have completed as many steps as possible for a successful
EHP review in support of their proposal for funding (e.g., coordination with their state, tribal, or
territorial Historic Preservation Office to identify potential historic preservation issues and to discuss
the potential for project effects, compliance with all state and local EHP laws and requirements).
Projects for which an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01,
Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the
FEMA HQ Preparedness Officer within 6 months of the award. Completed EHP review materials must
be submitted no later than 12 months before the end of the POP. EHP policy guidance and the EHP
Screening Form can both be found on FEMA.gov. EHP review materials should be sent to
gpdehpinfo@fema.dhs.gov.
4.5.4. HAZARD RESISTANT BUILDING CODES
Hazard-resistant building codes are a foundational element of a more resilient nation, safeguarding
communities and lives against natural disasters, with an estimated $11:1 return on investment. The
adoption, enforcement and application of modern building codes mitigates community
vulnerabilities, reduces disaster recovery costs, and strengthens nationwide capability. FEMA is
working to promote and support building codes in all areas of its work in support of the multi-agency
National Initiative to Advance Building Codes. In the interest of building a stronger, more resilient
nation, FEMA encourages all grant recipients and subrecipients to meet current published editions of
relevant consensus-based building codes, specifications and standards, and to exceed them where
feasible.
4.6.Davis-Bacon Act Compliance
Recipients using funds for construction projects must comply with the Davis-Bacon Act (codified as
amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers
and mechanics employed on projects of a character similar to the contract work in the civil
subdivision of the state in which the work is to be performed. Additional information regarding
compliance with the Davis-Bacon Act, including Department of Labor (DOL) wage determinations, is
available from the Davis-Bacon and Related Acts page on DOL.gov.
4.7.National Incident Management System Implementation
National Incident Management System (NIMS) guides all levels of government, nongovernmental
organizations (NGO), and the private sector to work together to prevent, protect against, mitigate,
respond to, and recover from incidents. NIMS provides stakeholders across the whole community
with the shared vocabulary, systems, and processes to successfully deliver the capabilities described
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in the National Preparedness System. As recipients and subrecipients of federal preparedness (ND)
grant awards, jurisdictions and organizations must achieve, or be actively working to achieve, all the
NIMS Implementation Objectives. These objectives and implementation information can be found on
the NIMS and NIMS Implementation and Training pages on FEMA.gov.
Emergency management and incident response activities require carefully managed resources
(personnel, teams, facilities, equipment, and/or supplies) to meet incident needs. NIMS defines a
national, interoperable approach for sharing resources, coordinating, and managing incidents, and
communicating information. Incident management refers to how incidents are managed across all
homeland security activities, including prevention, protection, mitigation, response, and recovery.
Utilization of the standardized resource management concepts such as typing, credentialing, and
inventorying promote a strong national mutual aid capability needed to support the delivery of core
capabilities. Additional information on resource management, NIMS resource typing definitions, job
titles, and position qualifications is available at the NIMS Components – Guidance and Tools page on
FEMA.gov. Please also see the relevant NOFOs for additional requirements regarding NIMS
implementation for specific programs.
4.7.1. NIMS GUIDANCE FOR THE NATIONAL QUALIFICATION SYSTEM
FEMA developed the NIMS Guideline for the National Qualification System (NQS) to describe national
credentialing standards and to provide written guidance regarding the use of those standards. This
guideline describes credentialing and typing processes and identifies tools that Federal Emergency
Response Officials and emergency managers at all levels of government may use both routinely and
to facilitate multijurisdictional coordinated responses. Starting in FY 2023, EMPG Program recipients
are required to use EMPG Program funds to support NQS implementation efforts.
The NQS doctrine promotes interoperability by establishing a common language for defining job titles
and by enabling jurisdictions and organizations to plan for, request, and have confidence in the
capabilities of personnel deployed for disasters and emergencies from other entities through mutual
aid agreements and compacts. Following the concepts and processes in this Guideline will enhance
national preparedness by expanding the network of qualified incident management and support
personnel who can be deployed nationwide.
4.8.SAFECOM Guidance Compliance
Lessons learned from recent major disasters, unplanned events, and full-scale exercises have
identified a need for greater coordination of emergency communications among senior elected
officials, emergency management agencies, and first responders at all levels of government. Federal
responders arriving on the scene of a domestic incident are not always able to communicate with
SLTT response agencies, as well as key government officials. State and local first responders
sometimes experience similar problems, particularly when the incident requires a multi-agency,
regional response effort or when primary communications capabilities fail. This lack of operability
and interoperability between federal and SLTT agencies―further complicated by problems with
communications survivability and resilience―has hindered the ability to share critical information,
which can compromise the unity-of-effort required for an effective incident response.
Departments and agencies at all levels of government have identified a need for improvement in
several high-priority areas, including Governance, Planning, Training and Exercises, Operational
Coordination, and Technology. In addition, communications resilience and continuity should be
viewed as a critical component within each of these areas. These priorities are explained in detail in
Section 2 of the SAFECOM Guidance on Emergency Communications Grants (SAFECOM Guidance).
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By addressing these priorities, which are reflective of proven best practices, emergency
communications can be significantly improved at all levels of government. The end goal is to ensure
operable, interoperable, and resilient communications that maintain a continuous flow of critical
information, under all conditions, among multi-jurisdictional and multi-disciplinary emergency
responders, command posts, agencies, critical infrastructure sectors, and government officials for
the duration of an emergency response operation, and in accordance with NIMS and the National
Emergency Communications Plan, which describes goals and objectives for improving emergency
communications nationwide.
To help meet this goal, the SAFECOM Guidance outlines requirements for grant applications,
including alignment to national, regional, and state communications plans (e.g., National Emergency
Communications Plan (NECP), Statewide Communication Interoperability Plan (SCIP), Tactical
Interoperability Communications Plan (TICP), FEMA Regional Emergency Communications Plan
(RECP)), project coordination, and technical standards for emergency communications technologies.
SCIPs define the current and future direction for interoperable and emergency communications
within a state or territory, while TICPs are designed to allow urban areas, counties, regions,
states/territories, tribes, or federal departments/agencies to document interoperable
communications governance structures, technology assets, and usage policies and procedures. In
addition, FEMA’s formal planning process has produced 10 RECPs and their associated state and/or
tribal/territorial annexes that identify emergency communications capability shortfalls and potential
resource requirements. Grant recipients are encouraged to leverage these planning resources as a
source of input and reference for all emergency communications grant applications and investment
justifications (IJ).
In addition, FEMA formally recognizes several statewide emergency communications governance
bodies (e.g., Statewide Interoperability Coordinator (SWIC), Statewide Interoperability Governance
Board (SIGB), Statewide Interoperability Executive Committee (SIEC), FirstNet State Single Point of
Contact (SPOC)), and strongly encourages grant recipients to closely coordinate with these entities
when developing an emergency communications investment to ensure projects support the state or
territory’s strategy to improve their communications capabilities with the goal of achieving fully
operable, interoperable, and resilient communications. In addition, recipients should work with
public and private entities, and across jurisdictions and disciplines, to demonstrate engagement with
the Whole Community in accordance with Presidential Policy Directive-8 (PPD-8).
For regional, cross-border initiatives, FEMA requires recipients to coordinate projects with national
level emergency communications coordination bodies, such as the National Council of Statewide
Interoperability Coordinators (NCSWIC) and the Regional Emergency Communications Coordination
Working Groups (RECCWG). The NCSWIC promotes and coordinates state-level activities designed to
ensure the highest level of public safety communications across the nation. RECCWGs are
congressionally mandated planning and coordination bodies located in each FEMA Region and
provide a collaborative forum to assess and address the survivability, sustainability, operability, and
interoperability of emergency communications systems at all levels of government. Grant-funded
investments that are coordinated with these bodies will help ensure that federally funded emergency
communications investments are interoperable and support national policies.
All entities using preparedness grant funding to support emergency communications investments are
required to comply with the SAFECOM Guidance. The SAFECOM Guidance provides current
information on emergency communications policies, eligible costs, best practices, and technical
standards for SLTT recipients investing federal funds in emergency communications projects. It is
also designed to promote and align with the NECP. Compliance with the SAFECOM Guidance helps
ensure that federally funded investments are compatible, interoperable, resilient, and support
national goals and objectives for improving emergency communications. Applicants should use the
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SAFECOM Guidance during planning, development, and implementation of emergency
communications projects and in conjunction with other planning documents (e.g., SCIPs).
Specifically, Appendix D of the SAFECOM Guidance contains compliance instructions for FEMA grant
recipients.
Emergency communications investments also will be reviewed jointly by FEMA and CISA to verify
compliance with SAFECOM Guidance. FEMA will coordinate directly with the recipient on any
compliance concerns and will provide TA as necessary to help ensure full compliance.
4.9.Resilient Communications Guidance
The risk imposed by the reliance on communication systems by government and the private sector
can be reduced by understanding dependencies, analyzing effects, and taking action. Entities
planning to use preparedness grant funding for communications investments are encouraged to
take a Whole Community Approach and work with state emergency management agencies, SWICs,
SIGBs, and appropriate stakeholders at the regional and SLTT levels to:
.
.
Plan communication around the whole community to meet everyone’s needs.
Establish robust, resilient, reliable, and interoperable communications capabilities. Account for
the mission impact of communication system disruptions in your planning;
.
.
Ensure mission-related communications (voice, video, data, and network security requirements)
are adequately planned for and understood. It is important to maintain current documentation of
your communication systems architecture and perform regular audits. Your ability to continue
operations is dependent on the availability of and access to communications systems with
sufficient resiliency, redundancy, and accessibility to perform essential functions and provide
critical services during a disruption;
Ensure critical communication systems connectivity among key government leadership, internal
elements, other supporting organizations, and the public under all conditions. As such,
organizations should ensure current copies of vital records, including electronic files and
software, are backed-up and maintained off-site;
.
.
Ensure all communications systems/networks are traced from end to end to identify all Single
Points of Failure (SPF). In doing so, recipients should work with communication service providers
to add redundancy at key critical infrastructure facilities as needed;
Ensure key communication systems resiliency through:
o
o
o
o
o
Ensuring availability of backup systems;
Ensuring diversity of network element components and routing;
Ensuring geographic separation of primary and alternate transmission media;
Ensuring availability of back-up power sources;
Ensuring availability and access to systems that are not dependent on commercial
infrastructure;
o Maintaining spares for designated critical communication systems; and
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o Working with commercial suppliers to remediate communication SPF.
.All communications system owners are encouraged to address the following issues:
o
o
Integrate communications needs into continuity planning efforts by incorporating Primary,
Alternate, Contingency, and Emergency (PACE) methodology, and vulnerability mitigation
options to ensure uninterrupted communications support;
Establish a cybersecurity plan that includes continuity of a communications component such
as Radio Frequency (RF)-based communications that do not rely on public infrastructure;
o
o
o
o
Maintain communications capabilities to ensure their readiness when needed;
Frequently train and exercise personnel required to operate communications capabilities;
Test and exercise communications capabilities; and
Consider Electromagnetic Pulse (EMP) protective measures for communications systems and
emergency backup power where practical.
CISA Emergency Communication Division enhances public safety interoperable communications at
all levels of government and conducts extensive, nationwide outreach to support and promote the
ability of emergency response providers and relevant government officials to communicate in the
event of natural disasters, acts of terrorism, and other hazards. CISA provides plans, resources, and
training to support operable and interoperable emergency communications for first responders.
4.10. FirstNet
The Middle-Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, as amended (codified
in part at 47 U.S.C. §§ 1401-1473) established the First Responder Network Authority (hereinafter
FirstNet Authority) as an independent authority within the National Telecommunications and
Information Administration (NTIA). 47 U.S.C. § 1424(a). The FirstNet Authority’s statutory mission is
to establish a nationwide public safety broadband network (FirstNet). 47 U.S.C. § 1426(b). FirstNet
uses the 700 MHz D block spectrum to provide Long-Term Evolution (LTE)-based broadband services
and applications to public safety entities. 47 U.S.C. §§ 1401(2), 1421(a). FirstNet became
operational in March 2018 and is based on a single, national network architecture that evolves with
technological advances and consists of a physically separate evolved packet core (EPC) network and
radio access networks (RANs).
FirstNet provides public safety entities with mission-critical broadband data capabilities and services
including, but not limited to messaging, image sharing, video streaming, group text, voice, data
storage, application, location-based services, and Quality of Service, Priority, and Preemption. Public
safety entities seeking to enhance their operational capabilities using broadband technology may
seek grant funding from appropriate programs to support the following:
.
.
.
Planning for integration of information technology (IT) infrastructure, software, and site upgrades
necessary to connect to FirstNet;
Handheld broadband devices including smartphones, feature phones, tablets, wearables, push-
to-talk (PTT) devices;
Vehicle-mounted or otherwise field operated data devices, such as ruggedized laptops;
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.
.
Network access devices, including portable Wi-Fi devices, Universal Serial Bus (USB)
modems/dongles, trunk-mounted modems, routers;
Customer-Owned and Managed (COAM) broadband deployable equipment, enabling public safety
to own and dispatch coverage expansion or capacity enhancement equipment within their
jurisdiction;
.
.
.
Broadband device accessories that enable efficient and safe public safety operations such as
headsets, belt clips, earpieces, remote Bluetooth sensors, ruggedized cases;
Subscriber Identification Modules (SIMs)/Universal Integrated Circuit Cards (UICCs) to allow
public safety users to update existing devices to operate on public safety prioritized services; and
One-time purchase and subscription-based applications for public safety use which could
include, among several other options, enterprise mobility management (EMM), mobile device
management (MDM), mobile Virtual Private Network (VPN), identity services, or cloud service
tools.
As FirstNet is built out in all 56 states and territories, and coverage and capacity for first responders
expands, recipients are strongly encouraged to coordinate with SWIC and FirstNet on the planning,
deployment timelines, and operational availability of the network deployment within a specific state
or territory, and to ensure that the project does not conflict with network planning efforts and
complies with all technical requirements. FirstNet requires participating agencies to demonstrate a
subscription to public safety-prioritized broadband services to purchase FirstNet broadband devices
or applications. Recipients must coordinate with FirstNet in advance of any strategic acquisition of
broadband LTE equipment to ensure that purchases adhere to all applicable standards for public
safety entities. Recipients with questions on FirstNet should contact info@firstnet.gov. Please also
refer to the most recent SAFECOM Guidance for additional guidance.
4.11. Department of Homeland Security/FEMA Communications Support
Services
CISA and FEMA offer a variety of TA and other support services to assist state and local entities in
their efforts to comply with the above requirements, including the SAFECOM Guidance, with the goal
of ensuring interoperable and resilient emergency communications. A summary of DHS support
services is provided below. Grant recipients are encouraged to refer to the respective websites for
additional information.
4.11.1. CYBERSECURITY AND INFRASTRUCTURE SECURITY AGENCY SUPPORT
CISA assists agencies through a myriad of services, including direct TA and training provided at no
cost to the jurisdiction. The TA offerings include (but are not limited to):
.
.
.
Coordinated statewide governance (e.g., State Mapping Tool, Interoperable Communications
Reference Guides);
Comprehensive emergency communications planning (e.g., SCIPs, TICPs, and Field Operations
Guides);
Next Generation 911 planning and implementation;
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.
.
.
.
.
Data operability and interoperability;
Alerts and warnings;
Broadband deployment;
Cybersecurity education and awareness; and
Communications Unit (COMU) planning and procedures.
Information on these services is available at the CISA Interoperable Communications Technical
Assistance Program (ICTAP) Resources page on CISA.gov.
4.11.2. FEMA DISASTER EMERGENCY COMMUNICATIONS DIVISION SUPPORT
FEMA Disaster Emergency Communications (DEC) deploys, installs, operates, maintains, and
protects telecommunications, logistics, and operations assets in support of planned special events
and in response to disasters, assisting citizens and first responders.
DEC provides DEC through six geographically dispersed Mobile Emergency Response Support
(MERS) detachments and a pre-positioned fleet of Mobile Communications Office Vehicles (MCOV).
DEC also assists SLTT entities in mitigating their DEC risks and requirements to support life-saving
efforts, protect property, and coordinate response and recovery operations. DEC can assist SLTT
entities in mitigating their DEC risks and requirements to support life-saving efforts, protect property,
and coordinate response and recovery operations. For more information about how DEC can provide
stakeholder support in these areas, see the DEC page on FEMA.gov.
4.11.3. FEMA NATIONAL PREPAREDNESS DIRECTORATE SUPPORT
National Preparedness Directorate (NPD) provides training, exercises, and TA to SLTT stakeholders
that support operational and emergency communications. Descriptions and resources specific to
operational communication are available on FEMA.gov’s Core Capability Development Sheets page
within the Response Mission Area and include the following information to support jurisdictions:
.
.
Description of the operational communications core capability;
Training for building and sustaining operational communication with specific course titles:
o Trainings can also be found at National Training and Education Division (NTED) page on
firstrespondertraining.gov.
.
.
Example capability targets to complete a Threat and Hazard Identification and Risk Assessment
(THIRA):
o Help in developing targets can be found at Unified Reporting Tool (URT)-Info page on FEMA’s
Preparedness Toolkit or requested at FEMA-SPR@fema.dhs.gov.
Tools to validate capabilities through exercises:
o TA and support from subject-matter experts can be requested through the Exercises page on
FEMA.gov.
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4.11.4. FEMA OFFICE OF NATIONAL CONTINUITY PROGRAMS SUPPORT
The Office of National Continuity Program’s (ONCP) support services focus on holistic continuity
planning, of which communications continuity is an important component. Currently, continuity
communications training and TA is limited to the FEMA National Radio System (FNARS) and the
Integrated Public Alerts & Warning System (IPAWS) and is delivered either on an ad hoc basis at the
request of the state entity, through a FEMA Region, or via a requirement for terms of use. Entities
interested in ONCP support services should contact FEMA-CGC@fema.dhs.gov or consult ONCP’s
Continuity Resources Toolkit page on FEMA.gov.
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5. Post-Award Management and Implementation
5.1.Reporting
Recipients are required to submit various financial and programmatic reports as a condition of
award acceptance. Future awards and funds drawdown may be withheld if these reports are
delinquent.
Consultants or contractors are not permitted to be the AOR or the Signatory Authority (SA) of the
recipient. The AOR, as the Authorized Official for the award, is responsible for submitting
programmatic and financial performance reports, accepting award packages, signing assurances
and certifications, and submitting award amendments.
5.2.Federal Financial Reporting Requirements
5.2.1. FEDERAL FINANCIAL REPORT
Recipients must report obligations and expenditures to FEMA on a quarterly basis through the
Federal Financial Report (FFR) form, also known as Standard Form 425 (SF-425). Recipients may
review the FFR at Post-Award Reporting Forms page on Grants.gov. Recipients must file the FFR
electronically using FEMA GO. Note that recipients for awards covered in this manual made before FY
2024 must file the FFR using the Payment and Reporting Systems (PARS).
Financial Reporting Periods and Due Dates
An FFR must be submitted quarterly throughout the POP, including partial calendar quarters, as well
as in periods where no grant award activity occurs. The final FFR is due within 120 days after the end
of the POP. Future awards and fund drawdowns may be withheld if these reports are delinquent,
demonstrate a lack of progress, or are insufficient in detail.
Table 3 shows the reporting periods and due dates for the FFR, except for the final FFR due at 120
days after the end of the POP for purposes of closeout.
Table 3: FFR Reporting Periods and Due Dates
FFR Reporting Period
Oct. 1–Dec. 31
Report Due Date
Jan. 30
Jan. 1–March 31
April 1–June 30
July 1–Sept. 30
April 30
July 30
Oct. 30
Because of a system limitation, if at the end of the POP for awards made prior to FY 2023 a recipient
still has funds to draw down, PARS requires an FFR be submitted within 30 days of the end of the
POP to access those funds. In that case, the recipient will need to submit an FFR within 30 days of
the end of the POP in addition to the final FFR within 120 days of the end of the POP. All other
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recipients who do not need to draw down funds after the end of the POP are only required to submit
the final FFR within 120 days after the end of the POP.
5.3.Program Performance Reporting Requirements
5.3.1. PERFORMANCE PROGRESS REPORTS
Recipients are responsible for providing performance reports to FEMA on a biannual (twice a year) or
quarterly (four times a year) basis via FEMA GO. The Performance Progress Reports (PPR) should
include the following:
.
.
.
A brief narrative of overall project(s) status;
A summary of project expenditures; and
A description of any potential issues that may affect project completion.
For the EMPG Program only, recipients are responsible for providing performance reports to FEMA on
a quarterly (four times a year) basis via FEMA GO. As explained in Section 12.10.1 “Standardized
Programmatic Reporting for the EMPG Program,” the quarterly PPRs must use or be based on the
approved EMPG Program Work Plan template provided in the EMPG Program NOFO.
Program Performance Reporting Periods and Due Dates
The biannual PPRs are due no later than 30 days after the end of the reporting period. Table 4
shows the reporting periods and due dates for biannual PPRs.
Table 4: Biannual PPR Reporting Periods and Due Dates
Reporting Period
Jan. 1–June 30
July 1–Dec. 31
Report Due Date
July 30
Jan. 30
Program Performance Reporting Periods and Due Dates for the Emergency Management
Performance Grant Program
The quarterly PPRs are due no later than 30 days after the end of the quarter. Table 5 shows the
reporting periods and due dates for the quarterly PPRs for the EMPG Program only.
Table 5: Quarterly PPR Reporting Periods and Due Dates (EMPG Program)
Reporting Period
Oct. 1 – Dec. 31
Jan. 1 – March 31
April 1 – June 30
Report Due Date
Jan. 30
April 30
July 30
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Reporting Period Report Due Date
July 1 – Sept. 30 Oct. 30
5.4.Biannual Strategy Implementation Report
Applicable to the HSGP, THSGP, NSGP, and EMPG Program only.
In addition to the financial and performance progress reports, recipients are responsible for
completing and submitting the Biannual Strategy Implementation Report (BSIR) through the FEMA
GO system. For all HSGP, THSGP, NSGP, and EMPG Program awards made prior to FY 2024, the
BSIR was completed in the Grants Reporting Tool.
The BSIR is due within 30 days after the end of the reporting period: July 30 for the reporting period
of January 1 through June 30 (summer BSIR report); and January 30 for the reporting period of July 1
through December 31 (winter BSIR report). All required attributes of each project must be included.
Updated obligations, expenditures, and significant developments must be provided within the BSIR
to show the progress of implementation for every project as well as how expenditures support
Planning, Organization, Equipment, Training, and Exercises. The first BSIR for a given fiscal year
award will be due by January 30, or 30 days after the end of the first reporting period of the award.
Subsequent BSIR reports will require recipients to report on a project-by-project basis.
Recipients also are responsible for completing and submitting a closeout BSIR. When an award’s
POP or the liquidation period ends in the middle of a reporting period, a traditional or “regular” BSIR
must be submitted with full accounting of actual project information/expenditures before a Closeout
BSIR can be created and submitted. Once FEMA approves the last “regular” BSIR, the Closeout BSIR
can be created and submitted. Please contact your respective FEMA Preparedness Officer for
questions regarding the BSIR.
5.5.Closeout Reporting Requirements
Within 120 days after the end of the POP for the prime award or after an amendment has been
issued to close out an award before the original POP ends, whichever occurs first, recipients must
liquidate all financial obligations and submit the following documentation in FEMA GO:
1. The final request for payment, if applicable;
2. The final FFR;
3. The final PPR;
4. A qualitative narrative summary of the impact of those accomplishments throughout the
entire POP submitted to the respective FEMA Preparedness Officer; and
5. Other documents required by program guidance, NOFOs, applicable program-specific
chapters of this manual, terms and conditions of the award, or other FEMA guidance.
In addition, any recipient that issues subawards to any subrecipient is responsible for closing out
those subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit
closeout materials within 90 days of the subaward POP end date. When a subrecipient completes all
closeout requirements, pass-through entities must promptly complete all closeout actions for
subawards in time for the recipient to submit all necessary documentation and information to FEMA
during the closeout of their prime award.
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After the prime award closeout reports have been reviewed and approved by FEMA, a closeout notice
will be completed to close out the grant. The notice will indicate the POP as closed, list any remaining
funds that will be deobligated, and address the requirement of maintaining the award records for at
least three years from the date of the final FFR. The record retention period may be longer than three
years due to an audit, litigation, for equipment or real property used beyond the POP or other
circumstances outlined in 2 C.F.R. § 200.334.
Recipients are responsible for refunding to FEMA any balances of unobligated cash that FEMA paid
that are not authorized to be retained per 2 C.F.R. § 200.344(d).
5.6.Administrative Closeout
Administrative closeout is a mechanism for FEMA to unilaterally move forward with closeout of an
award using available award information in lieu of final reports from the recipient per 2 C.F.R. §
200.344(h)-(i). It is a last resort available to FEMA, and if FEMA needs to administratively close an
award, this may negatively impact a recipient’s ability to obtain future funding. This mechanism can
also require FEMA to make cash or cost adjustments and ineligible cost determinations based on the
information it has, which may result in identifying a debt owed to FEMA by the recipient.
When a recipient is not responsive to FEMA’s reasonable efforts to collect required reports needed to
complete the standard closeout process, FEMA is required under 2 C.F.R. § 200.344(h) to start the
administrative closeout process within the regulatory timeframe. FEMA will make at least three
written attempts to collect required reports before initiating administrative closeout. If the recipient
does not submit all required reports in accordance with 2 C.F.R. § 200.344, the relevant program
NOFO, this manual, and the terms and conditions of the award, FEMA must proceed to
administratively close the award with the information available within one year of the POP end date.
Additionally, if the recipient does not submit all required reports within one year of the POP end date,
per 2 C.F.R. § 200.344(i), FEMA must report in SAM.gov Responsibility/Qualification (R/Q)
(previously known as the Federal Awardee Performance and Integrity Information System) the
recipient’s material failure to comply with the terms and conditions of the award.
If FEMA administratively closes an award where no final FFR has been submitted, FEMA uses that
administrative closeout date in lieu of the final FFR submission date as the start of the three-year
record retention period under 2 C.F.R. § 200.334.
In addition, if an award is administratively closed, FEMA may decide to impose remedies for
noncompliance per 2 C.F.R. § 200.339, consider this information in reviewing future award
applications, or apply special conditions to existing or future awards.
5.7.Disclosing Information per 2 C.F.R. § 180.335
This reporting requirement pertains to disclosing information related to government-wide suspension
and debarment requirements. Before a recipient enters into a grant award with FEMA, the recipient
must notify FEMA if it knows if it or any of the recipient’s principals under the award fall under one or
more of the four criteria listed at 2 C.F.R. § 180.335:
.
.
Are presently excluded or disqualified;
Have been convicted within the preceding three years of any of the offenses listed in 2 C.F.R. §
180.800(a) or had a civil judgment rendered against it or any of the recipient’s principals for one
of those offenses within that time period;
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.
.
Are presently indicted for or otherwise criminally or civilly charged by a governmental entity
(federal, state, or local) with commission of any of the offenses listed in 2 C.F.R. § 180.800(a); or
Have had one or more public transactions (federal, state, or local) terminated within the
preceding three years for cause or default.
At any time after accepting the award, if the recipient learns that it or any of its principals falls under
one or more of the criteria listed at 2 C.F.R. § 180.335, the recipient must provide immediate written
notice to FEMA in accordance with 2 C.F.R. § 180.350.
5.8.Reporting of Matters Related to Recipient Integrity and Performance
Per 2 C.F.R. Part 200, Appendix I § F.3, the additional post-award reporting requirements in 2 C.F.R.
Part 200, Appendix XII may apply to applicants who, if upon becoming recipients, have a total value
of currently active grants, cooperative agreements, and procurement contracts from all federal
awarding agencies that exceeds $10 million for any period of time during the POP of an award under
these funding opportunities.
Recipients that meet these criteria must maintain current information reported in SAM.gov R/Q
about civil, criminal, or administrative proceedings described in paragraph 2 of Appendix XII at the
reporting frequency described in paragraph 4 of Appendix XII.
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6. Additional Information
6.1.Monitoring and Oversight
6.1.1. OVERVIEW
Per 2 C.F.R. § 200.337, FEMA, through its authorized representatives, has the right, at all
reasonable times, to make site visits or conduct desk reviews to review project accomplishments
and management control systems to evaluate award progress and to provide any required TA. During
site visits or desk reviews, FEMA will review recipients’ files related to the award. As part of any
monitoring and program evaluation activities, recipients must permit FEMA, upon reasonable notice,
to review grant-related records and to interview the organization’s staff and contractors regarding the
program. Recipients must respond in a timely and accurate manner to FEMA requests for
information relating to the award.
Effective monitoring and oversight help FEMA ensure that recipients use grant funds for their
intended purpose(s), verify that projects undertaken are consistent with approved plans, and ensure
that recipients make adequate progress toward stated goals and objectives. Additionally, monitoring
serves as the primary mechanism to ensure that recipients comply with applicable laws, rules,
regulations, program guidance, and requirements. FEMA regularly monitors all grant programs both
financially and programmatically in accordance with federal laws, regulations (including 2 C.F.R. Part
200), program guidance, and the terms and conditions of the award. All monitoring efforts ultimately
serve to evaluate progress toward grant goals and proactively target and address issues that may
threaten grant success during the POP.
FEMA staff will periodically monitor recipients to ensure that administrative processes, policies and
procedures, budgets, and other related award criteria are meeting federal government-wide and
FEMA regulations. Aside from reviewing quarterly financial and programmatic reports, FEMA may
also conduct enhanced monitoring through desk-based reviews, onsite monitoring visits, or both.
Enhanced monitoring will involve the review and analysis of financial compliance and administrative
processes, policies, activities, and other attributes of each federal assistance award, and it will
identify areas where the recipient may need TA, corrective actions, or other support.
Financial and programmatic monitoring are complementary processes within FEMA’s overarching
monitoring strategy that function together to ensure effective grants management, accountability,
and transparency; validate progress against grant and program goals; and safeguard federal funds
against fraud, waste, and abuse. Financial monitoring primarily focuses on statutory and regulatory
compliance with administrative grant requirements, while programmatic monitoring seeks to validate
and assist in grant progress, targeting issues that may be hindering project goals and ensuring
compliance with the purpose of the grant and grant program. Both monitoring processes are similar
in that they feature initial reviews of all open awards and in-depth monitoring of grants requiring
additional attention.
Recipients and subrecipients who are pass-through entities are responsible for monitoring their
subrecipients in a manner consistent with the terms of the federal award at 2 C.F.R. Part 200,
including 2 C.F.R. § 200.332. This includes the pass-through entity’s responsibility to monitor the
activities of the subrecipient as necessary to ensure that the subaward is used for authorized
purposes, in compliance with federal statutes, regulations, and the terms and conditions of the
subaward, and that subaward performance goals are achieved.
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In terms of overall award management, recipient and subrecipient responsibilities include—but are
not limited to—accounting of receipts and expenditures, cash management, maintaining adequate
financial records, reporting, and refunding expenditures disallowed by audits, monitoring if acting as
a pass-through entity, other assessments and reviews, and ensuring overall compliance with the
terms and conditions of the award or subaward, as applicable, including the terms of 2 C.F.R. Part
200.
6.1.2. FINANCIAL MONITORING OVERVIEW AND APPROACH
FEMA’s approach to financial monitoring provides a standard monitoring framework that promotes
consistent processes across all monitoring staff. There are four core components of the monitoring
process:
1. Monitoring Assessment: Monitoring staff measure each grant’s monitoring needs using a
system of pre-determined evaluation criteria. The criteria help assess the recipient and
potential challenges to the success of the grant award.
2. Monitoring Selection and Scheduling: Monitoring staff make selection and scheduling
decisions in accordance with applicable statutory requirements, such as the Homeland
Security Act of 2002, as amended (hereafter “HSA”) and consider the results of the
monitoring assessment process.
3. Monitoring Activities: Monitoring activities include cash analysis, desk reviews, and site visits.
Grants Management Specialists are responsible for conducting quarterly or semi-annual
reviews of all grants via cash analysis. Desk reviews and site visits are additional monitoring
activities conducted on grants where the monitoring assessment process identified the need
for additional monitoring and validated the use of FEMA resources for these activities.
4. Post-Monitoring Actions: Monitoring staff may follow up with recipients via post-monitoring
actions based on the outcomes of monitoring activities. Post-monitoring actions include
conducting additional monitoring; reviewing Corrective Action Plans (CAP) and monitoring the
progress of CAP deliverables; documenting the resolution of identified corrective actions and
issues; providing TA and recipient training; and debt collection.
In addition to the monitoring guidance outlined above, section 2022(a)(2)(A) of the HSA mandates
the frequency of monitoring activities for applicable preparedness grants. The applicable section of
the HSA reads as follows:
Not less than once every 2 years, the Administrator shall conduct, for each state and high-
risk urban area receiving a grant administered by the Department, a programmatic and
financial review of all grants awarded by the Department to prevent, prepare for, protect
against, or respond to natural disasters, acts of terrorism, or other man-made disasters,
excluding assistance provided under section 203, title IV, or title V of the Robert T. Stafford
Disaster Relief and Emergency Assistance Act (42 U.S.C. 5133, 5170 et seq., and 5191 et
seq.).
HSGP (including SHSP, UASI, and OPSG), NSGP, TSGP, PSGP, and the EMPG Program are subject to
HSA monitoring requirements. The IPR Program, IBSGP, and THSGP are not subject to HSA
monitoring requirements.
6.1.3. STANDARD MONITORING ACTIVITY: CASH ANALYSIS
Through cash analysis, a Grants Management Specialist assesses and reports on the recipients’
cash-on-hand, expenditures, and unliquidated obligations; gauges potential cost share shortfalls and
cash on hand issues; and monitors spend down activities within the POP. The analysis reconciles
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and compares grant disbursement records with the recipient submitted FFR. This process identifies
recipients that may require additional monitoring due to issues identified with drawdowns or FFR
submissions.
6.1.4. ENHANCED MONITORING ACTIVITIES: DESK REVIEW, SITE VISIT
Desk reviews and site visits are two forms of additional monitoring that FEMA conducts on a
recipient. Table 6 defines the key differences and similarities.
Table 6: Enhanced Financial Monitoring Activities (Desk Review and Site Visit)
Attribute Desk Review Site Visit
Location/ A detailed, paper-based review and A visit by FEMA grants management staff
conducted at the site of the recipient’s
operations and/or selected performance
sites. Site visits may require travel.
Logistics evaluation conducted at a FEMA office.
Desk reviews do not require travel.
Materials Required reports, correspondence, and
Reviewed other documentation, including policies
and procedures, to substantiate
Includes documents listed under the desk
review in addition to all applicable
documents and required reports
necessary to assess recipient capability
and progress, validate records, and
substantiate compliance with laws,
compliance. Additional documentation
available remotely may include
information available through the grant
file, financial reports, interviews, and other regulations, and policies.
documentation and correspondence to
verify compliance.
The goals of FEMA’s financial desk review The goals of FEMA’s financial site visit
monitoring activities are, as applicable, to: monitoring activities are, as applicable, to:Goal of
Monitoring
Activity .Review grant files to verify compliance, . Review grant files to verify compliance,
conduct interviews to confirm conduct interviews to confirm
adherence to approved program plans,
and confirm equipment acquisition,
allowable use, and inventory controls;
adherence to approved program plans,
and confirm equipment acquisition,
allowable use, and inventory controls;
.
.
.
.
Document that recipient institutions
possess adequate internal controls,
policies, processes, and systems to
manage FEMA grants effectively;
.
.
Document that recipient institutions
possess adequate internal controls,
policies, processes, and systems to
manage FEMA grants effectively;
Assist the recipient with the grant
process and provide guidance to
improve recipient administrative
efficiencies;
Assist the recipient with the grant
process and provide guidance to
improve recipient administrative
efficiencies;
Identify and analyze relevant problems . Identify and analyze relevant problems
that might prevent the program from
achieving its internal and external
objectives; and
that might prevent the program from
achieving its internal and external
objectives; and
Provide TA..Provide TA.
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6.1.5. PROGRAMMATIC MONITORING OVERVIEW AND APPROACH
Programmatic monitoring involves oversight throughout the award lifecycle for FEMA to verify that
programs and projects undertaken by recipients are consistent with approved plans and comply with
applicable laws, regulations, program guidance, and the terms and conditions of the award.
FEMA’s monitoring approach complies with the monitoring requirements described in section 2022
of the HSA Programmatic monitoring also plays an important role in ensuring that FEMA
preparedness grant funding builds and sustains capabilities at the SLTT levels that advance the
Goal. Programmatic monitoring also is an opportunity for FEMA staff to build relationships with
recipients and to work collaboratively to identify and mitigate factors that may impede programmatic
performance.
The programs subject to section 2022 of the HSA and three additional programs (THSGP, IPR
Program, and IBSGP) are included in this programmatic monitoring approach—meaning that all
programs included in this manual are part of this programmatic monitoring approach.
FEMA uses a risk- and project-based programmatic monitoring framework for its preparedness grant
programs that is designed for data-driven grants management, and which interacts seamlessly with
other aspects of the grant lifecycle. FEMA uses monitoring as a vehicle to validate data previously
self-reported by recipients in applications and reporting tools. FEMA does not utilize monitoring as a
data collection tool in and of itself. By specializing monitoring in this way, FEMA avoids duplicative
data collection, targets its resources more effectively, and provides stronger and more proactive TA
to its recipients. The framework also comprehensively documents grant management decisions for
resource allocation.
This programmatic monitoring approach establishes baseline monitoring of all open awards across
the FEMA preparedness grant portfolio using a First Line Review (FLR). The FLR identifies recipients
and awards with a high potential for noncompliance with regulations or failure to meet project
objectives. The FLR uses quantifiable measures (criteria) to prioritize and rank recipients and awards
according to identified risks that threaten the success of FEMA’s preparedness grant awards.
Results of this prioritization process determine which high-risk recipients and awards will receive
advanced monitoring. Post-monitoring actions document and communicate findings and
recommendations for resolution to the recipients and FEMA leadership and allow for increasingly
cohesive programmatic and financial monitoring processes.
6.2.Case Studies and Use of Grant-Funded Resources During Real-World
Incident Operations
Analyzing the use of grant-funded investments in real-world incidents will improve the ability of FEMA
and its SLTT partners to assess the effectiveness of these investments and to better understand how
grant funds support improvements in nationwide capability levels. Currently, FEMA conducts case
studies with a limited number of grant recipients each year to explore how jurisdictions prioritize
grant investments based on risk and capability assessments, and the ways specific investments
improve SLTT preparedness (see the Preparedness Grants Case Studies page on FEMA.gov). By
accepting the award, the recipient agrees to participate in a case study or evaluation if requested.
Recipients can also contact FEMA-PreparednessGrantEvaluation@fema.dhs.gov if interested in
volunteering to participate in a case study.
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6.3.Termination Provisions
FEMA may terminate a federal award in whole or in part for one of the following reasons. FEMA and
the recipient must still comply with closeout requirements at 2 C.F.R. §§ 200.344-200.345 even if
an award is terminated in whole or in part. To the extent that subawards are permitted under the
respective program’s NOFO, pass-through entities should refer to 2 C.F.R. § 200.340 for additional
information on termination regarding subawards.
1. Noncompliance. If a recipient fails to comply with the terms and conditions of a federal
award, FEMA may terminate the award in whole or in part. If the noncompliance can be
corrected, FEMA may first attempt to direct the recipient to correct the noncompliance. This
may take the form of a Compliance Notification. If the noncompliance cannot be corrected or
the recipient is non-responsive, FEMA may proceed with a Remedy Notification, which could
impose a remedy for noncompliance per 2 C.F.R. § 200.339, including termination. Any
action to terminate based on noncompliance will follow the requirements of 2 C.F.R. §§
200.341-200.342 as well as the requirement of 2 C.F.R. § 200.340(c) to report in SAM.gov
R/Q the recipient’s material failure to comply with the award terms and conditions. See also
the section on Actions to Address Noncompliance.
2. With the Consent of the Recipient. FEMA may also terminate an award in whole or in part
with the consent of the recipient, in which case the parties must agree upon the termination
conditions, including the effective date, and in the case of partial termination, the portion to
be terminated.
3. Notification by the Recipient. The recipient may terminate the award, in whole or in part, by
sending written notification to FEMA setting forth the reasons for such termination, the
effective date, and in the case of partial termination, the portion to be terminated. In the
case of partial termination, FEMA may determine that a partially terminated award will not
accomplish the purpose of the federal award, so FEMA may terminate the award in its
entirety. If that occurs, FEMA will follow the requirements of 2 C.F.R. §§ 200.341-200.342 in
deciding to fully terminate the award.
6.4.Period of Performance Extensions
Extensions to the POP for programs addressed in this manual are allowed under limited
circumstances. Extensions to the initial POP identified in the award will only be considered through
formal, written requests to the recipient’s FEMA Preparedness Officer or Program Manager and must
contain specific and compelling justifications as to why an extension is required. Recipients are
advised to coordinate with their FEMA Preparedness Officer or Program Manager as needed when
preparing an extension request.
All extension requests must address the following:
1. The grant program, fiscal year, and award number;
2. Reason for the delay—including details of the legal, policy, or operational challenges that
prevent the final outlay of awarded funds by the deadline;
3. Current status of the activity(ies);
4. Approved POP termination date and new project completion date;
5. Amount of funds drawn down to date;
6. Remaining available funds, both federal and, if applicable, non-federal;
7. Budget outlining how remaining federal and, if applicable, non-federal funds will be
expended;
8. Plan for completion, including milestones and timeframes for achieving each milestone and
the position or person responsible for implementing the plan for completion; and
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9. Certification that the activity(ies) will be completed within the extended POP without any
modification to the original statement of work, as described in the investment justification
and as approved by FEMA.
Extension requests will be granted only due to compelling legal, policy, or operational challenges.
Extension requests will only be considered for the following reasons:
.
.
.
.
Contractual commitments by the recipient or subrecipient with vendors prevent completion of
the project within the existing POP;
The project must undergo a complex environmental review that cannot be completed within the
existing POP;
Projects are long-term by design, and therefore acceleration would compromise core
programmatic goals; or
Where other special or extenuating circumstances exist.
Recipients should submit all proposed extension requests to FEMA for review and approval at least
120 days before the end of the POP to allow sufficient processing time. Extensions are typically
granted for no more than a six-month period. Recipients are advised to coordinate with their FEMA
Preparedness Officer or Program Manager as needed when preparing an extension request.
Recipients should refer to the corresponding chapter of this manual for program-specific details
related to POP extensions.
6.5.Conflicts of Interest in the Administration of Federal Awards or
Subawards
For conflicts of interest under grant-funded procurements and contracts, refer to the section on
Procurement Integrity in the applicable NOFO, this manual, and 2 C.F.R. §§ 200.317 – 200.327.
To eliminate and reduce the impact of conflicts of interest in the subaward process, recipients and
pass-through entities must follow their own policies and procedures regarding the elimination or
reduction of conflicts of interest when making subawards. Recipients and pass-through entities are
also required to follow any applicable federal or SLTT statutes or regulations governing conflicts of
interest in the making of subawards.
The recipient or pass-through entity must disclose to the respective Preparedness Officer or Program
Manager, in writing, any real or potential conflict of interest that may arise during the administration
of the federal award, as defined by the federal or SLTT statutes or regulations or their own existing
policies, within five calendar days of learning of the conflict of interest. Similarly, subrecipients,
whether acting as subrecipients or as pass-through entities, must disclose any real or potential
conflict of interest to the recipient or next-level pass-through entity as required by the recipient or
pass-through entity’s conflict of interest policies, or any applicable federal or SLTT statutes or
regulations.
Conflicts of interest may arise during the process of FEMA making a federal award in situations
where an employee, officer, or agent, any members of their immediate family or their partner has a
close personal relationship, a business relationship, or a professional relationship, with an applicant,
subapplicant, recipient, subrecipient, or FEMA employee.
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6.6.Procurement Integrity
Through audits conducted by the DHS Office of Inspector General (OIG) and FEMA grant monitoring,
findings have shown that some FEMA recipients have not fully adhered to the proper procurement
requirements when spending grant funds. Anything less than full compliance with federal
procurement requirements jeopardizes the integrity of the grant, as well as the grant program. To
assist with determining whether an action is a procurement or instead a subaward, please consult 2
C.F.R § 200.331. For detailed guidance on the federal procurement standards, recipients and
subrecipients should refer to various materials issued by FEMA’s Procurement Disaster Assistance
Team (PDAT), such as the PDAT Field Manual and Contract Provisions Guide. Additional resources,
including an upcoming trainings schedule, can be found on the PDAT’s Contracting with Federal
Funds for Goods and Services Before, During and After Disasters page on FEMA.gov.
The subsections below highlight the federal procurement requirements for FEMA recipients when
procuring goods and services with federal grant funds. FEMA will include a review of recipients’
procurement practices as part of the normal monitoring activities. All procurement activity must be
conducted in accordance with federal procurement standards at 2 C.F.R. §§ 200.317–200.327.
Select requirements under these standards are listed below. The recipient and any of its
subrecipients must comply with all requirements, even if they are not listed below.
Under 2 C.F.R. § 200.317, when procuring property and services under a federal award, states
(including territories) must follow the same policies and procedures they use for procurements from
their non-federal funds; additionally, states must follow 2 C.F.R. § 200.321 regarding socioeconomic
steps, § 200.322 regarding domestic preferences for procurements, § 200.323 regarding
procurement of recovered materials, and § 200.327 regarding required contract provisions.
All other non-federal entities, such as tribes, local governments, and nonprofit organizations, must
have and use their own documented procurement procedures that reflect applicable SLTT laws and
regulations, provided that the procurements conform to applicable federal law and the standards
identified in 2 C.F.R. Part 200. These standards include, but are not limited to, providing for full and
open competition consistent with the standards of 2 C.F.R. § 200.319 and § 200.320.
6.6.1. IMPORTANT CHANGES TO PROCUREMENT STANDARDS IN 2 C.F.R. PART 200
OMB recently updated various parts of Title 2 of the Code of Federal Regulations, among them, the
procurement standards. States are now required to follow the socioeconomic steps in soliciting small
and minority businesses, women’s business enterprises, and labor surplus area firms per 2 C.F.R. §
200.321. All non-federal entities should also, to the greatest extent practicable under a federal
award, provide a preference for the purchase, acquisition, or use of goods, products, or materials
produced in the United States per 2 C.F.R. § 200.322. More information on OMB’s revisions to the
federal procurement standards can be found in the Purchasing Under a FEMA Award: OMB Revisions
Fact Sheet.
The recognized procurement methods in 2 C.F.R. § 200.320 have been reorganized into informal
procurement methods, which include micro-purchases and small purchases; formal procurement
methods, which include sealed bidding and competitive proposals; and noncompetitive
procurements. The federal micro-purchase threshold is currently $10,000, and non-state entities
may use a lower threshold when using micro-purchase procedures under a FEMA award. If a non-
state entity wants to use a micro-purchase threshold higher than the federal threshold, it must follow
the requirements of 2 C.F.R. § 200.320(a)(1)(iii)-(v). For small purchase procedures (2 C.F.R. §
200.320(a)(2)) under a FEMA award, the federal Simplified Acquisition Threshold (SAT) is currently
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$250,000, and a non-state entity may use a lower threshold but may not exceed the federal
threshold. See 2 C.F.R. § 200.1 (citing the definition of SAT from 48 C.F.R. Part 2, Subpart 2.1).
See 2 C.F.R. § 200.216, § 200.471, and Appendix II as well as FEMA Policy #405-143-1,
Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or
Services, the relevant program NOFO, and this manual regarding prohibitions on covered
telecommunications equipment or services.
6.6.2. COMPETITION AND CONFLICTS OF INTEREST
Among the requirements of 2 C.F.R. § 200.319(b) applicable to all non-federal entities other than
states, to ensure objective contractor performance and eliminate unfair competitive advantage,
contractors that develop or draft specifications, requirements, statements of work, or invitations for
bids or requests for proposals must be excluded from competing for such procurements. FEMA
considers these actions to be an organizational conflict of interest and interprets this restriction as
applying to contractors that help a non-federal entity develop its grant application, project plans, or
project budget. This prohibition also applies to the use of former employees to manage the grant or
carry out a contract when those former employees worked on such activities while they were
employees of the non-federal entity.
Under this prohibition, unless the non-federal entity solicits for and awards a contract covering both
development and execution of specifications (or similar elements as described above), and this
contract was procured in compliance with 2 C.F.R. §§ 200.317 – 200.327, federal funds cannot be
used to pay a contractor to carry out the work if that contractor also worked on the development of
those specifications. This rule applies to all contracts funded with federal grant funds, including pre-
award costs, such as grant writer fees, as well as post-award costs, such as grant management fees.
Additionally, some of the situations considered to be restrictive of competition include, but are not
limited to:
.
.
.
.
.
.
Placing unreasonable requirements on firms for them to qualify to do business;
Requiring unnecessary experience and excessive bonding;
Noncompetitive pricing practices between firms or between affiliated companies;
Noncompetitive contracts to consultants that are on retainer contracts;
Organizational conflicts of interest;
Specifying only a “brand name” product instead of allowing “an equal” product to be offered and
describing the performance or other relevant requirements of the procurement; and
.Any arbitrary action in the procurement process.
Per 2 C.F.R. § 200.319(c), non-federal entities other than states must conduct procurements in a
manner that prohibits the use of statutorily or administratively imposed SLTT geographical
preferences in the evaluation of bids or proposals, except in those cases where applicable federal
statutes expressly mandate or encourage geographic preference. Nothing in this section preempts
state licensing laws. When contracting for architectural and engineering services, geographic
location may be a selection criterion provided its application leaves an appropriate number of
qualified firms, given the nature and size of the project, to compete for the contract.
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Under 2 C.F.R. § 200.318(c)(1), non-federal entities other than states are required to maintain
written standards of conduct covering conflicts of interest and governing the actions of their
employees engaged in the selection, award, and administration of contracts. No employee, officer, or
agent may participate in the selection, award, or administration of a contract supported by a federal
award if he or she has a real or apparent conflict of interest. Such conflicts of interest would arise
when the employee, officer or agent, any member of his or her immediate family, his or her partner,
or an organization that employs or is about to employ any of the parties indicated herein, has a
financial or other interest in or a tangible personal benefit from a firm considered for a contract. The
officers, employees, and agents of the non-federal entity may neither solicit nor accept gratuities,
favors, or anything of monetary value from contractors or parties to subcontracts. However, non-
federal entities may set standards for situations in which the financial interest is not substantial, or
the gift is an unsolicited item of nominal value. The standards of conduct must provide for
disciplinary actions to be applied for violations of such standards by officers, employees, or agents of
the non-federal entity.
Under 2 C.F.R. § 200.318(c)(2), if the recipient or subrecipient (other than states) has a parent,
affiliate, or subsidiary organization that is not an SLTT government, the non-federal entity must also
maintain written standards of conduct covering organizational conflicts of interest. In this context,
organizational conflict of interest means that because of a relationship with a parent company,
affiliate, or subsidiary organization, the non-federal entity is unable or appears to be unable to be
impartial in conducting a procurement action involving a related organization. The non-federal entity
must disclose in writing any potential conflicts of interest to FEMA or the pass-through entity in
accordance with applicable FEMA policy.
6.6.3. SUPPLY SCHEDULES AND PURCHASING PROGRAMS
Generally, a non-federal entity may seek to procure goods or services from a federal supply schedule,
state supply schedule, or group purchasing agreement.
6.6.4. GENERAL SERVICES ADMINISTRATION SCHEDULES
States, tribes, local governments, and any instrumentality thereof (such as local education agencies
or institutions of higher education), may procure goods and services from a General Services
Administration (GSA) schedule. GSA offers multiple efficient and effective procurement programs for
SLTT governments, and instrumentalities thereof, to purchase products and services directly from
pre-vetted contractors. The GSA schedules (also referred to as the Multiple Award Schedules and the
Federal Supply Schedules) are long-term government-wide contracts with commercial firms that
provide access to millions of commercial products and services at volume discount pricing.
Information about GSA programs for states, tribes, and local governments, and instrumentalities
thereof, can be found at the Programs for State and Local Governments and State and Local
Governments pages on GSA.gov.
For tribes, local governments, and their instrumentalities that purchase off of a GSA schedule, this
will satisfy the federal requirements for full and open competition provided that the recipient follows
the GSA ordering procedures; however, tribes, local governments, and their instrumentalities will still
need to follow the other rules under 2 C.F.R. §§ 200.317–200.327, such as solicitation of minority
businesses, women’s business enterprises, small businesses, or labor surplus area firms (§
200.321), domestic preferences (§ 200.322), contract cost and price (§ 200.324), and required
contract provisions (§ 200.327 and Appendix II).
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6.6.5. OTHER SUPPLY SCHEDULES AND PROGRAMS
For non-federal entities other than states, such as tribes, local governments, and nonprofits, that
want to procure goods or services from a state supply schedule, cooperative purchasing program, or
other similar program, for such procurements to be permissible under federal requirements, the
following must be true:
.The procurement of the original contract or purchasing schedule and its use by the non-federal
entity complies with state and local law, regulations, and written procurement procedures;
.The state or other entity that originally procured the original contract or purchasing schedule
entered into the contract or schedule with the express purpose of making it available to the non-
federal entity and other similar types of entities;
.
.
.
The contract or purchasing schedule specifically allows for such use, and the work to be
performed for the non-federal entity falls within the scope of work under the contract as to type,
amount, and geography;
The procurement of the original contract or purchasing schedule complied with all the
procurement standards applicable to a non-federal entity other than states under at 2 C.F.R. §§
200.317–200.327; and
With respect to the use of a purchasing schedule, the non-federal entity must follow ordering
procedures that adhere to applicable SLTT laws and regulations and the minimum requirements
of full and open competition under 2 C.F.R. Part 200.
If a non-federal entity other than a state seeks to use a state supply schedule, cooperative
purchasing program, or other similar type of arrangement, FEMA recommends the recipient discuss
the procurement plans with its FEMA Preparedness Officer or Program Manager.
6.6.6. PROCUREMENT DOCUMENTATION
Per 2 C.F.R. § 200.318(i), non-federal entities other than states and territories are required to
maintain and retain records sufficient to detail the history of procurement covering at least the
rationale for the procurement method, contract type, contractor selection or rejection, and the basis
for the contract price. States and territories are encouraged to maintain and retain this information
as well and are reminded that for any cost to be allowable, it must be adequately documented per 2
C.F.R. § 200.403(g).
Examples of the types of documents that would cover this information include but are not limited to:
.Solicitation documentation, such as requests for quotes, invitations for bids, or requests for
proposals;
.
.
Responses to solicitations, such as quotes, bids, or proposals;
Pre-solicitation independent cost estimates and post-solicitation cost/price analyses on file for
review by federal personnel, if applicable;
.Contract documents and amendments, including required contract provisions; and
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.Other documents required by federal regulations applicable at the time a grant is awarded to a
recipient.
Additional information on required procurement records can be found on pages 24–26 of the PDAT
Field Manual.
6.7.Financial Assistance Programs for Infrastructure
6.7.1. BUILD AMERICA, BUY AMERICA ACT
Recipients and subrecipients must comply with the Text - H.R.3684 - 117th Congress (2021-2022):
Infrastructure Investment and Jobs Act | Congress.gov | Library of Congress, which was enacted as
part of the Infrastructure Investment and Jobs Act §§ 70901-70927, Pub. L. No. 117-58 (2021); and
the Executive Order on Ensuring the Future Is Made in All of America by All of America's Workers |
The White House. See also 2 C.F.R. Part 184 and OMB Memorandum M-24-02, Implementation
Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for
Infrastructure.
None of the funds provided under HSGP, THSGP, NSGP, TSGP, IBSGP, PSGP, the IPR Program, and
the EMPG Program may be used for a project for infrastructure unless the iron and steel,
manufactured products, and construction materials used in that infrastructure are produced in the
United States.
Additional information on the Buy America preference can be found in the program-specific NOFO.
6.8.Records Retention
6.8.1. RECORD RETENTION PERIOD
Financial records, supporting documents, statistical records, and all other non-federal entity records
pertinent to a federal award generally must be maintained for at least three years from the date the
final FFR is submitted. See 2 C.F.R. § 200.334. Further, if the recipient does not submit a final FFR
and the award is administratively closed, FEMA uses the date of administrative closeout as the start
of the general record retention period.
The record retention period may be longer than three years or have a different start date in certain
cases. These include:
.Records for real property and equipment acquired with federal funds must be retained for three
years after final disposition of the property. See 2 C.F.R. § 200.334(c).
.If any litigation, claim, or audit is started before the expiration of the three-year period, the
records must be retained until all litigation, claims, or audit findings involving the records have
been resolved and final action taken. See 2 C.F.R. § 200.334(a).
.The record retention period will be extended if the recipient is notified in writing of the extension
by FEMA, the cognizant or oversight agency for audit, or the cognizant agency for indirect costs.
See 2 C.F.R. § 200.334(b).
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.
.
Where FEMA requires recipients to report program income after the POP ends, the program
income record retention period begins at the end of the recipient’s fiscal year in which program
income is earned. See 2 C.F.R. § 200.334(e).
For indirect cost rate proposals, cost allocation plans, or other rate computations records, the
start of the record retention period depends on whether the indirect cost rate documents were
submitted for negotiation. If the indirect cost rate documents were submitted for negotiation, the
record retention period begins from the date those documents were submitted for negotiation. If
indirect cost rate documents were not submitted for negotiation, the record retention period
begins at the end of the recipient’s fiscal year or other accounting period covered by that indirect
cost rate. See 2 C.F.R. § 200.334(f).
6.8.2. TYPES OF RECORDS TO RETAIN
FEMA requires that non-federal entities maintain the following documentation for federally funded
purchases:
.
.
.
.
.
.
.
.
Specifications;
Solicitations;
Competitive quotes or proposals;
Basis for selection decisions;
Purchase orders;
Contracts;
Invoices; and
Canceled checks.
Non-federal entities should keep detailed records of all transactions involving the grant. FEMA may
at any time request copies of any relevant documentation and records, including purchasing
documentation along with copies of canceled checks for verification. See, e.g., 2 C.F.R. § 200.318(i),
§ 200.334, § 200.337.
For any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g). Non-
federal entities who fail to fully document all purchases may find their expenditures questioned and
subsequently disallowed.
6.9.Actions to Address Noncompliance
Non-federal entities receiving financial assistance from FEMA are required to comply with
requirements in the terms and conditions of their awards or subawards, including the terms set forth
in applicable federal statutes, regulations, NOFOs, policies, and this manual. Throughout the award
lifecycle or even after an award has been closed, FEMA or the pass-through entity may discover
potential or actual noncompliance on the part of a recipient or subrecipient. This potential or actual
noncompliance may be discovered through routine monitoring, audits, closeout, or reporting from
various sources.
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In the case of any potential or actual noncompliance, FEMA may place special conditions on an
award per 2 C.F.R. § 200.208 and § 200.339, FEMA may place a hold on funds until the matter is
corrected, or additional information is provided per 2 C.F.R. § 200.339, or it may do both. Similar
remedies for noncompliance with certain federal civil rights laws are authorized pursuant to 44 C.F.R
Parts 7 and 19.
In the event the noncompliance is not able to be corrected by imposing additional conditions or the
recipient or subrecipient refuses to correct the matter, FEMA might take other remedies allowed
under 2 C.F.R. § 200.339. These remedies include actions to disallow costs, recover funds, wholly or
partially suspend, or terminate the award, initiate suspension and debarment proceedings, withhold
further federal awards, or take other remedies that may be legally available. For further information
on termination due to noncompliance, see the section on Termination Provisions in the relevant
NOFO.
FEMA may discover and take action on noncompliance even after an award has been closed. The
closeout of an award does not affect FEMA’s right to disallow costs and recover funds if the action to
disallow costs takes place during the record retention period. See 2 C.F.R. § 200.334, § 200.345(a).
Closeout also does not affect the obligation of the non-federal entity to return any funds due as a
result of later refunds, corrections, or other transactions. See 2 C.F.R. § 200.345(a)(2).
The types of funds FEMA might attempt to recover include, but are not limited to, improper
payments, cost share reimbursements, program income, interest earned on advance payments, or
equipment disposition amounts.
FEMA may seek to recover disallowed costs through a Notice of Potential Debt Letter, a Remedy
Notification, or other letter. The document will describe the potential amount owed, the reason why
FEMA is recovering the funds, the recipient’s appeal rights, the requirement to retain records, how
the amount can be paid, and the consequences, including billing and collection, for not appealing or
paying the amount by the deadline.
If the recipient neither appeals nor pays the amount by the deadline, the amount owed will become
final. Potential consequences if the debt is not paid in full or otherwise resolved by the deadline
include the assessment of interest, administrative fees, and penalty charges; administratively
offsetting the debt against other payable federal funds; and transferring the debt to the U.S.
Department of the Treasury for collection. FEMA notes the following common areas of
noncompliance for the preparedness grant programs:
.
.
.
.
.
Insufficient documentation and lack of record retention;
Failure to follow the procurement under grants requirements;
Failure to submit closeout documents in a timely manner;
Failure to follow EHP requirements; and
Failure to comply with the POP deadline.
6.10. Audits
FEMA grant recipients are subject to audit oversight from multiple entities including DHS OIG, the
Government Accountability Office (GAO), the pass-through entity, or independent auditing firms for
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single audits, and may cover activities and costs incurred under the award. Auditing agencies such
as the DHS OIG, the GAO, and the pass-through entity (if applicable), and FEMA in its oversight
capacity, must have access to records pertaining to the FEMA award. Recipients and subrecipients
must retain award documents for at least three years from the date the final FFR is submitted, and
even longer in many cases subject to the requirements of 2 C.F.R. § 200.334. In the case of
administrative closeout, documents must be retained for at least three years from the date of
closeout, or longer subject to the requirements of 2 C.F.R. § 200.334. If documents are retained
longer than the required retention period, the DHS OIG, the GAO, and the pass-through entity, as well
as FEMA in its oversight capacity, have the right to access these records as well. See 2 C.F.R. §
200.334, § 200.337.
Additionally, non-federal entities must comply with the single audit requirements at 2 C.F.R. Part
200, Subpart F. Specifically, non-federal entities, other than for-profit subrecipients, that expend
$750,000 or more in federal awards during their fiscal year must have a single or program-specific
audit conducted for that year in accordance with Subpart F. 2 C.F.R. § 200.501. A single audit covers
all federal funds expended during a fiscal year, not just FEMA funds. The cost of audit services may
be allowable per 2 C.F.R. § 200.425, but non-federal entities must select auditors in accordance
with 2 C.F.R. § 200.509, including following the proper procurement procedures.
The objectives of single audits are to:
.Determine whether financial statements conform to generally accepted accounting principles
(GAAP);
.
.
Determine whether the schedule of expenditures of federal awards (SEFA) is presented fairly;
Understand, assess, and test the adequacy of internal controls for compliance with major
programs; and
.Determine whether the entity complied with applicable laws, regulations, and contracts or grants.
For single audits, the auditee is required to prepare financial statements reflecting its financial
position, a SEFA, and a summary of the status of prior audit findings and questioned costs. The
auditee also is required to follow up and take appropriate corrective actions on new and previously
issued but not yet addressed audit findings. The auditee must prepare a CAP to address the new
audit findings. See 2 C.F.R. § 200.508, § 200.510, § 200.511.
Non-federal entities must have an audit conducted, either single or program-specific, of their
financial statements and federal expenditures annually or biennially pursuant to 2 C.F.R. § 200.504.
Non-federal entities must also follow the information submission requirements of 2 C.F.R. §
200.512, including submitting the audit information to the Federal Audit Clearinghouse within the
earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the
audit period. The audit information to be submitted include the data collection form described at 2
C.F.R. § 200.512(b) and Appendix X to 2 C.F.R. Part 200 as well as the reporting package described
at 2 C.F.R. § 200.512(c).
The non-federal entity must retain one copy of the data collection form and one copy of the reporting
package for three years from the date of submission to the Federal Audit Clearinghouse. 2 C.F.R. §
200.512(f); see also 2 C.F.R. § 200.517 (setting requirements for retention of documents by the
auditor and access to audit records in the auditor’s possession).
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FEMA, the DHS OIG, the GAO, and the pass-through entity (if applicable), as part of monitoring or as
part of an audit, may review a non-federal entity’s compliance with the single audit requirements. In
cases of continued inability or unwillingness to have an audit conducted in compliance with 2 C.F.R.
Part 200, Subpart F, FEMA and the pass-through entity, if applicable, are required to take
appropriate remedial action under 2 C.F.R. § 200.339 for noncompliance, pursuant to 2 C.F.R. §
200.505.
6.11. Reporting Issues of Fraud, Waste, and Abuse
Recipients, subrecipients, SAAs, and any other applicable stakeholder at any time may report issues
of fraud, waste, abuse, and mismanagement, or other criminal or noncriminal misconduct to the
Office of Inspector General (OIG) Hotline. The toll-free numbers to call are 1 (800) 323-8603, and
TTY 1 (844) 889-4357.
6.12. Payment Information
Payment requests are submitted through FEMA GO for awards obligated in FY 2024 and going
forward. For awards obligated prior to FY 2024 in the ND Grants System, the payment request is
submitted through PARS.
6.13. Whole Community Preparedness
Preparedness is a shared responsibility that calls for the involvement of everyone—not just the
government—in preparedness efforts. By working together, everyone can help keep the nation safe
from harm and help keep it resilient when struck by hazards, such as natural disasters, acts of
terrorism, and pandemics. Whole Community includes, but is not limited to:
.Individuals and families, including those with disabilities and others with access and functional
needs;
.
.
.
.
.
.
Businesses;
Faith-based and community organizations;
Nonprofit groups;
Schools and academia;
Media outlets; and
All levels of government, including SLTT and federal partners.
The phrase “Whole Community” often appears in preparedness materials, as it is one of the guiding
principles. It means two things:
.
.
Involving people in the development of national preparedness documents; and
Ensuring their roles and responsibilities are reflected in the content of the materials.
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By engaging Whole Community stakeholders, preparedness grant recipients can help FEMA develop
and promote a suite of well-targeted solutions for individuals and communities to adopt. Recipients
should coordinate preparedness initiatives with FEMA and whole community partners to efficiently
apply federal funding to reach the goal of individual and community resilience.
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7. Resources
7.1.Department of Homeland Security/FEMA Provided Training and
Education
FEMA offers tuition-free training and education programs and courses through several providers
including the Center for Domestic Preparedness (CDP), the Emergency Management Institute (EMI),
and NTED’s Training Partner Program (TPP). TPP includes the Center for Homeland Defense and
Security, National Domestic Preparedness Consortium, Rural Domestic Preparedness Consortium,
and training partners through the Continuing Training Grants (CTG) program.
7.2.Training Not Provided by the Department of Homeland Security/FEMA
Trainings not provided by DHS/FEMA include courses that are either state-sponsored or federal-
sponsored (non-DHS/FEMA), coordinated and approved by the State Administrative Agency (SAA) or
their designated Training Point of Contact (TPOC), and fall within the FEMA mission scope to prepare
SLTT personnel to prevent, protect against, mitigate, and respond to acts of terrorism or catastrophic
events. These trainings often pertain to the HSGP and THSGP.
.State Sponsored Courses. These courses are developed for and/or delivered by institutions or
organizations other than federal entities or FEMA and are sponsored by the SAA or their
designated TPOC.
.Joint Training and Exercises with the Public and Private Sectors. These courses are sponsored
and coordinated by private sector entities to enhance public-private partnerships for training
personnel to prevent, protect against, mitigate, and respond to acts of terrorism or catastrophic
events. In addition, states, territories, tribes, and high-risk urban areas are encouraged to
incorporate the private sector in government-sponsored training and exercises.
Additional information on both FEMA provided training and other federal and state training can be
found at firstrespondertraining.gov.
7.3.Training Information Reporting System (“Web-Forms”)
Web-Forms is an electronic data management system built to assist recipients and federal agencies
with submitting non-NTED provided training courses for inclusion in the State/Federal-Sponsored
Course Catalog through electronic forms. The information collected is used in a two-step review
process to ensure the training programs adhere to the intent of the guidance and the course content
is structurally sound and current. As these programs may be delivered nationwide, it is vital to ensure
each training program’s viability and relevance to the Homeland Security mission. Reporting training
activities through Web-Forms is not required under present funding. However, the system remains
available and can be accessed through the Web-Forms section of the FEMA National Preparedness
Course Catalog to support recipients in their own tracking of training deliveries. Users need to
request First Responder Training System (FRTS) Admin rights from NTED to access the Web-Forms.
7.4.FEMA’s National Preparedness Course Catalog
Recipients are also encouraged to utilize FEMA’s National Preparedness Course Catalog. Trainings
include programs or courses developed for and delivered by institutions and organizations funded by
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FEMA. This includes CDP, EMI, and TPP, CTG, the National Domestic Preparedness Consortium (NDPC),
the Rural Domestic Preparedness Consortium (RDPC), and other partners.
The catalog features a wide range of course topics in multiple delivery modes to meet FEMA’s mission
scope as well as the increasing training needs of federal and SLTT audiences. The catalog can be
accessed at the NTED National Preparedness Course Catalog page on firstrespondertraining.gov.
Some exercise and training activities require EHP Review, including those that require any type of land,
water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP
review can be found online at the Environmental & Historic Preservation Guidance for FEMA Grant
Applications page on FEMA.gov.
7.5.Exercises
Exercises conducted with grant funding should be managed and conducted consistent with
Homeland Security Exercise and Evaluation Program (HSEEP). HSEEP guidance for exercise design,
development, conduct, evaluation, and improvement planning is located at the HSEEP page on
FEMA.gov.
7.6.Planning Assistance
FEMA’s NPD offers TA that is designed to provide recipients and subrecipients with specialized
expertise to improve and enhance the continuing development of state and local emergency
management across the five mission areas of the Goal and across all core capabilities. TA provides
the opportunity to engage emergency managers, emergency planners, and appropriate decision-
makers in open discussion of options to improve plans and planning considering their jurisdiction’s
needs. Although there is no direct cost to approved jurisdictions for FEMA TA, jurisdictions are
expected to invest staff resources and take ownership of the resulting products and tools.
TA deliveries combine current emergency management best practices with practical consideration of
emerging trends, through discussion facilitated by FEMA contract specialists and with the support of
FEMA Region operational specialists. Additionally, peer-to-peer representation may also be included
from other jurisdictions that have recently addressed the same planning issue. The TA request form
can be accessed at the NIMS Implementation and Training page on FEMA.gov
7.7.Training Information
States, territories, tribal entities, and high-risk urban areas do not need to request approval from
FEMA for personnel to attend non-DHS/FEMA training if the training is coordinated with and
approved by the state, territory, tribal, or high-risk urban area TPOC and falls within the FEMA
mission scope and the jurisdiction’s Emergency Operations Plan (EOP). For additional information on
review and approval requirements for training courses funded with preparedness grants, see FEMA
Policy #207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards.
FEMA will conduct periodic reviews of all SLTT entities, and high-risk urban area training funded by
FEMA. These reviews may include requests for all course materials and physical observation of, or
participation in, the funded training. If these reviews determine that courses are outside the scope of
this guidance, recipients will be asked to repay grant funds expended in support of those efforts. For
further information on developing courses using the Analysis, Design, Development, Implementation,
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and Evaluation (ADDIE) model and tools that can facilitate the process, SAAs and TPOCs are
encouraged to review the NTED Training Resource and Development Center.
7.8.Weblinks
.U.S. Department of Transportation (DOT) “RAISE” grants for National Infrastructure Investments
may include funding to support roads, bridges, transit, rail, ports, or intermodal transportation.
See the RAISE Discretionary Grants page on Transportation.gov for more information.
.Cybersecurity Assessment Evaluation and Standardization, Cyber Resilience Review, Cyber
Infrastructure Survey, and other resources are available via CISA. See the Cyber Resource Hub
for additional information.
7.9.Emergency Management Accreditation Program
States can encourage their local jurisdictions to pursue assessment and accreditation under the
Emergency Management Accreditation Program (EMAP). EMAP’s assessment and accreditation of
emergency management organizations against consensus-based, American National Standards
Institute (ANSI)-certified standards allows for standardized benchmarking of critical functions
necessary for an emergency management organization to meet the core capabilities identified in the
Goal. Additional information on the EMAP Standard is available on the EMAP website.
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8. Homeland Security Grant Program and Tribal
Homeland Security Grant Program
8.1.Alignment to the National Preparedness System (Homeland Security
Grant Program, Tribal Homeland Security Grant Program)
The Nation uses the National Preparedness System to build, sustain, and deliver core capabilities to
achieve the Goal. HSGP and THSGP recipients use the National Preparedness System to support their
efforts to build, sustain, and deliver these core capabilities, which are essential for each of the five
mission areas outlined in the Goal. The components of the National Preparedness System are
Identifying and Assessing Risk, Estimating Capability Requirements, Building and Sustaining
Capabilities, Planning to Deliver Capabilities, Validating Capabilities, and Reviewing and Updating.
Additional information on the National Preparedness System is available at the National
Preparedness System page on FEMA.gov.
As the National Preparedness System matures, we are getting better data on our capabilities as a
Nation that can be used to drive our focus and our resources at all levels. States, tribes, and
territories provide annual data on their proficiency across 32 core capabilities through the THIRA,
Stakeholder Preparedness Review (SPR), exercise and real world After-Action Reports (AAR), and
other preparedness data. These data feed into the National Preparedness Report and form a shared
national picture of needs relative to capability gaps, including what threats and hazards are posing
the greatest risks and what core capabilities are most in need of improvement or sustainment.
Communities and federal agencies alike use these data to prioritize, synchronize, and guide
programs and activities to build and sustain capabilities. FEMA requires recipients to prioritize grant
funding to demonstrate how investments support identified national priorities (for HSGP only) and
building capability, closing capability gaps, or sustaining capabilities as defined by Comprehensive
Preparedness Guide (CPG) 201: THIRA/SPR Guide, Third Edition. Analytic results help shape
prioritization decisions at FEMA and across the nation to make sure we are focusing our time and
our resources in the right areas.
The HSGP and THSGP provide financial support to SLTT jurisdictions to help them build, sustain, and
deliver core capabilities identified in the Goal. Key focus areas and requirements of both the HSGP
and THSGP are to prevent terrorism and other catastrophic events and to prepare the Nation for the
threats and hazards that pose the greatest risk to the security of the United States and Tribal
Nations, including risks along the nation’s borders. When applicable, funding should support
deployable assets that can be used anywhere in the nation through automatic assistance and
mutual aid agreements, including, but not limited to, the EMAC.
The HSGP and THSGP support investments that improve the ability of jurisdictions nationwide to:
.
.
Prevent a threatened or an actual act of terrorism;
Protect citizens, residents, visitors, and assets against the threats that pose the greatest risk to
the security of the United States;
.
.
Mitigate the loss of life and property by lessening the impact of future catastrophic events;
and/or
Respond quickly to save lives, protect property and the environment, and meet basic human
needs in the aftermath of a catastrophic incident.
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8.2.Reporting on the Implementation of the National Preparedness
System (Homeland Security Grant Program, Tribal Homeland Security
Grant Program)
8.2.1. IDENTIFYING AND ASSESSING RISK AND ESTIMATING CAPABILITY
REQUIREMENTS
HSGP: By Dec. 31 each year, states, territories, and high-risk urban area HSGP recipients are
required to complete an SPR that addresses all 32 core capabilities and is compliant with CPG 201,
Third Edition. Additionally, every three years recipients are required to complete a THIRA. In 2020,
jurisdictions began the requirement to respond to a series of planning-related questions as part of
the THIRA/SPR.
THSGP: THSGP recipients are required to complete a THIRA every three years. Tribes with open
THSGP awards must update their SPR inputs and Secondary Assessments (described in Section
8.2.4 “Planning to Deliver Capabilities” and Section 8.2.3 "National Incident Management System
Implementation”) for activities completed in each respective calendar year (CY) throughout the POP,
starting the CY after funding is awarded.
New THSGP recipients are required to complete the THIRA, SPR, and Secondary Assessments by
Dec. 31 of the year following award issuance. New THSGP recipients are recipients that have not
received THSGP funding in the past three years. The THIRA/SPR must address all 32 core
capabilities and be compliant with the CPG 201, Third Edition. When applying for THSGP funding,
tribes that were awarded THSGP funding during the previous two years are expected to prioritize and
align grant funding investments in building and sustaining capabilities as identified in their THIRA
and SPR.
For additional guidance on the THIRA/SPR, please refer to CPG 201, Third Edition.
Reporting
.States, tribes (with the exception of new THSGP recipients as noted above), and territories will
submit their THIRA and SPR through the URT on the Preparedness Toolkit no later than Dec. 31
of the applicable year (every three years for THIRA and each year for SPR) for which the recipient
has an open award.
o If a THSGP recipient has completed closeout for their THSGP grant award POP, they do not
have to submit the THIRA/SPR as the requirement does not apply to closed awards.
.
.
High-risk urban areas that receive UASI funding will submit their SPR through the URT on
Preparedness Toolkit no later than Dec. 31 for the years they have UASI open grants. If a UASI
recipient has completed closeout for their UASI grant award POP, they do not have to submit a
THIRA/SPR as the requirement is not applicable to closed grant awards. While UASIs that have
completed closeout for the award POP are not required to complete a THIRA/SPR, it is
encouraged.
Calendar year 2022 was the start of the new 3-year THIRA/SPR cycle and baseline assessment
year for existing recipients. Any new grant recipients for which the THIRA/SPR requirement
applies will start their new 3-year THIRA/SPR cycle and baseline assessment year in the year
during which they apply. States, territories, and high-risk urban areas should work collaboratively
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to create the most accurate THIRA and SPR possible. States, territories, and high-risk urban
areas may share scenarios, targets, and assessed capabilities when appropriate.
.Please contact FEMA-SPR@fema.dhs.gov if you have questions.
8.2.2. BUILDING AND SUSTAINING CAPABILITIES
States, territories, and high-risk urban areas must prioritize and align SHSP and UASI grant funding
investments in building and sustaining capabilities in areas that align with the national priorities in
the annual HSGP NOFO, and capability gaps identified in their THIRA and SPR. Tribes receiving
THSGP funds must prioritize and align grant funding investments in building and sustaining
capabilities as identified in their THIRA and SPR. When applying for THSGP funding, tribes that were
awarded THSGP funding during the previous two years are expected to prioritize and align grant
funding investments in building and sustaining capabilities as identified in their THIRA and SPR.
Reporting
Within the BSIR and as part of programmatic monitoring, recipients must describe how expenditures
support building capability, closing capability gaps, or sustaining capabilities identified in the THIRA
and SPR. Recipients must, on a project-by-project basis, check one of the following:
.
.
Building a capability with HSGP or THSGP funding; and
Sustaining a capability with HSGP or THSGP funding.
8.2.3. NATIONAL INCIDENT MANAGEMENT SYSTEM IMPLEMENTATION
Recipients receiving HSGP or THSGP funding are required to implement NIMS. HSGP and THSGP
recipients must use standardized resource management concepts for resource typing, credentialing,
and an inventory to facilitate the effective identification, dispatch, deployment, tracking, and
recovery of resources.
Reporting
.Recipients report in the applicable secondary NIMS assessment portion of the URT as part of
their THIRA/SPR submission, as outlined in the HSGP or THSGP NOFO.
8.2.4. PLANNING TO DELIVER CAPABILITIES
HSGP and THSGP recipients shall develop and maintain, jurisdiction-wide, all threats and hazards
EOPs consistent with CPG 101, Version 3.0 (CPG 101 v3), Developing and Maintaining Emergency
Operations Plans (September 2021). For HSGP, recipients must update their EOPs at least once
every two years. For THSGP, recipients must submit an EOP once during the POP.
Reporting
.Recipients report EOP compliance with CPG 101 v3 by completing the secondary CPG 101 v3
assessment portion of the URT as part of their THIRA/SPR submission.
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8.2.5. VALIDATING CAPABILITIES
All HSGP and THSGP recipients will develop and maintain a progressive exercise program consistent
with HSEEP guidance in support of the National Exercise Program (NEP). THSGP recipients are
required to develop and maintain this program regardless of whether the tribe planned to use THSGP
funding for exercises. The NEP serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation
that validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by
Principals’ Strategic Priorities, established by the National Security Council, and informed by
preparedness data from jurisdictions across the Nation.
To develop and maintain a progressive exercise program consistent with HSEEP and in support of
the NEP, recipients should engage senior leaders and other whole community stakeholders to
identify preparedness priorities. These priorities should be informed by various factors, including
jurisdiction-specific threats and hazards (i.e., the THIRA); areas for improvement identified by real-
world events and exercises; external requirements such as state or national preparedness reports,
homeland security policy, and industry reports; and accreditation standards, regulations, or
legislative requirements. Recipients should document these priorities and use them to deploy a
schedule of preparedness events in a multi-year Integrated Preparedness Plan (IPP). Information
related to Integrated Preparedness Planning Workshops (IPPWs) can be found on the HSEEP page
on FEMA.gov and the Preparedness Toolkit.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery
assistance, tools and resources, enhanced coordination, and the ability to directly influence and
inform policy and preparedness programs. If you have any questions, or would like to request
assistance through the NEP, please visit the NEP website on the Exercises page on FEMA.gov, or
reach out to the NEP directly at NEP@fema.dhs.gov.
Reporting
.Recipients must have a current multi-year IPP that identifies preparedness priorities and
activities. The current multi-year IPP must be submitted to hseep@fema.dhs.gov before Jan. 31
of each year:
o Recipients are encouraged to enter their exercise information into the Preparedness Toolkit.
.
.
Recipients must submit AARs/Improvement Plans (IPs) to hseep@fema.dhs.gov and indicate
which fiscal year’s funds were used (if applicable).
Submission of AAR/IPs must take place within 90 days following completion of the single
exercise or progressive series:
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took place
at the state, territorial, tribal, or urban area level. Recipients are discouraged from submitting
AAR/IPs specific to local jurisdictions that reflect drills;
o If a recipient endures a significant real-world incident during the CY that delays or prevents
conduct of a grant-funded exercise, they can submit the AAR from that event in place of the
exercise AARs. Jurisdictions submitting real world AARs should include an explanation with
the AAR submission to hseep@fema.dhs.gov; and
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o Recipients can access a sample AAR/IP template on the Improving Planning Templates page
on the Preparedness Toolkit.
8.3.Funding Guidelines (Homeland Security Grant Program, Tribal
Homeland Security Grant Program)
Recipients must comply with all the requirements in 2 C.F.R. Part 200 (Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards). In general, recipients
should consult with their FEMA HQ Preparedness Officer prior to making any investment that does not
clearly meet the allowable expense criteria. Funding guidelines support four of the five mission
areas—Prevention, Protection, Mitigation, and Response—and associated core capabilities within the
Goal. While Recovery is part of the Goal, it is not explicitly part of the HSGP and THSGP. Allowable
investments made in support of the national priorities, as well as other capability-enhancing projects
must have a nexus to terrorism preparedness and fall into the categories of planning, organization,
exercises, training, or equipment, aligned to building capability, closing capability gaps, and/or
sustaining capabilities, as defined by CPG 201, Third Edition. Recipients are encouraged to use grant
funds for evaluating grant-funded project effectiveness and return on investment. FEMA encourages
recipients to provide the results of that analysis to FEMA.
8.4.Allowable Costs (Homeland Security Grant Program)
8.4.1. MULTIPLE PURPOSE OR DUAL-USE OF FUNDS (STATE HOMELAND SECURITY
PROGRAM AND URBAN AREA SECURITY INITIATIVE)
For both SHSP and UASI, many activities that support the achievement of core capabilities related to
the national priorities and terrorism preparedness may simultaneously support enhanced
preparedness for other hazards unrelated to acts of terrorism. However, all SHSP- and UASI-funded
projects must assist recipients and subrecipients in achieving core capabilities related to preventing,
preparing for, protecting against, or responding to acts of terrorism per section 2008(c) of the HSA (6
U.S.C. § 609(c)).
8.4.2. ORGANIZATIONAL ACTIVITIES
Personnel Costs
In addition to the personnel cost allowability detailed in the HSGP NOFO, HSGP (SHSP, UASI) funds
may not be used to support the hiring of any personnel to fulfill traditional public health and safety
duties nor to supplant traditional public health and safety positions and responsibilities. HSGP
(SHSP, UASI, OPSG) funds will be used to supplement existing funds and will NOT replace (supplant)
funds that have been appropriated and/or budgeted for the same purpose. Applicants or recipients
may be required to supply documentation certifying that a reduction in non-federal resources
occurred for reasons other than the receipt or expected receipt of federal funds.
8.4.3. 28 C.F.R. PART 23 GUIDANCE
FEMA requires that any IT system funded or supported by HSGP funds comply with 28 C.F.R. Part 23,
Criminal Intelligence Systems Operating Policies if this regulation is determined to be applicable.
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8.5.Fusion Centers (Homeland Security Grant Program)
A critical component of the national response to the 9/11 terrorist attacks was the development of a
national-level, decentralized, and coordinated terrorism-related information sharing environment
(ISE). State and local governments, supported by federal investments from DHS, the Department of
Justice (DOJ), Department of Health and Human Services (HHS), and other federal agencies of the
national ISE. This National Network, comprised of 80 state and major urban area fusion centers,
collaborates and shares information with partners from all levels of government and the private
sector, as well as other field-based information sharing partners, including High-Intensity Drug
Trafficking Areas (HIDTA), Regional Information Sharing Systems (RISS) Centers, Joint Terrorism Task
Forces (JTTF), major city/county intelligence units, and real-time crime analysis centers, among
others.
National Network participation in the Nationwide Suspicious Activity Reporting Initiative (NSI) enables
fusion centers to identify, receive and analyze Suspicious Activity Reports (SAR) and other tips/leads
from frontline public safety personnel, the private sector, and the public, and ensure the sharing of
SARs with DHS and the FBI’s JTTFs for further investigation. In addition to those activities identified
in the National Prevention Framework, fusion centers are also required to collaborate with those
intelligence, operational, analytic, investigative, and information-sharing focused entities to combat a
wide array of threats—noted below—in support of efforts to enhance capabilities for detecting,
deterring, disrupting, and preventing acts of terrorism, targeted violence, and other threats. Such
entities include, but are not limited to JTTFs, Area Maritime Security Committees (AMSC), Border
Enforcement Security Task Forces, Integrated Border Enforcement Teams, HIDTAs, and RISS Centers
as well as other federal intelligence, operational, analytic, and investigative entities. Applicants
should describe their collaboration plan and proposed efforts in their required Fusion Center project
as part of the Intelligence and Information Sharing National Priority.
Today’s threats—including international and domestic terrorism, drugs, gangs, active shooters,
targeted violence, transnational organized crime, and cyber—require federal, state, and local
governments to leverage this national capacity to effectively respond to the evolving nature of the
various national and homeland security threats confronting our Nation. Ultimately, timely
identification and analysis of key indicators from local, state, and federal partners will enable all
stakeholders to address threats and develop and implement data-driven strategies to prevent,
protect against, mitigate, and respond effectively, while ensuring the protection of privacy, civil
rights, and civil liberties.
To underscore the importance of the National Network as a critical component of our Nation’s
distributed homeland security and counterterrorism architecture, FEMA preparedness grants will
continue to prioritize support for designated fusion centers and the maturation of the ISE. Fusion
centers must prioritize the following capabilities to further enable and mature this national asset and
strengthen the collective capacity to identify, collect, analyze, and share information, and to
disseminate actionable and strategic intelligence to key stakeholders:
.Addressing Threats: Fusion centers provide a national level, decentralized, and coordinated ISE
across all levels of government and disciplines that can be leveraged and applied to address
threats to homeland security, national security, public safety, and/or public health, and
especially those threats that may have little or no warning. Fusion centers should leverage and
build upon their terrorism-focused analytic and information-sharing capabilities so they can be
applied to address threats across the DHS mission space, including threats from both
international terrorism and domestic violent extremists, threats to life and targeted violence,
transnational organized criminal activity, cyber threats, and natural hazards, among others that
require close collaboration with DHS operational, investigative, and analytic entities such as CBP,
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ICE, United States Secret Service (USSS), CISA, the United States Coast Guard (USCG), and
FEMA.
.Analytic Capability: Fusion centers must maintain strong analytic capabilities at tactical,
operational, and strategic levels to address a wide array of threats or hazards that could have
implications for homeland security or national security. These capabilities directly support
operational, investigative, and information sharing efforts across all levels of government. These
capabilities include, but are not limited to:
o
o
o
Building and sustaining a capable workforce of analysts who have the necessary experience
and training; access to open source, unclassified and classified information, products, data,
SAR; tips/leads and online/social media-based threats; as well as necessary services and
technology to facilitate analytic capabilities and collaboration;
Assessing, evaluating, and deconflicting acts of targeted violence, threats to life, and other
criminal or suspicious activity, to include potential indicators and behaviors, for potential
connection to or implications for international or domestic terrorism, or other threats within
the DHS mission space;
Providing analytic support and responses to requests for information from federal, state, and
local partners during no notice threats, attacks, or incidents, as well as other planned events
such as National Security Special Events (NSSEs);
o
o
o
o
o
Conducting threat assessments within their respective jurisdictions, including the
identification of threats, intelligence gaps, and mitigation efforts;
Establishing, formalizing, and maintaining bi-directional information sharing with federal and
other state agencies in accordance with jurisdictional authorities;
Leveraging available resources and capabilities to conduct target and event deconfliction in
support of threat identification, officer safety, and information sharing.
Maintaining an ability to routinely support federal government efforts to watchlist terrorists
and transnational organized crime actors; and
Appropriately planning for, and assessing/forecasting, prioritizing, and executing against
both known and emerging threat vectors, and ensuring the safety and security of all
operations, while protecting privacy, civil rights, and civil liberties.
Fusion centers should also consider their operational capacity when aligning manpower and
resources in support of this capability (e.g., the ability to maintain watch and analytic support
functions over a 24/7 operational tempo).
.Technological Integration: Access to data, information, and products is essential for fusion
centers and the federal government to effectively identify, collect, analyze, and share
information. Just as threats do not stop at jurisdictional borders, fusion centers must be able to
effectively access and share appropriate information and data across jurisdictions, agencies,
and disciplines. Fusion centers must ensure and certify via the Fusion Center Assessment they
have the necessary technological capacity to access, analyze, and share information, including
criminal intelligence and online/social media threat information, both within their jurisdictions,
as well as with other fusion centers across the country and with the Federal Government through
a variety of systems, databases, tools, and technologies that allow for federated searching and
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data/information analysis that protects Personally Identifiable Information and includes
appropriate security, privacy, civil rights, and civil liberties protections. This includes
maintenance of the ability to collect, integrate, evaluate, and assess SAR, tips/leads, data
resident in Computer Assisted/Aided Dispatch (CAD) and Records Management System (RMS),
and online/social media-based threats from agencies across the jurisdiction. Such approaches
should also address the evaluation and use of emerging capabilities, including social network
analysis, federated search technology across CAD, RMS, and other data systems, complex data
indexing, social media, open source, facial recognition, unmanned aircraft systems, geographic
information systems (GIS), license plate reader technologies, and other artificial intelligence
technologies.
.Interagency Collaboration: Fusion centers must maintain strong partnerships to enable
intelligence, operational, investigative, and analytic collaboration and deconfliction of threat
information with other partners located within their jurisdiction and across their region, including
HIDTAs, RISS Centers, DHS intelligence, operational, investigative, and analytic entities, FBI Field
Offices, JTTFs, and major city/county intelligence units.
State and urban area fusion centers receiving SHSP or UASI grant funds will be evaluated based on
compliance with the guidance and requirements for the National Network as set forth by DHS
Intelligence and Analysis (I&A) through the annual Fusion Center Assessment.
.Additional fusion center grant requirements, including 28 C.F.R. Part 23 requirements, are listed
at the Fusion Center Performance Program’s HSGP page on DHS.gov and in the 28 C.F.R. Part
23 Online Training.
.FEMA approved analyst courses that meet the grant requirement are listed at FEMA Approved
Intelligence Analyst Training Courses page on DHS.gov.
Through the PPR, fusion centers will report on the compliance with measurement requirements
within the fusion centers through the annual Fusion Center Assessment managed by DHS I&A and
reported to FEMA. In addition to the activities identified in the National Prevention Framework, fusion
centers are also required to collaborate with those analytic, investigative, and information-sharing
entities focused on preventing, detecting, deterring, and disrupting acts of terrorism and combating
transnational criminal organizations. Such entities include, but are not limited to JTTFs, AMSC,
Border Enforcement Security Task Forces, Integrated Border Enforcement Teams, HIDTAs, and RISS
Centers, as well as other federal intelligence, operational, analytic, and investigative entities.
Applicants will be required to provide information regarding their information sharing partnerships,
including how they will identify, address, and overcome any existing laws, policies, and practices that
prevent information sharing, via the Information and Intelligence National Priority Investment and
supporting data via the annual Fusion Center Assessment.
8.5.1. FUSION CENTER PERFORMANCE MEASURES
Table 7: Fusion Center Performance Measures
Reference Performance Measures
Number*
Percentage of federal Information Intelligence Reports (IIRs) originating from fusion
center information that address a specific Intelligence Community needYEAR.1
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Reference Performance Measures
Number*
Percentage of federal IIRs originating from fusion center information that the
Intelligence Community otherwise used in performing its mission (e.g., contained
first-time reporting; corroborated existing information; addressed a critical
intelligence gap; or helped to define an issue or target)
YEAR.2
Number of SARs vetted and submitted by fusion centers that result in the initiation
or enhancement of an investigation by the FBIYEAR.3
YEAR.4
YEAR.5
YEAR.6
YEAR.7
YEAR.8
YEAR.9
Number of SAR vetted and submitted by fusion centers that involve an individual on
the Watchlist
Percentage of Requests for Information (RFIs) from the Terrorist Screening Center
(TSC) for which fusion centers provided information for a TSC case file
Percentage of I&A Watchlist nominations that were initiated or updated existing case
files based on information provided by fusion centers
Number of distributable analytic products co-authored by one or more fusion centers
and/or federal agencies
Percentage of fusion center distributable analytic products that address Homeland
Security topics
Percentage of fusion center distributable analytic products that address state/local
customer information needs
YEAR.10
YEAR.11
Percentage of key customers reporting that fusion center products are relevant
Percentage of key customers reporting that fusion center services are relevant
Percentage of key customers reporting that fusion center products are timely for
mission needsYEAR.12
YEAR.13
YEAR.14
YEAR.15
YEAR.16
YEAR.17
Percentage of key customers reporting that fusion center services are timely for
mission needs
Percentage of key customers reporting that fusion center products influenced their
decision making related to threat response activities within their AOR
Percentage of key customers reporting that fusion center services influenced their
decision making related to threat response activities within their AOR
Percentage of key customers reporting that fusion center products resulted in
increased situational awareness of threats within their AOR
Percentage of key customers reporting that fusion center services resulted in
increased situational awareness of threats within their AOR
YEAR.18
YEAR.19
Number of tips and leads vetted by the fusion center
Number of tips and leads vetted by the fusion center that were provided to other
F/SLTT agencies for follow up action
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Reference Performance Measures
Number*
YEAR.20
YEAR.21
Number of responses to RFIs from all sources
Number of situational awareness products developed and disseminated by fusion
centers
Number of case support and/or tactical products developed and disseminated by
fusion centers
Percentage of federally designated special events in which fusion centers played a
direct role
YEAR.22
YEAR.23
Percentage of federally declared disasters in which fusion centers played a direct
role
Number of public safety incidents in which fusion centers played a direct role
YEAR.24
YEAR.25
*“YEAR” should be changed for the current fiscal year, e.g., 2024, 2025, etc. Any updates to Performance
Measures will be noted in the HSGP NOFO.
8.6.Investment Modifications – Changes in Scope or Objective (Tribal
Homeland Security Grant Program)
Changes in scope or objective of the award—including those resulting from intended actions by the
recipient or subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §
200.308(c)(1), § 200.407. THSGP is competitive with applications recommended for funding based
on threat, vulnerability, and consequence, and their mitigation of potential terrorist attacks.
However, consistent with 2 C.F.R § 200.308(c)(1), Change in Scope Prior Approval, FEMA requires
prior approval of any change in scope or objective of the grant-funded activity after the award is
issued. See 2 C.F.R. § 200.308(b), (c). Scope or objective changes will be considered on a case-by-
case basis provided the change does not negatively impact the competitive process used to
recommend THSGP awards.
Requests to change the scope or objective of the grant-funded activity after the award is made must
be submitted via FEMA GO as a Scope Change Amendment. The amendment request must include
the following:
.A written request on the recipient’s letterhead outlining the scope or objective change including
the approved projects from the IJ, the funds and relative scope or objective significance allocated
to those projects, the proposed changes, and any resulting reallocations as a result of the
change of scope or objective;
.
.
An explanation why the change of scope or objective is necessary;
How the proposed scope or objective changes to the project support the vulnerabilities and
capability gaps identified in the approved IJ; and
.The request must also address whether the proposed changes will impact the recipient’s ability
to complete the project within the award’s POP.
Recipients may not proceed with implementing any scope or objective changes until they receive
prior written approval from FEMA through FEMA GO.
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8.7.Continuity Capability (Homeland Security Grant Program, Tribal
Homeland Security Grant Program)
Continuity should be integrated into each core capability and the coordinating structures that provide
them. Continuity capabilities increase resilience and the probability that organizations can perform
essential functions in the delivery of core capabilities that support the mission areas. FEMA is
responsible for coordinating the implementation and development, execution, and assessment of
continuity capabilities among executive departments and agencies. To support this role, FEMA
develops and promulgates directives, policy, and guidance for federal and SLTT governments, non-
governmental organizations, and private sector critical infrastructure owners and operators. Federal
Continuity Directives (FCD) establish continuity program and planning requirements for executive
departments and agencies, while FEMA's Continuity Guidance Circular (CGC) tailors’ continuity
guidance to SLTT and other non-Federal audiences. This direction and guidance assist in developing
capabilities for continuing the essential functions of federal and SLTT governmental entities, as well
as public/private critical infrastructure owners, operators, and regulators enabling them.
The FCDs, CGC, and the Continuity Resource Toolkit provide guidance and resources for
organizations. For additional information on continuity programs, guidance, and directives, see the
Continuity Resources and Technical Assistance page on FEMA.gov.
8.8.Senior Advisory Committee (Homeland Security Grant Program)
To support the Whole Community Approach (see Section 1.6 “Strengthening Governance Integration”
and Section 6.13 “Whole Community Preparedness”), the SAA must establish or reestablish a unified
Senior Advisory Committee (SAC). The SAC builds upon previously established advisory bodies under
SHSP, UASI, TSGP, and PSGP. Examples of advisory bodies that should be included on a SAC include
Urban Area Working Groups (UAWGs), SIGB, AMSCs, Regional Transportation Security Working
Groups (RTSWG), Citizen Corps Whole Community Councils, Disability Inclusion Working Groups, and
Children’s Working Groups. The membership of the SAC must reflect a state’s unique risk profile and
the interests of the five mission areas as outlined in the Goal. Further, the SAC must include
representatives that were involved in the production of the state’s THIRA and SPR.
8.8.1. SENIOR ADVISORY COMMITTEE COMPOSITION AND SCOPE
SAC membership shall include at least one representative from relevant stakeholders including:
.Individuals from the counties, cities, towns, and Indian tribes within the state or high-risk urban
area including, as appropriate, representatives of rural, high-population, and high-threat
jurisdictions of UASI-funded high-risk urban areas;
.
.
Representatives that were involved in the production of the state’s THIRA and SPR;
State and urban area Chief Information Officers (CIOs) and Chief Information Security Officers
(CISOs);
.
.
.
SWIC and SIGB members;
Citizen Corps Whole Community Councils;
Local and tribal government officials;
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.
.
Tribal organizations and associations;
Emergency response providers, including representatives of the fire service, law enforcement,
emergency medical services, and emergency managers;
.
.
.
Public health officials and other appropriate medical practitioners;
Hospitals;
Individuals representing educational institutions, including elementary schools, middle schools,
junior high schools, high schools, community colleges, and other institutions of higher education;
.
.
.
State and regional interoperable communications coordinators, as appropriate;
State and major urban area fusion centers, as appropriate; and
Nonprofit, faith-based, and other voluntary organizations, such as the American Red Cross.
Additionally, program representatives from the following entities should be members of the SAC (as
applicable): State Primary Care Association, State Homeland Security Advisor (if this role is not also
the SAA), State Emergency Management Agency (EMA) Director, State Public Health Officer, State
Awardee for HHS’ Hospital Preparedness Program, State Public Safety Officer (and SAA for Justice
Assistance Grants, if different), State Coordinator for the DoD 1033 Program (also known as the Law
Enforcement Support Office [LESO] Program), State Court Official, State Emergency Medical Services
(EMS) Director, State Trauma System Manager, Statewide Interoperability Coordinator, State Citizen
Corps Whole Community Council, the State Emergency Medical Services for Children (EMSC)
Coordinator, State Education Department, State Human Services Department, State Child Welfare
Services, State Juvenile Justice Services, Urban Area Points of Contact (POC), Senior Members of
AMSCs, Senior Members of the RTSWG, Senior Security Officials from Major Transportation Systems,
and the Adjutant General.
SACs are encouraged to develop subcommittee structures, as necessary, to address the issue or
region-specific considerations. The SAC must include whole community intrastate and interstate
partners as applicable and have balanced representation among entities with operational
responsibilities for terrorism/disaster prevention, protection, mitigation, and response activities
within the state, and include representation from the stakeholder groups and disciplines identified
above.
The above membership requirement does not prohibit states, high-risk urban areas, regional transit
and port entities, or other recipients of FEMA preparedness funding from retaining their existing
structure under separate programs; however, at a minimum, those bodies must support and feed
into the larger SAC. The composition, structure, and charter of the SAC should reflect this focus on
building core capabilities, instead of simply joining previously existing advisory bodies under other
grant programs. For designated high-risk urban areas, the SAA POCs are responsible for identifying
and coordinating with the POC for the UAWG, which should be a member of the SAC. The POC’s
contact information must be provided to FEMA with the grant application. SAAs must work with
existing high-risk urban areas to ensure that information for current POCs is on file with FEMA.
Finally, FEMA recommends that organizations advocating on behalf of youth, older adults, individuals
with disabilities, individuals with limited English proficiency and others with other access and
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functional needs, socio-economic factors and cultural diversity be invited to participate in the SAC.
Applicants must submit the list of SAC members and the SAC charter at the time of application as an
attachment in FEMA GO. SAAs will use the URT to verify compliance with SAC charter requirements.
8.8.2. SENIOR ADVISORY COMMITTEE RESPONSIBILITIES
The responsibilities of a SAC include:
.
.
Integrating preparedness activities across disciplines, the private sector, nonprofit, faith-based,
and community organizations, and SLTT governments, with the goal of maximizing coordination
and reducing duplication of effort;
Creating a cohesive planning network that builds and implements preparedness initiatives using
FEMA resources as well as other federal, SLTT, private sector, and faith-based community
resources;
.
.
.
.
Managing all available preparedness funding sources to ensure their effective use and to
minimize duplication of effort;
Ensuring investments support building capability, closing capability gaps, or sustaining
capabilities identified in the THIRA/SPR;
Assisting in preparation and revision of the state, regional, or local homeland security plan or the
THIRA, as the case may be; and
Assisting in determining effective funding priorities for SHSP grants.
8.8.3. SENIOR ADVISORY COMMITTEE CHARTER
The governance of SHSP and UASI through the SAC should be directed by a charter. All members of
the SAC should sign and date the charter showing their agreement with its content and their
representation on the Committee. Revisions to the governing charter must be sent to the recipient’s
assigned FEMA HQ Preparedness Officer. The SAC charter must at a minimum address the following:
.A detailed description of the SAC’s composition and an explanation of key governance processes,
including how the SAC is informed by the states and urban area’s THIRA/SPR;
.
.
.
A description of the frequency at which the SAC will meet;
How the committee will leverage existing governance bodies;
A detailed description of how decisions on programmatic priorities funded by SHSP and UASI are
made and how those decisions will be documented and shared with its members and other
stakeholders, as appropriate; and
.A description of defined roles and responsibilities for financial decision making and meeting
administrative requirements.
To ensure ongoing coordination efforts, SAAs are encouraged to share community preparedness
information submitted in a state’s BSIR with members of the SAC. SAAs are also encouraged to
share their THIRA/SPR data with members of the SAC who are applying for other FEMA preparedness
grants to enhance their understanding of statewide capability gaps. The charter should be made
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available upon request to promote transparency in decision-making related to SHSP and UASI
activities.
To manage this effort and to further reinforce collaboration and coordination across the stakeholder
community, a portion of the 20% holdback of a state or territory award may be utilized by the SAA to
support the SAC and to ensure representation and active participation of SAC members. Funding
may be used for hiring and training planners, establishing and maintaining a program management
structure, identifying and managing projects, conducting research necessary to inform the planning
process, and developing plans that bridge mechanisms, documents, protocols, and procedures.
8.9.Urban Area Working Group (Homeland Security Grant Program)
To support the Whole Community Approach (see Section 1.6 “Strengthening Governance Integration”
and Section 6.13 “Whole Community Preparedness”), high-risk urban areas are required to establish
UAWGs representative of the counties, cities, towns, and tribes within the high-risk urban area
including, as appropriate, representatives of rural jurisdictions, high-population jurisdictions, and
high-threat jurisdictions.
UASI implementation and governance must include regional partners and should have balanced
representation among entities with operational responsibilities for prevention, protection, mitigation,
and response activities within the region. In some instances, high-risk urban area boundaries cross
state borders. States and territories must ensure that the identified high-risk urban areas take an
inclusive regional approach to the development and implementation of the UASI and involve the
contiguous jurisdictions, mutual aid partners, port authorities, rail and transit authorities, state
agencies, Statewide Interoperability Coordinators, Citizen Corps Whole Community Council(s), and
campus law enforcement in their program activities.
8.9.1. URBAN AREA WORKING GROUP COMPOSITION AND SCOPE
Pursuant to section 2003(b) of the HSA (codified as amended at 6 U.S.C. § 604(b)), eligible high-risk
urban areas were determined based on an analysis of relative risk of the 100 most populous
Metropolitan Statistical Areas (MSA), as defined by OMB. MSAs are used by FEMA to determine
eligibility for participation in the program. Geographical areas queried do not equate to minimum
mandated membership representation of an urban area, nor does this guarantee funding for
geographical areas queried. UAWGs are not required to expand or contract existing urban area
participation to conform to MSA composition. Detailed information on MSAs is publicly available from
the United States Census Bureau.
An SAA must confirm a specific POC with the designated high-risk urban area. The SAA POC is
responsible for identifying and coordinating with the POC for the UAWG. This information must be
provided to FEMA with the grant application. SAAs must work with existing high-risk urban areas to
ensure that information for current POCs is on file with FEMA.
Membership in the UAWG must provide either direct or indirect representation for all relevant
jurisdictions and response disciplines (including law enforcement, fire service, EMS, hospitals, public
health, and emergency management) that comprise the defined high-risk urban area. It must also be
inclusive of local Whole Community Citizen Corps Council and tribal representatives. The UAWG
should also include at least one representative from each of the following significant stakeholders:
.Local and tribal government officials;
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.
.
CIO and CISO;
Emergency response providers, which shall include representatives of the fire service, law
enforcement, emergency medical services, and emergency managers;
.
.
Public health officials and other appropriate medical practitioners, including Health Care
Coalitions (HCCs);
Individuals representing educational institutions, including elementary schools, middle schools,
junior high schools, high schools, community colleges, and other institutions of higher education;
and
.State and regional interoperable communications coordinators and state and major urban area
fusion centers, as appropriate.
In addition to representatives from the local jurisdictions and tribes within the state, territory, or high-
risk urban area, the UAWG should include officials responsible for the administration of Centers for
Disease Control and Prevention’s (CDC) and the HHS Assistant Secretary for Preparedness and
Response’s (ASPR) cooperative agreements. Finally, it must be inclusive of members advocating on
behalf of youth, older adults, individuals with disabilities, individuals with limited English proficiency,
and others with other access and functional needs, socio-economic factors, and cultural diversity.
High-risk urban areas will use the URT to verify UAWG structure and membership. The list of UAWG
members must also be submitted at the time of application as an attachment in FEMA GO. High-risk
urban areas must notify the SAA and the FEMA Headquarters Preparedness Officer of any updates to
the UAWG structure or membership after the application is submitted.
8.9.2. URBAN AREA WORKING GROUP RESPONSIBILITIES
UAWGs must ensure that applications for funding under the UASI support building capability, closing
capability gaps, or sustaining capabilities identified in the high-risk urban area’s THIRA/SPR. The
UAWG should support state efforts to develop the SPR particularly as it relates to UASI-funded
activities. The UAWG, in coordination with the SAA POC, must develop a methodology for allocating
funding available through the UASI. The UAWG must reach consensus on all UASI funding allocations.
If consensus cannot be reached within the 45-day period allotted for the state to obligate funds to
subrecipients, the SAA must make the allocation determination. The SAA must provide written
documentation verifying the consensus of the UAWG or the failure to achieve otherwise on the
allocation of funds and submit it to FEMA immediately after the 45-day period allotted for the state
to obligate funds to subrecipients. Any UASI funds retained by the state must be used in direct
support of the high-risk urban area. States must provide documentation to the UAWG, and FEMA
upon request, demonstrating how any UASI funds retained by a state are directly supporting the high-
risk urban area.
8.9.3. URBAN AREA WORKING GROUP CHARTER
In keeping with sound project management practices, the UAWG must ensure that its approach to
critical issues such as membership, governance structure, voting rights, grant M&A responsibilities,
and funding allocation methodologies are formalized in a working group charter, or another form of
standard operating procedure related to the UASI governance. The charter must also outline how
decisions made in UAWG meetings will be documented and shared with UAWG members. The UAWG
charter must be submitted at the time of application as an attachment in FEMA GO and must be on
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file with FEMA prior to drawing down UASI funding. It also must be available to all UAWG members to
promote transparency in decision making related to the UASI.
8.10. Supplemental State Homeland Security Program and Urban Area
Security Initiative Guidance (Homeland Security Grant Program)
8.10.1. COLLABORATION WITH OTHER FEDERAL PREPAREDNESS PROGRAMS
FEMA strongly encourages states, high-risk urban areas, tribes, and territories to understand other
federal preparedness programs in their jurisdictions and to work with them in a collaborative manner
to leverage all available resources and avoid duplicative activities. For example, HHS has two robust
preparedness programs—CDC’s Public Health Emergency Preparedness (PHEP) cooperative
agreement and ASPR’s Hospital Preparedness Program (HPP) cooperative agreement—that focus on
preparedness capabilities. CDC’s 15 public health preparedness capabilities and ASPR’s 4
healthcare preparedness capabilities serve as operational components for many of the core
capabilities, and collaboration with the PHEP directors and HPP coordinators can build capacity
around shared interests and investments that fall in the scope of these HHS cooperative agreements
and the HSGP.
States and high-risk urban areas should coordinate among the entire scope of federal partners,
national initiatives, and grant programs to identify opportunities to leverage resources when
implementing their preparedness programs. These may include but are not limited to: Medical
Reserve Corps; Emergency Medical Services for Children grants; ASPR HPP; CDC PHEP; CDC Cities
Readiness Initiative; Strategic National Stockpile Programs; EMS; DOJ grants; the Department of
Defense 1033 Program (also known as the LESO Program); and CISA’s Infrastructure Security
Division. However, coordination is not limited to grant funding. It also includes leveraging
assessments such as Transportation Security Administration’s (TSA) Baseline Assessment for
Security Enhancement (BASE), reporting from the Intelligence Community, risk information such as
USCG’s Maritime Security Risk Analysis Model (MSRAM), and USBP Sector Analysis.
Each SHSP- and UASI-funded investment that addresses biological risk, patient care, or health
systems preparedness should be implemented in a coordinated manner with other federal programs
that support biological and public health incident preparedness such as those administered by HHS
ASPR, CDC, and DOT’s National Highway Traffic Safety Administration (NHTSA).
8.10.2. COLLABORATION WITH HEALTH CARE COALITIONS
Health Care Coalitions (HCC) are regional entities comprised of health care, public health, emergency
management, and emergency medical services organizations that plan and respond together,
leverage resources, and address challenges in health care delivery brought on by public health and
medical incidents. Given that many of the risks being mitigated include the potential for a range of
mass casualties, including those across the chemical, biological, radiological, nuclear, explosive
(CBRNE) spectrum, planning efforts should include the participation of HCCs and should take into
account the elements and capabilities articulated in the 2017-2022 Health Care Preparedness and
Response Capabilities, and other forthcoming versions.
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8.10.3. COLLABORATION WITH NONPROFIT ORGANIZATIONS
SHSP and UASI recipients are encouraged to work with the nonprofit community to address terrorism
and all-hazards prevention concerns, seek input on the needs of the nonprofit sector, and support
the goals of their investments.
8.10.4. COLLABORATION WITH TRIBAL NATIONS
Tribal governments and their members are an essential part of our nation’s emergency management
team. Effective relationships with tribes are necessary to fulfill FEMA’s mission of working together to
improve our nation’s preparedness and response posture. As such, FEMA strongly encourages
states, high-risk urban areas, and territories to work with Tribal Nations in overall initiatives, such as
whole community preparedness and emergency management planning.
8.11. Operation Stonegarden Operational Guidance (Homeland Security
Grant Program)
This section provides operational guidance to OPSG applicants on the development of a concept of
operations and campaign planning, the tactical operation period, and reporting procedures. This
guidance also delineates specific roles and responsibilities, expectations for operations, and
performance measures. Successful execution of these objectives will promote situational awareness
among participating agencies and ensure a rapid, fluid response to emerging border security
conditions.
OPSG uses an integrated approach to address transnational criminal activity. Federal and SLTT
partners are required to establish and maintain an OPSG Integrated Planning Team (IPT) with
representation from all participating law enforcement agencies and co-chaired by representatives
from USBP, the SAA, and participating local law enforcement agencies’ OPSG program
representatives. Each operational order will address specific threats, gaps, and vulnerabilities
identified by the USBP. All requests in the operational plan will be reviewed and approved by the
corresponding sector's Chief Patrol Agent or his/her designee for border security value. USBP will
provide routine monitoring and technical expertise to each participating agency. The content of each
operational plan, to include the requested items will be reviewed for border security value and
approved by the corresponding sector’s Chief Patrol Agent or his/her designee.
All operational plans should be crafted in cooperation and coordination with federal and SLTT
partners to meet the needs of the USBP Sector. Consideration will be given to applications that are
coordinated across multiple jurisdictions. All applicants must coordinate with the CBP/USBP Sector
Headquarters with geographic responsibility for the applicant’s location in developing and submitting
an Operations Order with an embedded budget to the SAA. Operations are to be crafted so that
resources are allocated to one or more of the supportable categories:
1. Law Enforcement Presence;
2. Situational Awareness; and/or
3. Intelligence Collection, Analysis, and Distribution.
Law Enforcement Presence includes activities and costs associated to having an SLTT partner
provide a law enforcement patrol presence in an area designated by the USBP Sector in support of
border security efforts. Situational Awareness includes technology to provide current and
immediately relevant information about currently active border security threats. Intelligence
Collection, Analysis, and Distribution includes both technology and manpower related to the
gathering and analysis of intelligence with a nexus to border security.
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The terms of an OPSG award do not extend to an SLTT partner any authority to enforce additional
laws, statutes, or regulations beyond their own authorities; SLTT partners are not empowered
through OPSG to enforce immigration authorities under Title 8 of the U.S. Code (i.e., the Immigration
and Nationality Act (INA)). Participation in the grant does not grant participants the power to operate
outside of their own jurisdictional boundaries.
8.11.1. CONCEPT OF OPERATIONS AND CAMPAIGN PLANNING
Post-Allocation Announcement/Pre-Award
The overarching operational cycle involves three stages: 1) application (described in the HSGP
NOFO); 2) concept of operations to formulate a Campaign Plan, and 3) one or more tactical
operational periods, which are all developed by the IPT. All Operations Orders: Concept of Operations
(CONOPS), Operation Orders or Campaign Plans, and Fragmentary Orders (FRAGOs) shall be
submitted through the CBP Stonegarden Data Management System.
Campaign Plan
After awards are announced, participants will create and submit an operations order that forms a
campaign plan and captures the initial, generalized-budgetary intent to their IPT.
The campaign plan should articulate the participant agency’s long-term border security objectives
and goals designed to mitigate border security risk.
Funds should be obligated as needed to target specific threats or vulnerabilities and ensure that
OPSG usage is commensurate to the unique risk of each border region. This may require several
short-term operations that combine to form an ongoing operational cycle, ensuring that USBP
commanders and SLTT agency partners reserve the flexibility to respond to the ever-changing
elements of border security.
The operations plan also will articulate the budgetary intent of how funds are to be used throughout
the performance period. The operations plan will project planned expenditures in the following
categories: overtime, equipment, travel, maintenance, fuel, and administrative funds. The
subrecipient can initiate the procurement of equipment as well as state how much the county
intends to use for M&A while keeping funds for overtime or residual equipment funds available for
use as needed. If the subrecipient intends to spend more than 50% of its award on overtime over the
course of the performance period, a Personal Reimbursement for Intelligence Cooperation and
Enhancement of Homeland Security Act (PRICE Act) waiver request must be submitted in accordance
with the policy initially outlined in IB 379: Guidance to State Administrative Agencies to Expedite the
Expenditure of Certain DHS/FEMA Grant Funding. The operations plan will meet both the SAA
expectations to obligate the funds within 45 days of the award announcement and the demands of
the grant’s operational intent. Sector approved campaign plans must be submitted to USBP
Headquarters no later than four months after the official awards announcement has been made.
Investment Modifications - Changes in Scope or Objective
Changes in scope or objective of the award – including those resulting from intended actions by the
recipient or subrecipients – require FEMA’s prior written approval, in accordance with 2 C.F.R. §
200.308(c)(1), § 200.407.
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If changes must be made to the original operational plan, such as additional funding requests or
other changes to the original scope or objectives, a FRAGO must be submitted in Homeland Security
Information Network (HSIN) to obtain FEMA’s prior written approval of such changes in accordance
with 2 C.F.R. § 200.308(c)(1). These modifications will be annotated in the annex section of the
FRAGO.
Operational Execution
If changes or additional funding requests to the original operational order must be made, a FRAGO
will be created. These modifications will be annotated in the annex section of the FRAGO.
Operational discipline is necessary for the success of OPSG. Deliberate, adaptive, integrated, and
intelligence-driven planning is critical to conducting targeted enforcement operations consistent with
the objectives of the OPSG. By participating in the OPSG, the SLTT agencies agree to conduct
operations designed to reduce border security risk.
Operations are composed of six critical elements: 1) a pre-planning meeting with the IPT; 2) specified
beginning and ending dates; 3) the integration of intelligence and border security; 4) use of targeted
enforcement techniques; 5) clearly stated objectives; and 6) an after-action meeting. These
operations require deliberate on-going planning to ensure command, staff, and unit activities
synchronize to current and future operations. The cyclical nature of the process will ensure OPSG
activities align with the fluctuating border security threats and vulnerabilities. The IPT should
leverage information provided by the fusion center, Border Intelligence Centers, or other local
intelligence center when possible and establish a common operational vision.
The USBP Sector’s Chief Patrol Agent or his/her designee will ensure that the information or
intelligence has a clear nexus to border security. Intelligence will be shared and vetted for border
security value, driving the focus of operations. Once intelligence-driven targets are identified, the IPT
will decide on operational objectives that reflect the intended impact of operations. The objectives
should outline how the operation will deter, deny, degrade, or dismantle the operational capacity of
the targeted transnational criminal organizations.
Each operational period will begin on a predetermined date and end on a predetermined date;
however, dates may be subject to change commensurate with emerging security conditions. The
starting date of the operational period should be established to allow sufficient time for the order to
be submitted and approved by the corresponding USBP Sector and in concurrence with its SAA and
USBP Headquarters. The USBP Sectors will upload copies of the operations order in the
corresponding folder in the CBP Stonegarden Data Management System.
8.11.2. REPORTING PROCEDURES
Participation in OPSG requires accurate, consistent, and timely reporting of how funds are used, and
how the SLTT agencies’ operations have impacted border security through the mitigation of threat or
vulnerability and the overall reduction of risk. Reporting will focus on monitoring program
performance; determining the level of integration and information sharing; and developing best
practices for future operations. To ensure consistent reporting each SLTT agency will identify a single
point of contact to represent their agency as a member of the IPT and to coordinate the submission
of reports or execute other aspects of the grant.
The Daily Activity Report (DAR), which can be found by selecting the current fiscal year HSGP NOFO
on FEMA’s preparedness grants page, is to be used to submit the ongoing results and outputs from
OPSG operations conducted. The information and statistics included in the DAR will be delineated
by agency (friendly forces). The DAR must be submitted to the USBP sector or the participating
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agency’s OPSG coordinator within 48 hours of the conclusion of each OPSG shift. Subrecipients and
Sectors are responsible to ensure that DARs are submitted in the proper format and in a timely
manner. DARs will be submitted using the CBP Stonegarden Data Management System. Friendly
forces receiving funding through a subrecipient will submit DARs within 48 hours. Border Patrol
Sectors and OPSG subrecipients will implement internal protocols to ensure operational data from
subrecipients and friendly force DARs are properly collected following the established guidelines.
In addition to the ongoing reporting of outputs, subrecipient participants will be required to submit
AARs to USBP sectors within 10 days of closing the operational POP for that funding year. The AAR
should carefully articulate outcomes and outputs as well as how the results of the operation
compare with the objectives identified during the pre-planning meeting. Failure to submit the AAR in
a timely manner may prevent the approval of future operations requests. All AARs and other OPSG
reporting requirements will be submitted through the CBP Stonegarden Data Management System.
Sectors are responsible for submitting AARs into Border Patrol Enforcement Tracking System
(BPETS) as applicable.
8.11.3. OPERATION STONEGARDEN COORDINATION
OPSG supports enhanced cooperation and coordination among CBP, USBP, and federal and SLTT
law enforcement agencies to improve overall border security. OPSG provides funding to support joint
efforts to secure the United States’ borders along routes of ingress/egress of international borders
including travel corridors in states bordering Mexico and Canada along with states and territories
with international water borders. OPSG also further enhances the sharing of threat information and
intelligence between federal and SLTT law enforcement agencies through the development and
sustainment of a capable workforce of analysts that have the necessary experience and training,
access to open source, unclassified and classified information, products, data, SAR, tips/leads, and
online/social media-based threats as well as necessary services and technology to facilitate analytic
capabilities and collaboration.
SLTT law enforcement agencies will utilize their own law enforcement authorities to support the CBP
and USBP border security mission and will not receive any additional authority as a result of
participation in the grant. An OPSG award does not provide any additional authority to SLTT law
enforcement agencies. More specifically, SLTT law enforcement agencies are not empowered
through OPSG to enforce immigration authorities under Title 8 of the U.S. Code (i.e., the INA).
SLTT law enforcement agencies are expected utilize their own jurisdictional authority in support of
enhanced border security unless some other agreement applies. SLTT law enforcement agencies are
further expected to operate within the bounds of all applicable laws, to include federal laws, state
statutes, and local laws, policies, and procedures.
OPSG is intended to support border states and territories of the United States in accomplishing the
following objectives:
.Increase intelligence and operational capabilities to prevent, protect against, and respond to
border security issues;
.
.
Increase coordination and collaboration among federal and SLTT law enforcement agencies;
Continue the distinct capability enhancements required for border security and border
protection;
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.
.
Provide intelligence-based operations through USBP Sector Level experts to ensure safety and
operational oversight of federal and SLTT law enforcement agencies participating in OPSG
operational activities;
Support a request to any Governor to activate, deploy, or redeploy specialized National Guard
Units/Packages and/or elements of state law enforcement to increase or augment
specialized/technical law enforcement elements operational activities;
.
.
.
Continue to increase operational, material, and technological readiness of SLTT law enforcement
agencies;
Enhance the sharing of threat information and intelligence between federal and SLTT law
enforcement agencies; and
Develop and sustain a capable workforce of analysts that have the necessary experience and
training, as well as access to open source, unclassified and/or classified information, products,
data, SAR, tips/leads, online/social media-based threats, and the necessary services and
technology to facilitate these analytic activities.
OPSG funds must be used to provide an enhanced law enforcement presence and to increase
operational and intelligence capabilities of federal and SLTT law enforcement, promoting a layered,
coordinated approach to law enforcement within border states and territories of the United States.
.Federal and SLTT OPSG IPT: Federal and SLTT partners must establish and maintain a formalized
OPSG IPT with representation from all participating law enforcement agencies, co-chaired by
representatives from USBP, the SAA, and participating law enforcement agencies’ OPSG program
representatives.
.No fewer than two IPT meetings must take place during every funding year:
o
o
Before submitting the CONCOPS (application); and
Before submitting the Campaign Plan
.OPSG funds may be used for travel and per diem in support of the IPTs and OPSG strategic
planning events if the costs are otherwise compliant with other program and regulatory
requirements.
8.11.4. COORDINATION REQUIREMENTS
All operational plans should be crafted in cooperation and coordination among federal and SLTT
partners. Consideration will be given to applications that are coordinated across multiple
jurisdictions. All applicants must coordinate with the USBP Sector Headquarters with geographic
responsibility for the applicant’s location in developing and submitting an Operations Order with an
embedded budget to the SAA. OPSG funds must be used to provide increased operational
capabilities to SLTT partners in support of enhanced border security through:
.
.
.
Enhanced Law Enforcement Presence;
Enhanced Situational Awareness; and
Enhanced Intelligence Collection and Distribution.
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After awards are announced, prospective recipients will re-scope the draft Operations Order and
resubmit it as a final Operations Order with an embedded budget based on actual dollar amounts
awarded. The appropriate Sector Headquarters will approve final Operations Orders and forward
those orders to Headquarters, Office of Border Patrol, Washington, D.C., before funding is released.
Recipients may not begin operations, obligate, or expend any funds until FEMA and USBP
Headquarters have approved the final Operations Order and the embedded budget and removed any
existing special conditions and/or restrictions.
8.11.5. OPERATIONAL ROLES AND RESPONSIBILITIES
To achieve unity of effort, it is essential that each participant know the roles and responsibilities
within the IPT. The USBP sector’s Chief Patrol Agent, or his/her designee, will:
.
.
Coordinate and chair the area IPT’s meetings;
Coordinate with all interested and eligible SLTT agencies in the sector’s area of operation during
the open period of the OPSG application process by:
o Assisting applicants in completing the operations planning portion of the application, which is
like the Operations Order used by the USBP;
o
o
Forwarding the approved operation portion of the application to CBP/USBP Headquarters as
well as to the SAA to complete the application process set by FEMA; and
Detailing what operational support the USBP Sector anticipates for specific periods and
matching the capabilities of partners to fill those gaps.
.Following the announcement of grant awards, coordinate and chair a meeting with SLTT
agencies that received OPSG awards to develop an individualized campaign plan. This includes:
o Working with SLTT agencies along with other federal law enforcement agencies to determine
the dates, focus, and needs of each operational period thus ensuring that each operation
has a nexus to border security;
o Receiving the first periodic operations order from the SLTT agencies and ensuring that the
operation is conducted as outlined in the Campaign Planning section;
o
o
Monitoring and supporting the Operational Cycle throughout the performance period;
Ensuring the DAR and the AAR are submitted by SLTT agencies in the proper format and
within the established timeframes;
o
o
Providing instruction, when possible, to SLTT agencies regarding techniques, methods, and
trends used by transnational criminal organizations in the area;
Providing a single point of contact to participants as a subject-matter expert in OPSG that can
coordinate, collect, and report operational activities within the established reporting
procedures;
o Providing verification that operations are conducted;
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o
o
o
Documenting and conducting random, on-site operational verification of OPSG patrols by
subrecipients and friendly forces;
Verifying that subrecipients are performing OPSG enforcement duties in accordance with the
applicable grant, statute, and regulatory guidance and instructions; and
Ensuring that grant funds are appropriately expended to meet sector border enforcement
operational requirements and assist in enhancing subrecipient/friendly force capabilities to
provide for enhanced enforcement presence, operational integration, and intelligence
sharing in border communities.
The SLTT agency lead, or their designee, will:
.Coordinate with the SAA on all grant management matters including but not limited to the
development and review of operations orders, expenditure of funds, allowable costs, reporting
requirements;
.
.
.
Upon receiving a grant award, coordinate and meet as a member of the IPT to develop an
individualized campaign plan that covers the length of the grant performance period;
Work within the IPT to develop an initial Operational Cycle and determine the duration of the first
operational period based on the tactical needs specific to the area;
Submit all operations orders for review and submit the operations order to the Border Patrol and
ensure the operation meets the six criteria established in the Operational Execution Section (see
Section 8.11.1 “Concept of Operations and Campaign Planning”):
o
o
Conduct operations as needed throughout the length of the grant performance period;
Integrate law enforcement partners from contiguous counties and towns into their tactical
operations to expand the layer of security beyond existing areas;
o
o
Ensure all required reports, including reports from friendly forces, are submitted to the
Border Patrol and the SAA, when applicable, in the proper format and within established
timeframes;
Ensure applicable OPSG-derived data is shared with the designated fusion center in the state
or high-risk urban areas;
o Ensure applicable intelligence is shared with the designated fusion center in the state and/or
high-risk urban areas;
o Request instruction and information from the SAA, when applicable, and/or USBP and other
federal law enforcement agencies regarding techniques, methods, and trends used by
transnational criminal organizations in the area;
.
.
Provide the SAA and USBP a single point of contact that maintains subject-matter expertise in
OPSG who can coordinate, collect, and report operational activities within the established
reporting procedures; and
Assist as required with the coordination, management, and operational aspects of the grant.
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The SAA will:
.
.
Actively engage in the IPT meetings;
Work in direct coordination and communication with the local or tribal agency lead on all grant
management matters;
.
.
.
.
Review all operations orders created by the local or tribal agency;
Act as the fiduciary agent for the program and provide expertise in state policy and regulations;
Enter into a subaward agreement to disburse the allocated funding awarded through FEMA;
Generate biannual reports to FEMA capturing the subrecipients’ obligations and expenditures of
funds;
.
.
.
Determine if the grant’s performance period requires additional refinement over the federally
established 36-month period;
Conduct audits of the program to ensure that the subrecipients are following program guidance;
and
Assist as required with the coordination, management, and operational aspects of the grant.
8.11.6. DEFINITIONS (OPERATION STONEGARDEN)
Area of Interest: A specific area, areas, or facilities known to be used by transnational criminal
organizations in furtherance of their criminal activity.
Border security related crime: Any action or enterprise that constitutes an offense which is
punishable by law, for which prosecution would serve established border security goals as outlines
by the CBP for a whole of community approach:
That results in a favorable environment for criminal enterprise network, transnational criminal, or
terrorist organizations; the smuggling/trafficking of humans, contraband, narcotics, or weapons of
mass destruction across or in proximity to the U.S. border; or
.That has a direct nexus to illicit cross-border activity.
Campaign Plan: The first Operational Order based on the CONOP aimed at accomplishing a strategic
or operational objective within a given time and space.
CONOPS: A written statement that clearly and concisely expresses what the SLTT commander
intends to accomplish and how it will be done using available resources (and funding). It is also the
operational equivalent of the OPSG grant application.
FRAGO: A fragmentary order is a modification of the approved campaign plan, reflecting changes to
the scope or objective pursuant to 2 C.F.R. § 200.308(c)(1). After an operation order has been
approved, any changes to a campaign plan will be submitted via HSIN as a FRAGO for FEMA’s
approval. Subsequent FRAGOs are permissible, subject to FEMA’s prior written approval, consistent
with the requirements of 2 C.F.R. § 200.308, § 200.407.
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Friendly Forces: Local law enforcement entities supporting border security operations to whom OPSG
subrecipients provide funding.
IPT: Group that coordinates on all aspects of OPSG application, planning, and de-briefings.
Operational Cycle: A deliberate on-going cycle of command, staff, and unit activities intended to
synchronize current and future operations (driven by current intelligence and short-term goals that
support the campaign).
Operational Discipline: The organized manner in which an organization plans, coordinates, and
executes the OPSG mission with common objectives toward a particular outcome.
Operation/Operational Order: A formal description of the action to be taken to accomplish or satisfy
a CONOP, Campaign Plan, or FRAGO. The Operation/Operational Order includes a detailed
description of actions to be taken and required logistical needs to execute an operation.
Opioid Receptor Antagonists: Any medically approved drug or medical substance that can be utilized
by first responder personnel in an emergency that is designed to counteract the effects of an opioid
overdose.
Performance Measure: A numerical expression that quantitatively conveys how well the organization
is doing against an associated performance goal, objective, or standard.
Risk: Potential for an adverse outcome assessed as a function of threats, vulnerabilities, and
consequences associated with an incident, event, or occurrence.
Targeted Enforcement: The leveraging of all available assets against a specific action, area,
individual, or organization and using those deemed most appropriate to mitigate risk.
Target of Interest: A specific person, group of persons, or conveyance known to be part of, or used by
transnational criminal organizations to advance their criminal activity.
Threat: Information expressing intent to conduct illegal activity often derived from intelligence
sources, the overall context, a specific event or series of events, or observation of suspicious activity.
Tier: Tier refers to the geographical location of a municipality, county, or tribe with respect to the
United States national border, i.e., Tier 1 is a county located on the border; a Tier 2 county is a
county contiguous to a Tier 1 county; and a Tier 3 is a county not located on the physical border but
is a contiguous to a Tier 2 county.
Unity of Effort: Coordination and cooperation among all organizational elements, even though they
may not be part of the same command structure, to achieve success.
Vulnerability: The protective measures in place are less than the protective measures needed to
mitigate risk.
8.12. Supplemental Resources (Homeland Security Grant Program, Tribal
Homeland Security Grant Program)
FEMA collaborates with various subject-matter experts and acknowledges the value and expertise
these Federal partner agencies provide to help shape the development and implementation of the
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HSGP and THSGP. This continued partnership and collaboration helps provide recipients with the
greatest number of resources required to effectively manage and implement funds as well as
promotes transparency. Therefore, FEMA is providing links to information on various subjects and
policies that are relevant to the mission and intent of FEMA and its preparedness grant programs.
8.12.1. CHEMICAL, BIOLOGICAL, RADIOLOGICAL, AND NUCLEAR DETECTION
The Countering Weapons of Mass Destruction (CWMD) Office is a support component within DHS
established in December 2017 to counter attempts by terrorists or other threat actors to carry out an
attack against the United States or its interests using a weapon of mass destruction. The CWMD
Office provides guidance to improve national coordination on CBRN issues and works with federal
and SLTT agencies to ensure operators have better access to current data and subject-matter
expertise they need. FEMA offers implementation support on the THIRA/SPR for SLTT partners and
the CWMD Office offers TA to provide guidance to SLTT partners seeking to address CBRN threats
and to build or sustain CBRN detection and response capabilities. For more information or
assistance, please contact CWMD-THIRA@hq.dhs.gov.
8.12.2. NATIONAL INFORMATION EXCHANGE MODEL
National Information Exchange Model (NIEM) is a common vocabulary that enables efficient
information exchange across diverse public and private organizations. NIEM can save time and
money by providing consistent, reusable data terms and definitions and repeatable processes. To
support information sharing, all recipients of grants for projects implementing information exchange
capabilities are required to use NIEM and to adhere to the NIEM compliance rules. Go to NIEM.gov
for guidance on how to utilize FEMA award funding for information sharing, exchange, and
interoperability activities.
The NIEM Emergency Management domain supports emergency-related services (including
preparing first responders and responding to disasters), information sharing, and activities such as
homeland security and resource and communications management. The NIEM Emergency
Management domain has an inclusive governance structure that includes federal, SLTT, industry,
and, where necessary, international partnerships. The NIEM Emergency Management domain is
committed to community support via TA and NIEM training. For more information on the NIEM
Emergency Management domain, to request training or TA or to just get involved, go to the
Emergency Management page on NIEM.gov.
8.12.3. INFRASTRUCTURE RESILIENCE PLANNING FRAMEWORK
SLTT governments are faced with complex long-term decisions, limited sources of revenue, and
changing populations. CISA developed the Infrastructure Resilience Planning Framework (IRPF) as a
resource for SLTT planners. The IRPF provides a process and a series of tools and resources for
incorporating critical infrastructure resilience considerations into planning activities. The IRPF can be
used to support capital improvement plans, hazard mitigation plans, or other planning documents,
as well as funding requests. For more information, see the IRPF.
8.12.4. INTEGRATED PUBLIC ALERT AND WARNING SYSTEM
The Integrated Public Alert & Warning System (IPAWS) is FEMA's national system for local alerting
that provides authenticated emergency and life-saving information to the public through mobile
phones using Wireless Emergency Alerts, to radio and television via the Emergency Alert System, and
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on the National Oceanic and Atmospheric Administration's Weather Radio. For more information, see
the IPAWS page on FEMA.gov.
8.12.5. HOMELAND SECURITY INFORMATION NETWORK
HSIN is a user-driven, web-based, information sharing platform that connects all homeland security
professionals including the DHS and its federal, SLTT, international, and private sector partners
across all homeland security mission areas. HSIN is used to support daily operations, events,
exercises, natural disasters, and incidents. To support user mission needs, HSIN provides three sets
of services for secure information sharing. The first service provides a shared place for communities
to securely collaborate on homeland security issues and includes core functions such as a web
conferencing and instant messaging tools with white boarding, video, and chat services for real-time
communication and situational awareness. The second set provides secure dissemination and
sharing capabilities for homeland security alerts, reports, and products. The third set allows users to
access and query a variety of shared data and services from all homeland security mission areas
and trusted federal partners. Preparedness grant funds may be used to support planning, training
and development costs associated with developing and managing mission critical HSIN communities
of interest and sites. Learn more about HSIN on the HSIN HSGP Guidance page on DHS.gov.
8.12.6. STATE, LOCAL, TRIBAL, TERRITORIAL CYBERSECURITY ENGAGEMENT PROGRAM
CISA is responsible for enhancing the security, resilience, and reliability of the Nation’s cyber and
communications infrastructure. CISA works to prevent or minimize disruptions to critical information
infrastructure to protect the public, the economy, and government services. CISA leads efforts to
protect the Federal “.gov” domain of civilian government networks and to collaborate with the private
sector—the “.com” domain—to increase the security of critical networks.
The DHS SLTT Cybersecurity Engagement Program within CISA was established to help non-federal
public stakeholders and associations manage cyber risk. The program provides appointed and
elected SLTT government officials with cybersecurity risk briefings, information on available
resources, and partnership opportunities to help protect their citizens online. Through these and
related activities, the program coordinates DHS’s cybersecurity efforts with its SLTT partners to
enhance and protect their cyber interests. More information on all CISA resources available to
support SLTT governments is available at the Resources & Tools page on CISA.gov.
8.12.7. FRAMEWORK FOR IMPROVING CRITICAL INFRASTRUCTURE CYBERSECURITY
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would
aid in implementation of all or part of the Framework for Improving Critical Infrastructure
Cybersecurity (the “Framework”) developed by the National Institute of Standards and Technology
(NIST). The Framework gathers existing international standards and practices to help organizations
understand, communicate, and manage their cyber risks. For organizations that do not know where
to start with developing a cybersecurity program, the Framework provides initial guidance. For
organizations with more advanced practices, the Framework offers a way to improve their programs,
such as better communication with their leadership and suppliers about management of cyber risks.
CISA’s Critical Infrastructure Cyber Community C³ Voluntary Program also provides resources to
critical infrastructure owners and operators to assist in adoption of the Framework and managing
cyber risks. Additional information on the Critical Infrastructure Cyber Community C³ Voluntary
Program can be found at the Critical Infrastructure Cyber Community C³ Voluntary Program page on
CISA.gov.
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DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under
the “Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that
help U.S.-based companies and SLTT governments defend their computer systems against
unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable
cyber threat indicators from sensitive and classified Government Furnished Information (GFI). DHS
then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in
turn use the indicators to block certain types of malicious traffic from entering a company’s
networks. Groups interested in subscribing to ECS must contract directly with a CSP to receive
services. Please visit the ECS page on CISA.gov for a current list of ECS CSP points of contact.
8.12.8. REGIONAL RESILIENCY ASSESSMENT PROGRAM
The Regional Resiliency Assessment Program (RRAP) is a cooperative assessment of specific critical
infrastructure within a designated geographic area and a regional analysis of the surrounding
infrastructure that address a range of infrastructure resilience issues that could have regionally and
nationally significant consequences. These voluntary, non-regulatory RRAP projects are led by CISA’s
Infrastructure Security Division and are selected each year by DHS with input and guidance from
federal, state, and local partners. For additional information on the RRAP, visit the RRAP page on
CISA.gov.
8.12.9. LAW ENFORCEMENT SUPPORT OFFICE, OR 1033 PROGRAM
LESO facilitates a law enforcement support program, which originated from the National Defense
Authorization Act of Fiscal Year 1997. This law allows the transfer of excess Department of Defense
property that might otherwise be destroyed to law enforcement agencies across the United States
and its territories.
No equipment is purchased for distribution. All items were excess that had been turned in by military
units or had been held as part of reserve stocks until no longer needed. Requisitions cover the
gamut of items used by America’s military ― clothing, office supplies, tools and rescue equipment,
vehicles, small arms, and more. There is no fee for the equipment itself; however, the law
enforcement agencies are responsible for the shipping costs.
For additional information on the LESO, see the LESO page on DLA.mil.
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9. Nonprofit Security Grant Program
9.1.Program Funding Guidelines and Priorities
NSGP grant recipients (e.g., SAAs) and subrecipients (e.g., nonprofit organizations) may only use
NSGP grant funds for the purpose set forth in the grant award and must use funding in a way that is
consistent with the statutory authority for the award. See the annual NSGP NOFO for program
Priorities.
9.1.1. NATIONAL INCIDENT MANAGEMENT SYSTEM IMPLEMENTATION
Recipients receiving NSGP funding must implement NIMS. Recipients must manage resources
purchased or supported with FEMA grant funding according to NIMS resource management
guidance.
9.2.Nonprofit Security Grant Program Investment Modifications – Changes
in Scope or Objective
Changes in scope or objective of the award—whether as a result of intended actions by the recipient
or subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. § 200.308(c)(1),
§ 200.407. NSGP is competitive with applications recommended for funding based on threat,
vulnerability, consequence, and their mitigation to a specific facility/location. However, consistent
with 2 C.F.R § 200.308(c)(1), Change in Scope Notification, FEMA requires prior written approval of
any change in scope/objective of the grant-funded activity after the award is issued. See 2 C.F.R. §
200.308(b), (c). Scope/objective changes will be considered on a case-by-case basis, provided the
change does not negatively impact the competitive process used to recommend NSGP awards.
Requests to change the scope or objective of the grant-funded activity after the award is made must
be submitted by the SAA via FEMA GO as a Scope Change Amendment. The amendment request
must include the following:
.A written request from the NSGP subrecipient on its letterhead, outlining the scope or objective
change including the approved projects from the subrecipient’s IJ, the funds and relative scope
or objective significance allocated to those projects, the proposed changes, and any resulting
reallocations as a result of the change of scope or objective;
.
.
An explanation why the change of scope or objective is necessary;
Validation from the SAA that any deviations from the approved IJ are addressed in the
vulnerability assessment submitted by the subrecipient at the time of application; and
.The subrecipient request must also address whether the proposed changes will impact its ability
to complete the project within the award’s POP.
FEMA will generally not approve NSGP change-of-scope requests resulting from the following
situations:
.Subrecipients that relocate their facilities after submitting their application who are requesting a
change of scope to allow them to use NSGP funds toward projects at the new facility; or
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.Subrecipients that renovate their facilities after submitting their application in cases where the
subsequent renovations would affect the vulnerability/risk assessment upon which the IJ is
based.
NSGP project funding is based on the ability of the proposed project to mitigate the risk factors
identified in the IJ. For this reason, FEMA may reject requests to significantly change the physical
security enhancements that are purchased with NSGP funding where FEMA believes approval of the
request would change or exceed the scope of the originally approved project. FEMA will consider all
requests to deviate from the security project as originally proposed on a case-by-case basis,
consistent with 2 C.F.R. § 200.308(c)(1).
Subrecipients may not proceed with implementing any scope/objective changes until the SAA
receives written approval from FEMA through FEMA GO and until the SAA has made any required
subaward modifications.
If a subrecipient is simply making changes to its own budget without impacting the scope or
objective of the subaward, and where the budget changes do not involve other prior approval
requirements listed in 2 C.F.R. § 200.407, then the subrecipient does not need the prior approval of
the SAA or FEMA. See 2 C.F.R. § 200.308. Instead, the subrecipient is only required to report to the
SAA the budget changes. Similarly, the SAA should report those budget changes to FEMA.
9.3.Pass-Through Requirements
Pass-through funding is required under this program. Awards made to the SAA for the NSGP carry
additional pass-through requirements. Pass-through is defined as an obligation on the part of the
state to make subawards to selected nonprofit organizations. The SAA must provide funds awarded
under NSGP to subrecipients within 45 days of receipt of the funds. A letter of intent (or equivalent)
to distribute funds is not sufficient. Award subrecipients that are selected for funding under this
program must be provided with funding within 45 days from the date the funds are first made
available to the recipient so that they can initiate implementation of approved investments.
For the SAA to successfully meet the pass-through requirement and provide funding to the
subrecipients, the SAA must meet the following four requirements:
.
.
.
.
There must be some action by the SAA to establish a firm commitment to award the funds to the
selected nonprofit organization;
The action must be unconditional on the part of the SAA (i.e., no contingencies for availability of
SAA funds);
There must be documentary evidence of the commitment of the award of funding to the selected
nonprofit organization; and
The SAA must communicate the terms of the subaward to the selected nonprofit organization.
If a nonprofit organization is selected for an NSGP award and elects to decline the award, the SAA
must notify their FEMA Preparedness Officer. The SAA may not re-obligate to another subrecipient
without prior approval. “Receipt of the funds” occurs either when the SAA accepts the award or 15
calendar days after the SAA receives notice of the award, whichever is earlier. SAAs are sent
notification of NSGP awards via the FEMA GO system. If an SAA accepts its award within 15 calendar
days of receiving notice of the award in the FEMA GO system, the 45-calendar day pass-through
period will start on the date the SAA accepted the award. Should an SAA not accept the NSGP award
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within 15 calendar days of receiving notice of the award in the FEMA GO system, the 45-calendar
days pass-through period will begin 15 calendar days after the award notification is sent to the SAA
via the FEMA GO system.
It is important to note that the POP start date does not directly affect the start of the 45-calendar day
pass-through period. For example, an SAA may receive notice of the NSGP award on Aug. 20, 2023,
while the POP dates for that award are Sept. 1, 2023, through Aug. 31, 2026. In this example, the
45-day pass-through period will begin on the date the SAA accepts the NSGP award or Sept. 4, 2023
(15 calendar days after the SAA was notified of the award), whichever date occurs first. The POP
start date of Sept. 1, 2023, would not affect the timing of meeting the 45-calendar day pass-through
requirement.
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10. Surface Transportation Security Grant Programs
(Transit Security Grant Program, Intercity Passenger
Rail Program, Intercity Bus Security Grant Program)
10.1. Program Funding Guidelines and Priorities (Transit Security Grant
Program, Intercity Passenger Rail Program, Intercity Bus Security Grant
Program)
Costs charged to a TSGP, IPR Program, or IBSGP award must be consistent with the Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, located at 2
C.F.R. Part 200.
.NOTE: Costs charged to an IPR Program award must also be consistent with the cost principles in
the Federal Acquisition Regulation (FAR) Part 31.2 in lieu of 2 C.F.R. Part 200, Subpart E. Any
conflicts between FAR 31.2 and 2 C.F.R. Part 200, Subpart E shall be resolved in favor of the
applicable provision in FAR 31.2.
See annual program NOFO for information on program-specific priorities.
10.2. Changes in Scope or Objectives (Transit Security Grant Program,
Intercity Passenger Rail Program, Intercity Bus Security Grant Program)
All three Surface Transportation Security Grant Programs generally do not allow for scope or objective
changes unless there are extenuating circumstances (e.g., the COVID-19 or a similar pandemic
preventing activities). FEMA will consider scope/objective changes on a case-by-case basis if
extenuating circumstances are present.
10.3. Security Plan Requirements (Transit Security Grant Program, Intercity
Passenger Rail Program, Intercity Bus Security Grant Program)
10.3.1. TRANSIT SECURITY GRANT PROGRAM AND INTERCITY PASSENGER RAIL PROGRAM
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):
Security plans should include the following, as appropriate:
.
.
A prioritized list of all items included in the public transportation agency’s security assessment that
have not yet been addressed;
A detailed list of any additional capital and operational improvements identified by DHS or the
public transportation agency and a certification of the public transportation agency’s technical
capacity for operating and maintaining any security equipment that may be identified in such list;
.Specific procedures to be implemented or used by the public transportation agency in response to
a terrorist attack including evacuation and passenger communication plans along with appropriate
evacuation and communication measures for the elderly and individuals with disabilities;
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.A coordinated response plan that establishes procedures for appropriate interaction with state and
local law enforcement agencies, emergency responders, and federal officials to coordinate security
measures and plans for response in the event of a terrorist attack or other major incident;
.
.
A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part
1582;
Plans for providing redundant and other appropriate backup systems necessary to ensure the
continued operation of critical elements of the public transportation system in the event of a
terrorist attack or other major incident;
.
.
.
Plans for providing service capabilities throughout the system in the event of a terrorist attack or
other major incident in the city or region which the public transportation system serves;
Methods to mitigate damage within a public transportation system in case of an attack on the
system, including a plan for communication and coordination with emergency responders; and
Other actions or procedures as the Secretary of Homeland Security determines are appropriate to
address the security of the public transportation system.
10.3.2. ADDITIONAL AMTRAK REQUIREMENTS
Sections 1512 and 1513 of the Implementing Recommendations of the 9/11 Commission Act of
2007 (6 U.S.C. §§ 1162 and 1163) require a recipient to complete a vulnerability assessment and
develop a security plan. To be eligible for the IPR Program, Amtrak must have developed, or updated,
its security plan. The security plan must be based on a security assessment, such as the Baseline
Assessment for Security Enhancement, which is performed by ’SA's Transportation Security Inspectors-
Surface. This security assessment must have been conducted within the last three years prior to
receiving the respective fiscal year’s IPR Program award. A copy of the security plan and security
assessment must be provided to DHS/FEMA upon request.
Entities providing transit security (e.g., city/county police department or a transportation agency’s own
police department) must approve the security plan. The signature of a responsible official from the
agency’s railroad security provider serves as this approval. Associated documentation of this approval
must be provided to DHS/FEMA upon request. In addition, the agency’s railroad security provider is
encouraged to review the IJs prior to submission.
Amtrak, in receiving funds through this program, must participate in RTSWGs in participating urban
areas. The RTSWG should serve as the forum for regional partners to discuss risk, planning efforts,
and mitigation strategies. These discussions should be held regardless of funding to continue
enhancing the overall security of the region. Regional working groups are a best practice for enhancing
security and are encouraged for all jurisdictions.
An application submitted by an otherwise eligible non-federal entity (i.e., the applicant) may be deemed
ineligible when the person that submitted the application is not: 1) a current employee, personnel,
official, staff or leadership of the non-federal entity; and 2) duly authorized to apply for an award on
behalf of the non-federal entity at the time of application.
Further, the AOR and SA must be a duly authorized current employee, personnel, official, staff or
leadership of the recipient and provide an email address unique to the recipient at the time of
application and upon any change in assignment during the POP. Consultants or contractors of the
recipient are not permitted to be the AOR or the SA of the recipient. It is the sole responsibility of the
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recipient to keep their points of contact for the organization up-to-date and accurate in all federal
systems.
The AOR is responsible for submitting programmatic and financial performance reports, accepting
award packages, signing assurances and certifications, and submitting award amendments.
10.3.3. INTERCITY BUS SECURITY GRANT PROGRAM REQUIREMENTS
To be eligible for the IBSGP, operators must have developed or updated their organization’s
Vulnerability Assessment and Security Plan (VASP) that must be based on a security assessment, such
as the BASE performed by Transportation Security Inspectors-Surface from TSA. Private operators
providing transportation with an over-the-road bus system must have completed or updated their VASP
within the past three years before the opening of the respective fiscal year’s IBSGP application period.
Additionally, a copy of the VASP certification must be submitted along with the application to be
considered eligible. Failure to include this certification will result in the application being deemed
ineligible. All operators must have completed or updated a VASP as required by Section 1531 of the
9/11 Act (6 U.S.C. § 1181) as follows:
Assessments and security plans should include, as appropriate:
.Identification and evaluation of critical assets and infrastructure, including buses, platforms,
stations, terminals, and information systems;
.
.
Identification of vulnerabilities to those assets and infrastructure; and
Identification of gaps in physical security; passenger and cargo security; the security of
programmable electronic devices, computers, or other automated systems that are used in
providing over-the-road bus transportation; alarms, cameras and other communications systems
and utilities needed for over-the-road bus security purposes, including dispatching systems;
emergency response planning; and employee training.
Security plans should also include, as appropriate:
.The identification of a security coordinator having authority to implement security actions,
coordinate security improvements, and receive communications from appropriate federal officials
regarding over-the-road bus security;
.
.
A list of needed capital and operational improvements;
Procedures to be implemented or used by the operator in response to a terrorist attack, including
evacuation and passenger communication plans that include individuals with access and
functional needs;
.
.
The identification of steps taken with state and local law enforcement agencies, emergency
responders, and federal officials to coordinate security measures and plans for response to a
terrorist attack;
A strategy and timeline for conducting training to prepare frontline employees for potential security
threats and conditions;
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.
.
Enhanced security measures to be taken by the operator when the Secretary of Homeland Security
declares a period of heightened security risk; and
Plans for providing redundant and backup systems required to ensure the continued operation of
critical elements of the operator’s system in the event of a terrorist attack.
For additional information, see the current fiscal year’s IBSGP NOFO.
10.4. Allowable Cost Guidance
10.4.1. SPECIFIC GUIDANCE ON EXPLOSIVE DETECTION CANINE TEAMS (TRANSIT SECURITY
GRANT PROGRAM, INTERCITY PASSENGER RAIL PROGRAM)
Explosive Detection Canine Team Certification
Each Explosive Detection Canine Team (EDCT), composed of one dog and one handler, must be
certified by an appropriate, qualified organization. TSA-certified EDCTs will meet or exceed certification
standards set by the TSA National Explosives Detection Canine Team Program (NEDCTP). Recipient
EDCTs that do not participate in the NEDCTP will be required to certify annually under their respective
agency, local, and state regulations. The recipient will maintain certification, utilization, and training
data to show compliance in meeting or exceeding those guidelines set forth by the Scientific Working
Group on Dog and Orthogonal Detection Guidelines (SWGDOG), as of Sept. 14, 2007, in addition to the
requirements set forth in the NOFO.
Explosive Detection Canine Team Submission Requirements
1. The recipient will ensure that a written security procedure plan exists for the safekeeping of all
explosive training aids, including safe transportation. The recipient will document the removal,
use, and return of explosive training aids used during training exercises or for any other
reason. The plan and all documentation must be made available to FEMA upon request;
2. The recipient will comply with requirements for the proper storage, handling, and
transportation of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco,
Firearms and Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law
and Regulation;
3. The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a
day, 7 days per week on an on-duty or off-duty on-call basis. If TSGP- or IPR Program-funded
EDCTs are not available, other non-TSGP or non-IPR Program funded EDCTs may be utilized for
this response. The intent is to provide maximum coverage during peak operating hours and to
maintain the ability to promptly respond to threats that affect public safety or mass transit
operations;
4. EDCTs under this grant are single purpose and will be trained to detect “live” explosives only,
not “simulated” explosives. EDCTs must not have received previous training to detect any other
substances;
5. The recipient will ensure that each EDCT receives on-site proficiency training at a minimum of 4
hours per week per duty cycle. This training shall include, but not be limited to, mass transit
passenger cars, terminals/platforms, luggage, freight/warehouses, and vehicles. Complete,
detailed, and accurate training records must be maintained for all proficiency training
conducted by each EDCT. These records must be made available to FEMA upon request;
6. The recipient will conduct appropriate training or other canine activities, within view of the
public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts which
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affect public safety or mass transit operations. The recipient will also ensure that such
activities include, over a period, a presence in operational areas of the mass transit system
during peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at
least 80% of their duty time, annually;
7. The recipient will provide safe and sanitary kennel facilities for program canines, and these
costs may be allowable with prior approval by FEMA. This applies to kenneling canines at a
mass transit system, handlers’ residences, or commercial boarding facilities. Canines must not
be left in makeshift accommodations or without proper supervision, protection, and care. The
recipient will ensure that canines are transported on-duty and off-duty in vehicles configured
with adequate temperature control, padding, and screening to ensure proper health, safety,
and security; and
8. The recipient will ensure that adequate routine and emergency veterinary care are provided for
all canines.
Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour
notice to ensure compliance with applicable federal regulations.
10.4.2. CAPITAL (CONSTRUCTION) PROJECTS GUIDANCE (TRANSIT SECURITY GRANT
PROGRAM, INTERCITY PASSENGER RAIL PROGRAM, INTERCITY BUS SECURITY
GRANT PROGRAM)
The recipient must obtain written approval from FEMA prior to the use of any program funds for
construction or renovation projects. When applying for construction funds, including communications
towers, the recipient must submit evidence of approved zoning ordinances, architectural plans, and
any other locally required planning permits. Additionally, the recipient is required to submit a SF-424C
Form and budget detail citing the project costs and a SF-424D Form for standard assurances for the
construction project.
Additional guidance for Transit Security Grant Program Capital (Construction) Projects:
Capital expenditures are defined in 2 C.F.R. § 200.1 as expenditures to acquire capital assets or
expenditures to make additions, improvements, modifications, replacements, rearrangements,
reinstallations, renovations, or alterations to capital assets that materially increase their value or
useful life. Use of capital expenditures must comply with 2 C.F.R. § 200.439. See Section 4.5.1
“Construction and Renovation” for more information.
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11. Port Security Grant Program
11.1. Program Funding Guidelines and Priorities
PSGP grant recipients may only use PSGP grant funds for the purpose set forth in the grant award and
must use funding in a way that is consistent with the statutory authority for the award. See the annual
PSGP NOFO for program Priorities.
11.2. Allowable Cost Guidance
11.2.1. SPECIFIC GUIDANCE ON EXPLOSIVE DETECTION CANINE TEAMS
Explosive Detection Canine Team Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified
organization. Canine (K-9) and handler should receive an initial basic training course and weekly
maintenance training sessions thereafter to maintain the certification. The basic training averages ten
weeks for the canine team (K-9 and handler together) with weekly training and daily exercising.
Comparable training and certification standards, such as those promulgated by the TSA Explosive
Detection Canine Program, the National Police Canine Association (NPCA), the U.S. Police Canine
Association (USPCA), or the International Explosive Detection Dog Association (IEDDA), may be used to
meet this requirement. Certifications and training records will be kept on file with the recipient and
made available to FEMA upon request.
Explosive Detection Canine Team Submission Requirements
PSGP recipients are required to submit a written plan or standard operating procedure (SOP) that
describes EDCT deployment policy including visible and unpredictable deterrent efforts and on-call
EDCTs rapid response times. Recipients who are subject to the maritime security regulations contained
in 33 C.F.R. Parts 104 (vessel security) or 105 (facility security), shall submit a Vessel Security Plan
(VSP) or Facility Security Plan (FSP) amendment detailing the inclusion of a (K-9) explosive detection
program into their security measures to the USCG for review and approval. The relevant portion of any
USCG-approved VSP or FSP, or any agency specific security plan or SOP must be made available to
FEMA and USCG upon request. The recipient will comply with requirements for the proper storage,
handling, and transportation of all explosive training aids in accordance with the Bureau of Alcohol,
Tobacco, Firearms and Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law
and Regulations.
Additional Explosive Detection Canine Team Resources Available for Canine Costs
The PSGP, while providing the ability to defray some start-up costs, does not cover any recurring costs
associated with EDCT programs. FEMA strongly encourages applicants to investigate their eligibility
under other programs, and potential exclusions, when developing their K-9 programs.
11.2.2. MARITIME DOMAIN AWARENESS
The maritime domain is defined as “all areas and things of, on, under, relating to, adjacent to, or
bordering on a sea, ocean, or other navigable waterway, including all maritime-related activities,
infrastructure, people, cargo, and vessels and other conveyances.” PSGP recipients are encouraged to
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familiarize themselves with this National Strategy. Homeland Security Presidential Directive-13 (NSPD-
41/HSPD-13) (Maritime Security Policy, Dec. 21, 2004). According to the National Plan to Achieve
Maritime Domain Awareness for the National Strategy for Maritime Security (Oct. 2005), “Maritime
Domain Awareness (MDA) is the effective understanding of anything associated with the global
maritime domain that could impact the security, safety, economy, or environment of the United States.
MDA is a key component of an active, layered maritime defense in depth. It will be achieved by
improving our ability to collect, fuse, analyze, display, and disseminate actionable information and
intelligence to operational commanders.” Id. at ii.
11.2.3. CAPITAL (CONSTRUCTION) PROJECTS GUIDANCE
Recipients must obtain written approval from FEMA prior to the use of any PSGP funds for construction
or renovation projects. Additionally, PSGP funding may not be used to construct buildings or other
physical facilities that are not constructed under terms and conditions consistent with the
requirements of section 611(j)(9) of the Stafford Act (42 U.S.C. § 5196(j)(9))1 which requires
compliance with the Davis-Bacon Act (codified as amended at 40 U.S.C. §§ 3141 et seq.) for PSGP
funded projects. Grant recipients must ensure that their contractors or subcontractors for construction
projects pay workers no less than the prevailing wages for laborers and mechanics employed on
projects of a character similar to the contract work in the civil subdivision of the state in which the
work is to be performed. See Section 4.6 “Davis-Bacon Act Compliance” for more information.
The following types of construction and renovation projects are allowable under PSGP, provided they
address a specific vulnerability or need identified in an AMSP or otherwise support the
maintenance/sustainment of capabilities and equipment acquired through PSGP funding:
.Maritime Command and Control Centers;
.
.
.
.
Interagency Operations Centers (IOCs) for maritime security;
Port Security Emergency Communications Centers;
Buildings to house generators that support maritime security risk mitigation;
Maritime security risk mitigation facilities (e.g., dock house, ramps, and docks for existing port
security assets);
.
.
Hardened security fences/barriers at access points;
Any other building or physical facility that enhances access control to the port/Maritime
Transportation Security Act (MTSA) facility area; and
.PSGP funding may be used to purchase and/or upgrade a barge to support a staging area for
maritime/port security patrols or maritime security risk mitigation responses. (Certain areas
1 While the Maritime Transportation Security Act of 2002, as amended at 46 U.S.C. § 70107(b)(2), requires that such
activities are carried out consistent with Section 611(j)(8) of the Stafford Act, a subsequent amendment to the Stafford Act by
section 3 of Pub. L. No. 109-308 in 2006 redesignated the text of Section 611(j)(8) to 611(j)(9). The cross reference in the
Maritime Transportation Security Act of 2002 has not been updated.
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throughout the Nation may require a barge that can be permanently anchored or moored in certain
areas to support maritime security risk mitigation activities.)
To be considered eligible for funding, the construction of fusion centers, operations centers, or
communications centers must offer a port wide benefit and support information sharing and
operational coordination among regional interagency and other port security partners. Applicants are
reminded that the POP is 36 months. Eligible costs for construction or renovation projects may not
exceed $1 million (federal share) per project, which may not exceed 10% of the total amount of the
award, as stated in 46 U.S.C. § 70107(b)(2)(A) and (B) (Section 102 of the Maritime Transportation
Security Act of 2002, Pub. L. 107-295, as amended). Grant recipients are not permitted to use PSGP
funds for construction projects that are eligible for funding under other federal grant programs. PSGP
funds may only be used for construction activities directly related to maritime security risk mitigation
enhancements.
All construction or renovation projects require EHP review. See Section 4.5 “Environmental Planning
and Historic Preservation Compliance” for more information.
11.3. Port-Wide Risk Management Plans
Port areas with existing Port Wide Risk Mitigation Plans (PRMPs) are encouraged to maintain their
PRMPs and use them to identify projects that will serve to address remaining maritime security
vulnerabilities. These ports are also encouraged to develop or maintain a Business Continuity and
Resumption of Trade Plans (BCRTP). For purposes of regional strategic and tactical planning, these
plans must take into consideration all port areas covered by their AMSP, align with the port area’s
AMSP, consider the entire port system strategically as a whole, and identify actions designed to
effectively mitigate security risks associated with the system’s maritime critical infrastructure and key
resources.
11.4. Port Security Grant Program Investment Modifications
The purpose of the grant award is to implement projects pursuant to the authorities at 46 U.S.C. §
70107. Under extreme circumstances, a recipient may reallocate award funds from one project to
another with prior written approval from FEMA and in a manner consistent with 2 C.F.R. § 200.308 if it
does not change the overall scope or objective of the award. Circumstances include, but are not
limited to, an inability to complete the original project, disaster events perpetuating an immediate
need to reprioritize funds, and changes in regulatory requirements. A recipient must explain the
deviation from the original project- including why it is deviating from or scaling down the original project
and what specific circumstances that occurred after the time of its award that necessitate the
reallocation request- in its reallocation request. The recipient must also identify how the reallocation
request aligns with PSGP priorities and the recipient’s original application and the award’s scope of
work. Due to legal limitations, reallocation requests that would change the scope of the overall
project(s) are not permitted. FEMA will also coordinate such reallocation requests with the USCG
Captain of the Port (COTP), and these requests must be verified and supported by the COTP as
essential in addressing Port Area priorities. Please also see the relevant PSGP NOFO regarding cost
share requirements including the implications if the project costs are less than what was applied for.
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12. Emergency Management Performance Grant
Program
12.1. Alignment of the Emergency Management Performance Grant
Program to the National Preparedness System
The EMPG Program contributes to the implementation of the National Preparedness System by
supporting the building, sustainment, and delivery of core capabilities. Core capabilities are essential
for the execution of critical tasks for each of the five mission areas outlined in the Goal. The EMPG
Program’s allowable costs support efforts to build and sustain core capabilities across the
Prevention, Protection, Mitigation, Response, and Recovery mission areas described in the Goal.
FEMA requires recipients to prioritize grant funding to demonstrate how EMPG Program-funded
investments support the following:
.Building or sustaining those capabilities that are identified as high priority through the
THIRA/SPR process and other relevant information sources, such as:
o
o
o
o
AARs following exercises or real-world events;
Audit and monitoring findings;
Hazard Mitigation Plans; and/or,
Other deliberate planning products; and
.Closing capability gaps that are identified in the state or territory’s most recent SPR.
To better understand the relationship between building capabilities and closing capability gaps,
refer to CPG 201, Third Edition. In advance of issuing the EMPG Program awards, FEMA Regional
Administrators will identify individual regional priorities based on their unique knowledge of each
region’s preparedness and emergency management needs and will share those priorities with the
states and territories within their region. The final priorities will be identified and mutually agreed to
by the state/territory and Regional Administrator through a collaborative negotiation process.
Ideally, all EMPG Program-funded projects, as outlined in the approved EMPG Program Work Plan,
will support the priorities identified through this collaborative approach. See the EMPG Program
Work Plan template in the EMPG Program NOFO for additional guidance.
FEMA continues to place emphasis on capabilities that address the greatest risks to the security and
resilience of the United States. When applicable, funding should support deployable assets that can
be used anywhere in the Nation through automatic assistance and mutual aid agreements,
including, but not limited to, the EMAC. The EMPG Program supports investments that improve the
ability of jurisdictions nationwide to:
.
.
.
Prevent a threatened or an actual act of terrorism;
Protect our citizens, residents, visitors, and assets against the greatest threats and hazards;
Mitigate the loss of life and property by lessening the impact of future disasters;
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.
.
Respond quickly to save lives, protect property and the environment, and meet basic human
needs in the aftermath of a catastrophic incident; or
Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy as well as the health, social, cultural,
historic, and environmental fabric of communities affected by a catastrophic incident.
The core capabilities contained in the Goal are highly interdependent and require the use of existing
preparedness networks and activities to improve training and exercise programs, innovation, and
appropriate administrative, finance, and logistics systems.
12.2. Implementation of the National Preparedness System
12.2.1. IDENTIFYING AND ASSESSING RISK AND ESTIMATING CAPABILITY
REQUIREMENTS
By Dec. 31, 2022, recipients were required to complete a THIRA/SPR that addresses all 32 core
capabilities and is compliant with CPG 201, Third Edition. Recipients are required to submit a THIRA
every three years to establish a consistent baseline for assessment. 2022 was the start of the new
3-year THIRA/SPR cycle and baseline assessment year for existing recipients. Any new grant
recipients during future CYs, for which the THIRA/SPR requirement applies, will start their new 3-year
THIRA/SPR cycle and baseline assessment year in that year. Specific guidance on the requirements
for each core capability is provided through program implementation support and supplemental
guidance, as some core capabilities have fewer reporting requirements than others. Recipients must
continue to respond to a series of planning-related questions as part of the THIRA/SPR process.
While the THIRA is only required every three years, jurisdictions are required to submit an SPR
annually. The submission deadline is Dec. 31 each year (as applicable). For additional guidance on
the THIRA/SPR, please refer to CPG 201, Third Edition. Recipients are also encouraged to refer to
the Preparedness Toolkit, which is an online portal that provides the whole community with tools to
aid in implementing all six areas of the National Preparedness System.
Reporting
In each EMPG Program recipient’s BSIR, the recipient must describe how expenditures support
building capability, closing capability gaps, or sustaining capabilities identified in the THIRA/SPR
process. EMPG Program recipients will, on a project-by-project basis, check one of the following:
.
.
Building a capability with EMPG Program funding; or
Sustaining a capability with EMPG Program funding.
Building and Sustaining Core Capabilities
Recipients must describe how proposed EMPG Program-funded projects will close capability gaps
or sustain capabilities identified through the THIRA/SPR process, particularly SPR Step 2 (see CPG
201, Third Edition), or other relevant information sources that identify capability needs. See the
EMPG Program Work Plan template in the EMPG Program NOFO for additional guidance and
requirements.
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12.2.2. NATIONAL INCIDENT MANAGEMENT SYSTEM IMPLEMENTATION
EMPG Program recipients must use standardized resource management concepts for resource
typing, credentialing, and an inventory to facilitate the effective identification, dispatch, deployment,
tracking, and recovery of resources. EMPG Program funds may be used for NIMS implementation;
specifically, to meet the requirements described in the NIMS Implementation Objectives for Local,
State, Tribal, and Territorial Jurisdictions.
Reporting
.Recipients will answer questions in the applicable secondary NIMS assessment portion of the
URT as part of a jurisdiction’s THIRA/SPR submission. This involves reporting on the status of the
qualification system used within the jurisdiction and sub-jurisdictions, as outlined in the EMPG
Program NOFO.
.Reporting will also be through a review by the FEMA Regional NIMS Coordinators during annual
TA visits with the states, tribes, and territories within their regions.
12.2.3. NATIONAL QUALIFICATION SYSTEM IMPLEMENTATION
For FY 2023 and going forward, as a post-award requirement, all recipients in the 50 states and
District of Columbia must work toward achieving the Phase 1 NQS Implementation Objectives
outlined in the table below and must, at a minimum, execute the Implementation Plan they
developed in FY 2022 as part of the Phase 0 NQS Implementation Objectives. Jurisdictions that
began implementation in FY 2023 shall have designed and adopted organizational qualification
system procedures, a certification program and credentialing standards for incident workforce
personnel in alignment with the NIMS Guideline for the NQS. All other jurisdictions (including
territories and EMPG Program subrecipients) are required to work toward implementation of NQS by
developing an Implementation Plan, using the FEMA-provided two-page template referenced in the
table below.
For all states and territories, the following requirements shall apply:
.At a minimum, only EMPG Program-funded deployable personnel, as determined by each
recipient organization, will be required to meet NQS certification requirements.
.Recipients and subrecipients will be considered in compliance with the NQS requirements as
long they are working toward implementing the NQS Implementation Objectives as outlined in
the table below.
.The expected completion date for each phase of the NQS Implementation Objectives is Dec. 31
of the applicable CY.
Additional NQS Implementation Guidance can be found at the NQS Supplemental Documents page
on FEMA.gov.
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Table 8: National Qualification System Implementation Phase Objectives
Phase 0: NQS Implementation
Objectives for CY 2022 Example Indicators
. Only the 50 States, the District of
Columbia and Puerto Rico shall work
toward implementation of NQS by
developing an Implementation Plan
using the FEMA-provided two-page
template.
. Completion of a jurisdiction
implementation plan.
. Identification of implementation
challenges.
. The Implementation Plan will identify
a jurisdiction’s timeline for
implementing NQS by CY 2025.
. All other jurisdictions are encouraged
to begin working toward identifying, at
a minimum, frequently deployed
positions and implementation but will
not be required until CY 2023.
Phase 1: NQS Implementation
Objectives for CY 2023 Example Indicators
. All jurisdictions shall work toward
implementation of NQS by developing
an Implementation Plan using the
FEMA-provided two-page template.
. Completion of a jurisdiction
implementation plan.
. Identification of implementation
challenges.
. Jurisdictions that began . Qualification policies and procedures
approved by the jurisdiction.
Procedures may include:
implementation in CY 2022 shall
have designed and adopted
organizational qualification system
procedures, a certification program,
and credentialing standards for
incident workforce personnel in
alignment with the NIMS Guideline for
the NQS.
o Establishment of a Qualification
Review Board or equivalent review
processes for incident workforce
personnel qualifications.
o Individual and team coach and
evaluation processes for incident
workforce personnel qualifications.
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Phase 0: NQS Implementation
Objectives for CY 2022 Example Indicators
Example IndicatorsPhase 2: NQS Implementation
Objectives for CY 2024
. All jurisdictions shall have designed
and approved organizational
. Qualification policies and procedures
approved by the jurisdiction.
qualification system procedures,
certification program, and
credentialing standards for incident
workforce personnel in alignment with
the NIMS Guideline for the NQS.
. Minimum criteria that trainees must
meet to be qualified in a specific
position is outlined in the NQS Job
Title/Position Qualification.
. PTB issuance and completion data.. Jurisdictions that began . Adoption of a resource management
system, such as OneResponder: a
web-based application hosted in a
cloud environment. It allows Authority
Having Jurisdictions (AHJ) to manage
qualifications of personnel.
implementation in CY 2022 shall
have issued position task books
(PTBs) to incident workforce
personnel, as designated by the
jurisdiction, and ensure incident
workforce personnel show progress in
working toward task endorsements
and minimum training requirements.
. In CY 2024, all jurisdictions partially
satisfy the requirement by ensuring
designated incident workforce
personnel meet the minimum training
requirements from the Job
Title/Position Qualification.
. Jurisdictions shall use a resource
management or qualification tool
system to track the qualification,
certification, and credentialing of
incident workforce personnel.
Phase 3: NQS Implementation
Objectives for CY 2025 Example Indicators
.PTB issuance and completion data.. All jurisdictions shall have issued
PTBs to designated incident
workforce personnel and ensure
incident workforce personnel show
progress in working toward task
endorsements and minimum training
requirements.
Reporting
Data collection and reporting on NQS implementation will be addressed via the following:
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.
.
NIMS secondary assessment questions on the URT. This involves reporting on the status of the
qualification system used within the jurisdiction and sub-jurisdictions.
Review by the Regional NIMS Coordinators during annual TA visits with the states, tribes, and
territories within their regions.
12.3. Logistics Planning
12.3.1. DISTRIBUTION MANAGEMENT PLANS
EMPG Program recipients are required to develop and maintain a Distribution Management (DM)
plan as an annex to their existing EOP. CPG 101 v3 provides guidance on the fundamentals of
planning and development of EOPs. The Distribution Management Plan Guide 2.0 released in Jan.
2022 provides information on how to develop the DM plan annex, key DM plan components, how to
review and update a DM plan, and how FEMA reviews and evaluates the plans.
A state/territory should submit its DM plan as both a Word document and PDF to its FEMA Regional
Grants Division. The maturity level of the plan may vary by state/territory, but the recipient is
required to submit a DM plan that accurately reflects the state or territory’s current capabilities and
capacity to distribute resources to survivors after a disaster and addresses the following
components: Requirements Defining; Resource Ordering; Distribution Methods; Inventory
Management; Transportation; Staging; and Demobilization.
The DM plan must be reviewed by recipients on an annual basis and updated as necessary by Sept.
30 of each CY. In the applicable secondary CPG 101 assessment portion of the online URT,
jurisdictions capture whether they have developed and incorporated a DM plan in their EOP.
.The DM plan should focus on the distribution of commodities and supplies such as food, water,
generators, and tarps to survivors following a disaster.
.The DM plan should address strategies/plans for:
o
o
o
o
o
o
o
Requirements Defining;
Resource Ordering;
Distribution Methods;
Inventory Management;
Staging Areas;
Transportation; and
Demobilization.
FEMA Regional Logistics Branch staff will work with EMPG Program recipients to provide TA during
the development and maintenance of their DM plans and to ensure all recipients have effective DM
plans capable of integrating with federal, NGOs, private sector, and SLTT stakeholders during major
disasters. Recipients should refer to the following for additional guidance:
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.
.
IB 442, Guidance on Distribution Management Plans for the Fiscal Year 2019 Emergency
Management Performance Grants Program; and
The Distribution Management Plan Guidance found on the Planning Guides page on FEMA.gov
12.3.2. ADDITIONAL LOGISTICS PLANNING RESOURCES
FEMA recommends that EMPG Program recipients use the following resources in developing their
DM plan. To learn more about these programs and documents, or for any questions, please contact
the Logistics Section Chief from your FEMA Region.
.The Logistics Capability Assessment Tool 2 (LCAT2) Flyer: The LCAT2 Flyer provides an overview
of the LCAT2, how it is beneficial, how the LCAT process works, and how to obtain an LCAT2. For
more information on the LCAT2, contact your FEMA Regional Logistics Branch Chief.
.Points of Distribution (PODs) Training: FEMA Logistics developed a comprehensive POD training
to assist states in developing actionable emergency distribution plans and understanding
associated challenges. Additional information, including an explanatory DVD, POD guide, and
online exam, are available on EMI’s website at the IS-26: Guide to Points of Distribution page.
.
.
Interagency Logistics (IL) Training: This basic IL training course (Interagency Logistics Training,
E8540) familiarizes participants with the IL concepts of planning and response. The course also
provides an overview of IL Partner disaster response organizations, discusses parameters for
logistics support coordination, and creates a whole community forum to exchange the best
logistics practices. Recipients may find more information on this and other courses by visiting the
EMI Courses & Schedules website.
Other Logistics Planning Resources: Recipients will find additional planning guidance at the
Planning Guides page on FEMA.gov. Specific to logistics planning, CPG 101 v3 provides guidance
on how to incorporate logistics into EOPs. Additionally, the Supply Chain Resilience Guide
provides emergency managers with recommendations and best practices on how to analyze local
supply chains and work with the private sector to enhance supply chain resilience using a five-
phased approach.
Reporting
Annual DM plan reviews will be reported in the PPR for the quarter ending Sept. 30 of the most
recently awarded EMPG Program. Reviews that result in an update must be submitted to the
Regional Grants Division Director or Regional EMPG Program Manager for review by regional logistics
staff. The regional logistics staff will review and rate the plans using the latest FEMA Distribution
Management Plan Guide 2.0.
12.4. Evacuation Planning
EMPG Program recipients should review and update their EOP in accordance with CPG 101 v3.
Recipients are strongly encouraged to include an evacuation plan or annex as part of their EOP as
well as plans to exercise and validate the evacuation plan and capabilities. At a minimum, recipients
should incorporate the National Response Framework’s (NRF’s) Mass Evacuation Incident Annex’s
planning considerations, and other FEMA documents related to evacuation planning, when
developing their own Evacuation Plan or Annex. See the NRF, Fourth Edition (October 2019) and NRF
Mass Evacuation Incident Annex (June 2008). Additional National Preparedness resources are
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available at National Preparedness and Planning Guides pages on FEMA.gov. Specific to evacuation
planning, the Evacuation and Shelter in Place Guidance identifies relevant concepts, considerations,
and principles that can inform jurisdictions in planning for evacuation and/or shelter-in-place
protective actions.
12.5. Disaster Housing Planning
12.5.1. STATE-LED DISASTER HOUSING TASK FORCE
Based on lessons learned from recent disasters, FEMA strongly encourages EMPG Program
recipients to establish a State-Led Disaster Housing Task Force (SLDHTF) plan as part of their EOP or
as a standalone document and update their plan at least once every two years.
SLDHTFs lead and coordinate state, local, private sector, and community-based actions to assess
housing impacts, identify appropriate post-disaster housing options, and establish processes for
expediting post-disaster housing delivery. SLDHTF plans should clearly identify the roles,
responsibilities, composition, and mobilization procedures for the SLDHTF, and how the SLDHTF
integrates into the incident command structure. To have a successful SLDHTF plan, FEMA
encourages recipients to establish a State Disaster Recovery Coordinator (SDRC).
.Complete the State Housing Strategy Template.
12.5.2. DISASTER HOUSING EXERCISES
SLTT governments are encouraged to exercise and validate their long-term sheltering and housing
stabilization plans as part of an existing exercise program. This includes:
.Validating the organizational structure of the Housing Task Force and internal readiness
capabilities to address post-disaster housing recovery.
.Validating disaster housing communication plans and procedures that coordinate and integrate
the activities and information generated by internal/external partners.
.
.
Validating data systems, security, and exchange protocols.
Validating planned actions and milestones transitioning from emergency sheltering to temporary
housing to permanent housing and long-term recovery.
12.5.3. ADDITIONAL DISASTER HOUSING PLANNING RESOURCES
SLTT governments are encouraged to review the planning guidance available at the Planning Guides
page on FEMA.gov. The Planning Guides page includes Planning Considerations: Disaster Housing
Guidance for State, Local, Tribal and Territorial Partners (May 2020), which supplements CPG 101
v3. It provides guidance on national housing priorities, types of housing, key considerations, and
housing-specific planning recommendations for SLTT jurisdictions to use, in conjunction with the Six-
Step Planning Process described in CPG 101 v3, to develop or improve disaster housing plans.
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12.6. State Disaster Recovery Coordinator
The Pre-Disaster Recovery Planning Guide helps states prepare for recovery by developing pre-
disaster recovery plans that follow a process to engage members of the whole community, develop
recovery capabilities, and create an organizational framework for recovery efforts.
FEMA strongly recommends that EMPG Program recipients include pre-disaster recovery planning as
part of their State Readiness and Preparedness efforts by establishing an SDRC. An effective pre-
disaster recovery plan and process is crucial to help recipients prepare for major disaster incidents
and recover effectively. Recipients are encouraged to use the Pre-Disaster Recovery Planning Guide
to help inform their identification and establishment of a SDRC. The SDRC position should be
included in the State Administrative Plan with the following responsibilities:
.Development of the pre-disaster recovery plan, including state-level leadership and structure,
formation of communication channels, multi-agency coordination, and building whole-community
partnerships to support recovery efforts.
.
.
.
.
Set the stage for necessary strategic, operational, and tactical post-disaster planning, actions,
and processes.
Maximize impact of federal, private sector, and nongovernmental dollars to enable recovery and
resilience.
Accelerate the delivery of resources, including funding and TA, to disaster-impacted
communities.
Enable state leadership to better organize and identify gaps in the state’s recovery capabilities.
12.7. Disaster Financial Management Policies and Procedures
Lessons learned from recent hurricane seasons and wildfires demonstrate the need for impacted
jurisdictions to improve their ability to immediately track and account for disaster costs. Disaster
financial management includes policies and procedures that work to recover expenses pertaining to
damage, emergency protective measures, and debris management during and after a disaster.
These policies and procedures include, but are not limited to, those supporting eligible contract costs
and force account labor, materials, and equipment.
12.7.1. STATE ADMINISTRATIVE PLAN
FEMA strongly recommends that EMPG Program recipients include disaster financial management
planning as part of their State Administrative Plan. An effective disaster financial management plan
and process is crucial to help recipients prepare for declarations of emergencies or major disasters
and plan for reimbursement. The table below details the processes that should be included in the
State Administrative Plan and recommendations on where they should be placed.
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Table 9: State Administrative Plan Guidance
State Administrative Plan Section
Recommendations
Processes
. Section V Part D: Project Funding and . A process to ensure subrecipients are
tracking and documenting disaster costs
necessary for federal reimbursement, such
as receipts, invoices, procurement
documents, contracts, and insurance
coverage/claims
Reimbursement
. Section V Part G: Records and Reports
. Section V Part D: Project Funding and . A process to document disaster cost
operations such as labor, equipment, and
materials that are allowable under federal
requirements
Reimbursement
. Section V Part G: Records and Reports
. Section V Part D: Project Funding and . A process to ensure that subrecipients are
Reimbursement not receiving a duplication in benefits
. Section IV Part B: Organization and Staffing . A process to ensure pre-disaster contracts
and procurement strategies are in place, if
necessary
Additionally, recipients are encouraged to use EMPG Program funds for training that develops,
delivers, and exercises disaster financial management procedures.
12.7.2. DISASTER FINANCIAL MANAGEMENT RESOURCES
Recipients are encouraged to use the following resources to inform their disaster financial
management planning efforts:
.State Administrative Plan Template: Recipients are recommended to use the State
Administrative Plan template found on FEMA’s Public Assistance webpage to inform their
planning efforts. The template includes example structure and content as a model for states to
create their own Administrative Plan.
.
.
Public Assistance Program and Policy Guide: The Public Assistance Program and Policy Guide
(PAPPG) combines all Public Assistance policy into a single volume and provides an overview of
the Public Assistance program implementation process.
Public Assistance Frequently Asked Questions and Guidance: Recipients are encouraged to view
the Public Assistance Frequently Asked Questions and guidance found on the Public Assistance
webpage to assist with disaster financial management planning efforts. The webpage provides
information pertaining to documentation, Public Assistance grant funding eligibility, and hazard
mitigation and can be found at the Public Assistance Fact Sheets, Job Aids, and FAQs page on
FEMA.gov.
.DHS OIG Audit Tips: Recipients are recommended to consult the DHS OIG report, Audit Tips for
Managing Disaster-Related Project Costs (OIG-17-120-D) for further assistance in documenting
and accounting for disaster-related costs. This report is informed by OIG audit findings and can
assist recipients in addressing issues that are frequent findings in disaster-related audits.
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.
.
Disaster Financial Management Guide: The Disaster Financial Management Guide provides
guidance for SLTT partners on establishing and implementing sound disaster financial
management practices.
PDAT Training and Resources: The PDAT provides training and other resources to assist grant
recipients in their efforts to comply with federal procurement standards.
12.8. Training and Exercises
12.8.1. INTEGRATED PREPAREDNESS PLAN
Recipients are expected to engage senior leaders and other whole community stakeholders to
identify preparedness priorities specific to training and exercise needs, which will guide development
of a state/territory multi-year IPP. Like the EMPG Program Work Plan development process, these
priorities should be informed by various factors, including jurisdiction-specific threats and hazards
(i.e., the THIRA); areas for improvement identified by real-world events and exercises (i.e., AAR);
external requirements such as stakeholder preparedness reviews (i.e., SPR), homeland security
policy, and industry reports; and accreditation standards, regulations, or legislative requirements.
Recipients must document these priorities, in conjunction with the Work Plan development process,
and use them to deploy a schedule of preparedness events and activities in the IPP. Information
related to IPPs and IPPWs can be found on the HSEEP page on FEMA.gov and FEMA’s Preparedness
Toolkit. FEMA Regional staff can provide TA for IPP and IPPW development.
Recipients should ensure that their EMPG Program Work Plans and IPPs align with and are
complementary to one another and are used in tandem to support shared priorities for building and
sustaining the state/territory’s preparedness capabilities. Recipients should include planning,
training, and exercise projects in their EMPG Program Work Plan that support priorities included in
their IPP. The current multi-year IPP must be submitted to hseep@fema.dhs.gov and the Regional
EMPG Program Manager before Jan. 31 of each year.
This will help ensure that priorities for both the IPP and EMPG Program Work Plan are based on
building capability and/or closing capability gaps documented in their THIRA/SPR and other relevant
sources of information. For example, if a recipient included Logistics and Distribution Management,
Resilient Communications, and Housing as priorities for its IPP, those should also be priorities in its
EMPG Program Work Plan. Additionally, IPPs should include all planning, training, and exercise
activities funded by the EMPG Program as well as activities funded by other sources. This inclusion
will ensure that recipients’ preparedness projects, investments, and activities are concentrated,
focused, and oriented toward closing gaps related to their top priorities, regardless of funding
source.
12.8.2. VALIDATING CAPABILITIES THROUGH EXERCISES
All recipients are required to develop and maintain a progressive exercise program consistent with
HSEEP guidance in support of the NEP. The NEP serves as the principal exercise mechanism for
examining national preparedness and measuring readiness. The NEP is a two-year cycle of exercises
across the nation that validates capabilities in all preparedness mission areas. The two-year NEP
cycle is guided by Principals’ Strategic Priorities, established by the National Security Council, and
informed by preparedness data from jurisdictions across the Nation.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery
assistance, tools and resources, enhanced coordination, and the ability to directly influence and
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inform policy and preparedness programs. If you have any questions or would like to request
assistance through the NEP, please visit the NEP website or reach out to the NEP directly at
NEP@fema.dhs.gov.
The exercises and priorities outlined in the IPP and all EMPG Program-funded exercises must be
included in the current fiscal year’s EMPG Program Work Plan. To avoid duplicate reporting,
applicants/recipients are not required to report EMPG Program-funded personnel costs associated
with exercises in the EMPG Program Work Plan. See the EMPG Program Work Plan template in the
EMPG Program NOFO for additional guidance.
12.8.3. TRAINING
Like the exercise guidance above, training activities should align to a current, multi-year IPP
developed through an annual IPPW and build from training gaps identified in the THIRA/SPR and
work plan development process. Further guidance concerning the IPP and the IPPW can be found at
the HSEEP Resources page on Preparedness Toolkit.
Through the NPD’s training and education enterprise, consisting of CDP, EMI, and NTED’s
partnerships with the National Domestic Preparedness Consortium, Rural Domestic Preparedness
Consortium, Continuing Training Grants partners, and the Center for Homeland Defense and
Security, FEMA develops and delivers training and education programs to increase capabilities,
reduce risk, and build resilient communities. More than 700 tuition-free courses are offered to
members of SLTT communities. By accessing the National Preparedness Course Catalog, users will
find all courses to include EMI training and includes links to the basic, advanced, and executive
emergency management academies.
12.8.4. FEMA’S NATIONAL PREPAREDNESS COURSE CATALOG
Training should foster the development of a community-oriented approach to emergency
management that emphasizes engagement at the community level, strengthens best practices, and
provides a path toward building sustainable resilience, all of which is included in the curriculum of
the EMI Basic Academy. The EMI Basic Academy provides a foundational education in emergency
management as a way for emergency managers to begin or advance their career. The goal of the
Basic Academy is to support the early careers of emergency managers through a training experience
combining knowledge of all fundamental systems, concepts, and practices of cutting-edge
emergency management.
EMPG Program funds used for training should support the nationwide implementation of NIMS. The
NIMS Training Program establishes a national curriculum for NIMS and provides information on
NIMS courses. Recipients are encouraged to place emphasis on the core competencies as defined in
the NIMS Training Program. NIMS is also included in the curriculum of the EMI Basic Academy. The
NIMS Training Program can be found at NIMS Implementation and Training.
All EMPG Program-funded personnel are expected to be trained emergency managers (see Section
12.2.3 “National Qualification System Implementation”). All EMPG Program-funded personnel must
complete either the Independent Study courses identified in the Professional Development Series, or
the National Emergency Management Basic Academy delivered either by EMI or at a sponsored
SLTT, regional, or other designated location. Further information on the National Emergency
Management Basic Academy and the Emergency Management Professional Program (EMPP) can be
found at the EMPP page on EMI’s website. A complete list of Independent Study Program Courses
may be found at the Independent Study page on EMI’s website.
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In addition to training activities aligned to and addressed in the IPP, all EMPG Program-funded
personnel (including full- and part-time SLTT recipients and subrecipients) must complete the
following training requirements and record proof of completion:
1. NIMS Training, Independent Study (IS)-100 (any version), IS-200 (any version), IS-700 (any
version), and IS-800 (any version)2; and
2. Professional Development Series (PDS) or the EMPP Basic Academy courses listed in the
table below.
Table 10: PDS or EMPP Basic Academy Courses
PDS Basic Academy
Professional Development Series Basic Academy Pre-requisites and Courses
IS-120.a: An Introduction to Exercises IS-100 (any version): Introduction to the
Incident Command System
IS-230.d: Fundamentals of Emergency
Management
IS-700 (any version): National Incident
Management System (NIMS)-An Introduction
IS-235.b: Emergency Planning IS-800 (any version): National Response
Framework, An Introduction
IS-240.b: Leadership and Influence IS-230.d: Fundamentals of Emergency
Management
IS-241.b: Decision Making and Problem
Solving
E/L101: Foundations of Emergency
Management
IS-242.b: Effective Communication E/L102: Science of Disasters
IS-244.b: Developing and Managing
Volunteers
E/L103: Planning Emergency Operations
IS-244.b: Developing and Managing
Volunteers
E/L104: Exercise Design
IS-244.b: Developing and Managing
Volunteers
E/L105: Public Information & Warning
The EMI Basic Academy provides this foundational Emergency Management education. To ensure
the professional development of the emergency management workforce, the recipients must ensure
a routine capabilities assessment is accomplished and an IPP is developed and implemented.
2 NIMS training courses IS-100, IS-200, IS-700, and IS-800 only need to be taken once to fulfill requirements. Also,
previous versions of the IS courses are still considered as meeting the NIMS training requirement.
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12.8.5. TRAINING AND EXERCISE REPORTING
.All EMPG Program-funded exercise and training activities must be captured in the approved
EMPG Program Work Plan and should be included in the IPP. This includes training for which the
only expenses are for overtime and/or backfill costs associated with emergency management
personnel attending the training.
.
.
EMPG Program-funded exercise costs in the Work Plan can include costs to plan, conduct and
evaluate the exercise (e.g., planning, materials, props, contractual services for conducting the
exercise, AAR, and IP, etc.).
All EMPG Program-funded training activities must be reported quarterly. To simplify reporting, it is
recommended the recipient submit an updated Training Data Table from the EMPG Program
Work Plan Template as an attachment to the quarterly PPR. For those recipients who choose not
to use the EMPG Program Work Plan Template, the data and information found in the Training
Data Table must still be submitted (in any chosen format) as an attachment to the PPR.
.EMPG Program-funded personnel costs associated with exercises are not required in the EMPG
Program Work Plan Template for application or reporting purposes.
.
.
Recipients are encouraged to enter their exercise information into the Preparedness Toolkit.
Recipients must have a current multi-year IPP that identifies preparedness priorities and
activities. The current multi-year IPP must be submitted to hseep@fema.dhs.gov and the
Regional EMPG Program Manager and indicate which fiscal year’s funds were used (if applicable)
before Jan. 31 of each year.
.Submission of AAR/IPs to hseep@fema.dhs.gov and the Regional EMPG Program Manager must
take place within 90 days following completion of the single exercise or progressive series.
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took place
at the state, territorial, tribal, or regional level. Recipients are discouraged from submitting
AAR/IPs specific to local jurisdictions that reflect drills.
o If a state, territory, tribe, or local jurisdiction has experienced a major disaster and they would
like to request exemptions for a scheduled exercise, the recipient should send this request to
its assigned Regional EMPG Program Manager through the quarterly PPR. Exemptions will be
reviewed by the Region on a case-by-case basis.
.
.
Recipients can access a sample AAR/IP template at the Improvement Planning Templates page
on Preparedness Toolkit.
Recipients must report their NIMS implementation status of their jurisdiction and sub-
jurisdictions, including the training of personnel, in the applicable secondary NIMS assessment
portion of the URT as part of their THIRA/SPR submission.
.
.
Recipients must maintain proof of completion of training requirements. Recipients are
encouraged to use the OneResponder system to enter, track, and report training.
Training Information Reporting System (“Web Forms”): Web Forms is an electronic data
management system built to assist SAA TPOCs and federal agencies to submit non-NTED training
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courses for inclusion in the State/Federal-Sponsored Course Catalog. The information collected
is used in a two-step review process to ensure that the training programs adhere to the EMPG
Program’s intent, and the course content is sound and current. While reporting training activities
through Web Forms is not required under the EMPG Program, the system remains available and
can be accessed through the Web-Forms section of the FEMA National Preparedness Course
Catalog to support recipients in their own tracking of training deliveries.
12.9. Reviewing and Updating Planning Products
Based on the applicant’s current THIRA/SPR, capability levels, and resources, plans should be
reviewed on an annual basis to determine if they remain relevant or need to be updated. This review
should be based on a current THIRA/SPR and utilize information gathered during the capability
validation process. These reviews will provide a means to determine priorities, direct preparedness
actions, and calibrate goals and objectives.
12.10. Program Performance Reporting Requirements
12.10.1. STANDARDIZED PROGRAMMATIC REPORTING FOR THE EMERGENCY
MANAGEMENT PERFORMANCE GRANT PROGRAM
The EMPG Program Work Plan Template standardizes data collection, which enables improved
analysis and reporting. The EMPG Program Work Plan includes 10 components:
1. Grant Investment Strategy
2. Grant Activities Outline
3. Detailed Budget – Excluding M&A
4. Budget Narrative – Excluding M&A
5. Detailed Budget – M&A Only
6. Budget Narrative – M&A Only
7. EMPG Program Summary
8. Implementation Schedule
9. Training Data Table
10. Exercise Data Table
Although using the fiscal year’s EMPG Program Work Plan Template is not mandatory (see the EMPG
Program Work Plan template in the EMPG Program NOFO), baseline data on personnel, training, and
exercises, as well as the information included on the Grant Activities Outline and Implementation
Schedule, must be provided in the EMPG Program Work Plan at the time of application regardless of
the chosen work plan format.
The status of all EMPG Program-funded plans, training, and exercise activities, any risks that may
affect project progress or success, and updates to project schedules, must be reported quarterly as
part of the PPR. To facilitate reporting, recipients are encouraged to submit an updated
Implementation Schedule, Training Data Table, and Exercise Data Table from the EMPG Program
Work Plan Template as an attachment to the quarterly PPR. Recipients who choose not to use the
EMPG Program Work Plan Template must still provide the updated data and information included in
the Implementation Schedule, Training Data Table, and Exercise Data Table, but may use a different
format for reporting that information in their PPR submission.
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13. Abbreviations and Acronyms
Abbreviation
AAR
Definition
After-Action Report
ABA Architectural Barriers Act of 1968
Americans with Disabilities ActADA
ADDIE
AEL
Analysis, Design, Development, Implementation, and Evaluation
Authorized Equipment List
AHJ Authority Having Jurisdiction
AMSC
AMSP
ANSI
AOR
Area Maritime Security Committees
Area Maritime Security Plan
American National Standards Institute
Authorized Organizational Representative
Assistant Secretary for Preparedness and Response
Alcohol, Tabaco, Firearms, and Explosives
Build America, Buy America Act
ASPR
ATF
BABAA
BASE
BCRTP
BPETS
BSIR
CAD
Baseline Assessment for Security Enhancement
Business Continuity and Resumption of Trade Plans
Border Patrol Enforcement Tracking System
Biannual Strategy Implementation Report
Computer Assisted/Aided Dispatch
Corrective Action PlansCAP
CART
CBP
Computer Aided Real-Time Translation
Customs and Border Protection
CBRN
CBRNE
CDC
Chemical, Biological, Radiological, and Nuclear
Chemical, Biological, Radiological, Nuclear, Explosive
Centers for Disease Control and Prevention
Center for Domestic Preparedness
Continuity Guidance Circular
CDP
CGC
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Abbreviation
CISA
Definition
Cybersecurity and Infrastructure Security Agency
Customer-Owned and Managed
Communications Unit
COAM
COMU
CONOPS
COTP
CPG
Concept of Operations
Captain of the Port
Comprehensive Preparedness Guide
Commercial Service Providers
Continuing Training Grants
CSPs
CTG
CWMD
CY
Countering Weapons of Mass Destruction
Calendar Year
DAR Daily Activity Report
DEC Disaster Emergency Communications
Department of Homeland Security
Distribution Management
DHS
DM
DOJ Department of Justice
DOL Department of Labor
DOT Department of Transportation
Enhanced Cybersecurity Services
Explosive Detection Canine Teams
Environmental Planning and Historic Preservation
Emergency Management Agency
Emergency Management Assistance Compact
Emergency Management Accreditation Program
Emergency Management Institute
Enterprise Mobility Management
Electromagnetic Pulse
ECS
EDCTs
EHP
EMA
EMAC
EMAP
EMI
EMM
EMP
EMPG Emergency Management Performance Grant
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Abbreviation
EMPP
EMS
Definition
Emergency Management Professional Program
Emergency Medical Services
Emergency Medica Services for Children
Executive Order
EMSC
EO
EOP Emergency Operations Plan
Evolved Packet CoreEPC
FAR Federal Acquisition Regulation
Federal Bureau of Investigation
Federal Continuity Directive
Federal Emergency Management Agency
FEMA Grants Outcomes
FBI
FCD
FEMA
FEMA GO
FFR Federal Financial Report
FFRMS
FirstNet
FLR
Federal Flood Risk Management Standard
First Responder Network
First Line Review
FNARS
FRAGO
FRTS
FSP
FEMA National Radio System
Fragmentary Order
First Responder Training System
Facility Security Plan
FVA Freeboard Value Approach
Fiscal YearFY
GAAP
GAO
General Accepted Accounting Principles
Government Accountability Office
Government Furnished Information
Geographic Information Systems
Grant Programs Directorate
General Services Administration
GFI
GIS
GPD
GSA
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Abbreviation
HHS
HIDTA
HPP
HSA
HSEEP
HSGP
HSIN
I&A
Definition
Health and Human Services
High-Intensity Drug Trafficking Areas
Hospital Preparedness Program
Homeland Security Act of 2002
Homeland Security Exercise and Evaluation Program
Homeland Security Grant Program
Homeland Security Information Network
Intelligence and Analysis
IAPPG
IB
Individual Assistance Program and Policy Guide
Information Bulletin
IBSGP
IEDDA
IGSA
IJ
Intercity Bus Security Grant Program
International Explosive Detection Dog Association
Inter-Governmental Service Agreement
Investment Justification
IL Interagency Logistics
INA Immigration and Nationality Act
Interagency Operations Centers
Improvement Plan
IOC
IP
IPAWS
IPP
Integrated Public Alert and Warning System
Integrated Preparedness Plan
IPPWs
IPR
Integrated Preparedness Planning Workshops
Intercity Passenger Rail
IPT Integrated Planning Team
IRPF
ISE
Infrastructure Resilience Planning Framework
Information Sharing Environment
Information TechnologyIT
JES Joint Explanatory Statement
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Abbreviation
K-9
Definition
Canines
LCAT2
LEP
Logistics Capability Tool 2
Limited English Proficiency
LESO
LTE
Law Enforcement Support Office
Long-Term Evolution
M&A Management and Administration
Mobile Communications Office Vehicles
Maritime Domain Awareness
MCOV
MDA
MDM
MERS
MSAs
MSRAM
MTSA
NCSWIC
ND
Mobile Device Management
Mobile Emergency Response Support
Metropolitan Statistical Areas
Maritime Security Risk Analysis Model
Maritime Transportation Security Act
National Council of Statewide Interoperability Coordinators
Non-Disaster
NDAA
NDPC
NECP
NEDCTP
NEP
National Defense Authorization Act
National Domestic Preparedness Consortium
National Emergency Communications Plan
National Explosives Detection Canine Team Program
National Exercise Program
NGO Nongovernmental Organization
National Highway Traffic Safety Administration
National Information Exchange Model
National Incident Management System
National Institute of Standards and Technology
Notice of Funding Opportunity
NHTSA
NIEM
NIMS
NIST
NOFO
NPCA National Police Canine Association
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Abbreviation
NPD
Definition
National Preparedness Directorate
National Qualification SystemNQS
NRF National Response Framework
Nonprofit Security Grant Program
Nationwide Suspicious Activity Reporting Initiative
National Security Special Event
National Training and Education Division
National Telecommunications and Information Administration
Office of Inspector General
NSGP
NSI
NSSE
NTED
NTIA
OIG
OMB Office of Management and Budget
Office of National Continuity Programs
Operation Stonegarden
ONCP
OPSG
PAPPG
PARS
PDAT
PHEP
POC
Public Assistance Program and Policy Guide
Payment and Reporting Systems
Procurement Disaster Assistance Team
Public Health Emergency Preparedness
Point of Contact
PODs
POP
Points of Distribution
Period of Performance
PPD Presidential Policy Directive
PPE Personal Protective Equipment
Performance Progress ReportPPR
PRICE Act Personal Reimbursement for Intelligence Cooperation and
Enhancement of Homeland Security Act
PRMP
PSGP
PTT
Port Wide Risk Mitigation Plan
Port Security Grant Program
Push-to-Talk
RANs Radio Access Networks
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Abbreviation
RDPC
RECC
RECCWG
RECP
RF
Definition
Rural Domestic Preparedness Consortium
Regional Emergency Communications Coordinator
Regional Emergency Communications Coordination Working Groups
Regional Emergency Communications Plan
Radio Frequency
RFI Request for Information
RISS Regional Information Sharing Systems
Records Management SystemsRMS
R/Q Responsibility/Qualification
RRAP
RTSWGs
SAA
Regional Resilience Assessment Program
Regional Transportation Security Working Groups
State Administrative Agency
SAC Senior Advisory Committee
SAR Suspicious Activity Report
SAT Simplified Acquisition Threshold
SCIP Statewide Communication Interoperability Plan
State Disaster Recovery Coordinator
Schedule of Expenditures of Federal Awards
State Homeland Security Program
Statewide Interoperability Executive Committee
Statewide Interoperability Governance Board
Subscriber Identification Modules
State-Led Disaster Housing Task Force
State, Local, Tribal, and Territorial
Standard Operating Procedure
SDRC
SEFA
SHSP
SIEC
SIGB
SIMS
SLDHTF
SLTT
SOP
SPF Single Point of Failure
SPOC Single Point of Contact
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Abbreviation
SPR
Definition
Stakeholder Preparedness Review
Small Unmanned Aircraft Systems
Statewide Interoperability Coordinator
Technical Assistance
sUAS
SWIC
TA
the Goal
THIRA
THSGP
TICP
National Preparedness Goal
Threat and Hazard Identification and Risk Assessment
Tribal Homeland Security Grant Program
Tactical Interoperability Communications Plan
Transportation Infrastructure Security Branch
Training Point of Contact
TISB
TPOC
TPP Training Partner Program
TSA Transportation Security Administration
Terrorist Screening CenterTSC
TSGP
UAS
Transit Security Grant Program
Unmanned Aircraft System
UASI Urban Area Security Initiative
Urban Area Working GroupUAWG
UICC
URT
Universal Integrated Circuit Cards
Unified Reporting Tool
USB Universal Serial Bus
USBP
USCG
USPCA
USSS
VASP
VPN
United States Border Patrol
United States Coast Guard
U.S. Police Canine Association
United States Secret Service
Vulnerability Assessment and Security Plan
Virtual Private Network
VSP Vessel Security Plan
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ATTACHMENT B
ATTACHMENT C
Fiscal Year 2024
Emergency Management
Performance Grant (EMPG)
California Supplement to the
Federal Notice of Funding Opportunity
January 2025
SECTION 1—OVERVIEW………………………………………………………………………….1
Federal Program Announcement
Information Bulletins
Purpose of the California Supplement
Key Changes to the FY 2024 Emergency Management Performance Grant
Grant Management Memoranda
Eligible Subrecipients
Tribal Allocations
Subrecipient Allocations
Supplanting
Public/Private Organizations
Debarred/Suspended Parties
SECTION 2—FEDERAL CHANGES AND INITIATIVES .......................................................5
FY 2024 Program Priorities
National Campaigns and Programs
NIMS Implementation
Match Requirement
Management and Administration
Indirect Costs
Equipment Typing/Identification and Use
Equipment Maintenance and Sustainment
Small Unmanned Aircraft Systems
Telecommunications Equipment or Services Prohibitions
Emergency Operations Plans
Conflict of Interest
Integrated Preparedness Plan
Prohibited and Controlled Equipment
Build America, Buy America Act
SECTION 3—STATE CHANGES AND INITIATIVES.......................................................... 13
California Homeland Security Strategy Goals
“On Behalf Of”
Public Alert and Warning
SECTION 4—REQUIRED STATE APPLICATION COMPONENTS...................................... 14
Financial Management Forms Workbook
Subrecipient Grants Management Assessment
Application Attachments
Standard Assurances
Governing Body Resolution
Authorized Agent Information
SECTION 5—THE STATE APPLICATION PROCESS......................................................... 18
Application Submission
Late or Incomplete Application
EMPG Contact Information
Subaward Approval
SECTION 6—POST AWARD REQUIREMENTS ................................................................ 19
Payment Request Process
Semi-Annual Drawdown Requirements
Modifications
Training Requirements
Exercises, Improvement Plans and After Action Reporting
Procurement Standards and Written Procedures
Procurement Documentation
Procurement Thresholds
Noncompetitive Procurements
Environmental Planning and Historic Preservation
Construction and Renovation
Inventory Control and Property Management
Equipment Disposition
Performance Reporting
Extension Requests
Progress Reports on Grant Extensions
Monitoring
Failure to Submit Required Reports
Suspension/Termination
Closeout
Records Retention
ATTACHMENTS
A – FY 2024 EMPG Allocations
B – FY 2024 EMPG Timeline
C – FY 2024 EMPG Program Checklist
Section 1 ‒ Overview | 2024
Federal Program
Announcement
In April 2024, the U.S. Department of Homeland Security
(DHS)/Federal Emergency Management Agency (FEMA)
issued the Fiscal Year (FY) 2024 Emergency Management
Performance Grant (EMPG), Notice of Funding
Opportunity (NOFO) and FEMA Preparedness Grants
Manual.
Subrecipients must follow the programmatic requirements
in the NOFO, FEMA Preparedness Grants Manual, and the
applicable provisions of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for
Federal Awards located in Title 2, Code of Federal
Regulations (C.F.R.) Part 200.
Information Bulletins DHS issues Information Bulletins (IBs) to provide updates,
clarification, and new requirements throughout the life of
the grant.
Purpose of the
California Supplement
The FY 2024 EMPG California Supplement to the NOFO
(State Supplement) is intended to complement, rather
than replace, the NOFO and the FEMA Preparedness
Grants Manual. Applicants are highly encouraged to
thoroughly read the NOFO and the Preparedness Grants
Manual before referring to the State Supplement. The
State Supplement will emphasize differences between the
FY 2023 and FY 2024 EMPG and highlight additional
California policies and requirements applicable to the
FY 2024 EMPG.
Key Changes to the
FY 2024 EMPG
The National Priorities for the FY 2024 EMPG Program
continue to be:
• Equity
• Climate Resilience
• Readiness
A detailed description of allowable investments for each
national priority is included in the FY 2024 EMPG NOFO.
1
Section 1 ‒ Overview | 2024
Key Changes to the
FY 2024 EMPG Cont.
Phase 2 National Qualification System (NQS) for Calendar
Year 2024
Subrecipients shall have designed and approved
organizational qualification system procedures,
certification program, and credentialing standards for
incident workforce personnel in alignment with the NIMS
Guideline for the NQS.
Additional information regarding the NQS implementation
requirements and be found in the FEMA Preparedness
Grants Manual.
Public Alert and Warning Preparedness
Subrecipients shall include exercise objectives centered
on practicing and validating their plans and procedures
for sending emergency alerts to the public through the
FEMA Integrated Public Alert and Warning System.
Purchasing Under a FEMA Award: 2024 OMB Revisions:
The Office of Management and Budget (OMB) updated
parts of the OMB Guidance for Grants and Agreements in
Title 2 of the Code of Federal Regulations. These updates
will apply to FEMA awards with an award date on or after
October 1, 2024.
Updates to the federal procurement standards at 2 C.F.R.
§§ 200.317 – 200.327, which govern how FEMA award
recipients and subrecipients must conduct purchases
under a FEMA award.
FEMA will update its policy and guidance documents to
incorporate these revisions. For now, please refer to the
Purchasing Under a FEMA Award: 2024 OMB Revisions
Fact Sheet. Details on all the 2 C.F.R. revisions can be
found on the Federal Register’s Guidance for Federal
Financial Assistance webpage. For additional information
on the federal procurement standards, visit Contracting
with Federal Funds for Goods and Services Before, During
and After Disasters | FEMA.gov.
2
Section 1 ‒ Overview | 2024
Grants Management
Memoranda
Cal OES issues Grant Management Memoranda (GMMs)
which provide additional information and requirements
regarding EMPG funds.
Eligible Subrecipients
Tribal Allocations
Eligible Applicants, referred to as Subrecipients, include
Counties/Operational Areas (OAs), and federally-
recognized tribes located in California.
The NOFO strongly encourages Cal OES to provide EMPG
funds directly to tribes in California. To implement this
requirement, a special Competitive Funding Opportunity
will be issued to California’s federally-recognized tribes. All
Subrecipients are encouraged to coordinate with tribal
governments to ensure that tribal needs are considered in
their grant applications.
Subrecipient
Allocations
FY 2024 EMPG Subrecipient final allocations are included
in Attachment A.
Supplanting Grant funds must be used to supplement existing funds,
not replace (supplant) funds that have been
appropriated for the same purpose. Subrecipients may be
required to provide supporting documentation that
certifies a reduction in non-federal resources occurred for
reasons other than the receipt or expected receipt of
federal funds. Supplanting will result in the disallowance of
any activity associated with this improper use of federal
grant funds.
Public/Private
Organizations
Subrecipients may contract with any other public or private
organizations to perform eligible activities on approved
EMPG projects.
Debarred/
Suspended Parties
Subrecipients must not make or permit any award
(subaward or contract) at any tier, to any party, that is
debarred, suspended, or otherwise excluded from, or
ineligible for, participation in federal assistance programs.
Subrecipients must obtain documentation of eligibility prior
to making any subaward or contract funded by EMPG
funds, and must be prepared to present supporting
documentation to monitors/auditors.
3
Section 1 ‒ Overview | 2024
Debarred/
Suspended Parties
Cont.
Before entering into a Grant Subaward, the Subrecipient
must notify Cal OES if it knows if any of the principals under
the subaward fall under one or more of the four criteria
listed at 2 C.F.R. § 180.335. The rule also applies to
Subrecipients who pass-through funding to other local
entities.
If at any time after accepting a subaward, Subrecipients
learn that any of its principals fall under one or more of
the criteria listed at 2 C.F.R. § 180.335, immediate written
notice must be provided to Cal OES and all grant
activities halted until further instructions are received from
Cal OES. The rule also applies to subawards passed
through by Subrecipients to local entities.
4
Section 2 ‒ Federal Changes and Initiatives | 2024
FY 2024 Program
Priorities
DHS/FEMA annually publishes the National Preparedness
Report (NPR) to report national progress in building,
sustaining, and delivering the core capabilities outlined in
the goal of a secure and resilient nation. This analysis
provides a national perspective on critical preparedness
trends for whole community partners to use to inform
program priorities, allocate resources, and communicate
with stakeholders about issues of concern.
In developing applications for the FY 2024 EMPG Program,
Subrecipients should fund projects that address areas for
improvement as they relate to emergency management
capabilities, and projects that fall into the state, regional,
and national priority areas, including:
• Planning
• Operational Coordination
• Community Resilience
• Equity
• Climate Resilience
• Readiness
DHS/FEMA does not prescribe a minimum funding amount
for these priorities. However, Subrecipients are required to
support local, regional, state, and national efforts in
achieving the desired outcomes of these priorities.
National
Campaigns and
Programs
Whole Community Preparedness – Subrecipients should
engage with the whole community to advance individual
and community preparedness and to work as a nation to
build and sustain resilience. In doing so, Subrecipients are
encouraged to consider the needs of individuals with access
and functional needs and limited English proficiency in the
activities and projects funded by the grant.
Subrecipients should utilize established best practices for
whole community inclusion and engage with stakeholders to
advance individual and jurisdictional preparedness and
resilience. Subrecipients are encouraged to consider the
necessities of all Californians in the activities and projects
funded by the grant including children, seniors, individuals
with disabilities or access and functional needs,
5
Section 2 ‒ Federal Changes and Initiatives | 2024
National
Campaigns and
Programs Cont.
individuals with diverse culture and language use, individuals
with lower economic capacity, and other underserved
populations.
Active Shooter Preparedness – DHS has developed a
comprehensive Active Shooter Preparedness website, which
strives to enhance national preparedness through a whole-
community approach by providing the necessary products,
tools, and resources to help all stakeholders prepare for and
respond to an active shooter incident. Subrecipients are
encouraged to review the referenced active shooter
resources and evaluate their preparedness needs.
Soft Targets and Crowded Places – States, territories, Urban
Areas, and public and private sector partners are
encouraged to identify security gaps and build capabilities
that address security needs and challenges related to
protecting locations or environments that are easily
accessible to large numbers of people on a predictable or
semi-predictable basis that have limited security or
protective measures in place, including town centers,
shopping malls, open-air venues, outside hard
targets/venues perimeters, and other places of meeting and
gathering. For more information, please see DHS’s
Hometown Security Program.
Community Lifelines – FEMA created Community Lifelines to
reframe incident information and impacts using plain
language and unity of effort to enable the integration of
preparedness efforts, existing plans, and identifies unmet
needs to better anticipate response requirements. Additional
information may be found at the Community Lifelines
Implementation Toolkit website.
Strategic Framework for Countering Terrorism and Targeted
Violence – DHS adopted the DHS Strategic Framework for
Countering Terrorism and Targeted Violence, which explains
how the department will use the tools and expertise that
have protected and strengthened the country from foreign
terrorist organizations to address the evolving challenges of
today.
6
Section 2 ‒ Federal Changes and Initiatives | 2024
NIMS
Implementation
Prior to allocation of any federal preparedness awards,
Subrecipients must ensure and maintain adoption and
implementation of the National Incident Management
System (NIMS).
Match
Requirement
The FY 2024 EMPG requires a dollar-for-dollar match. This can
be cash or third-party in-kind contributions. Refer to
2 C.F.R. § 200.306 for specific details. Utilizing the Financial
Management Forms Workbook (FMFW) Match Tab,
Subrecipients will indicate the appropriate Solution Area and
Solution Area Subcategory that accurately represents the
specific activity(ies) and cost(s) used to meet the match
requirement under the FY 2024 EMPG subaward.
Contributions from the Subrecipient should be specifically
identified in the match description located on the FMFW
Match Tab. The non-federal match contributions have the
same eligibility requirements as the federal share. For
additional match guidance, see EMPG Clarifying Guidance
IB 458.
Management
and
Administration
The Management and Administration (M&A) allowance for
Subrecipients is set at a maximum of five percent for the
FY 2024 EMPG.
Indirect Costs Indirect costs are allowable under the FY 2024 EMPG Grant
Award.
Subrecipients with an indirect cost rate approved by their
cognizant federal agency may claim indirect costs based
on the established rate. Indirect costs claimed must be
calculated using the base approved in the indirect cost
negotiation agreement. A copy of the approved
negotiation agreement is required at the time of
application.
Indirect costs are in addition to the M&A allowance and
must be included in the Grant Award application as a
“Project” and reflected in the FMFW on the Indirect Cost
category ledger if being claimed under the award.
Indirect costs must be claimed no more than once annually,
and only at the end of the Subrecipient’s fiscal year. An
exception to this rule applies if there is a mid-year change to
the approved indirect cost rate; in this case, costs incurred
7
Section 2 ‒ Federal Changes and Initiatives | 2024
Indirect Costs
Cont.
to date must be claimed. At that time, a Grant Subaward
Modification reflecting the rate change must also be
submitted to Cal OES, along with a copy of the new Indirect
Cost Rate Agreement.
The FEMA Preparedness Grants Manual, published by FEMA,
states that State and local governments are not permitted to
use the de minimis rate. These costs are allowable only when
an exception is granted to the SAA by FEMA per 2 C.F.R.
Part 200, Appendix VII, paragraph D.1.b.
Equipment
Typing/
Identification
Allowable EMPG equipment is listed on the FEMA Authorized
Equipment List (AEL) website, and includes equipment from
the following AEL Sections:
and Use • Personal Protective Equipment (Category 1)
• Information Technology (Category 4)
• Cybersecurity Enhancement Equipment (Category 5)
• Interoperable Communication Equipment (Category 6)
• Detection Equipment (Category 7)
• Power Equipment (Category 10)
• Chemical, Biological, Radiological, Nuclear, and
Explosive (CBRNE) Reference Materials (Category 11)
• CBRNE Incident Response Vehicles (Category 12)
• Physical Security Enhancement Equipment (Category 14)
• CBRNE Logistical Support Equipment (Category 19)
• Other Authorized Equipment (Section 21)
Subrecipients should analyze the cost benefits of purchasing
versus leasing equipment, especially high cost items and
those subject to rapid technical advances.
Large equipment purchases must be identified and
explained. For more information regarding property
management standards for equipment, refer to 2 C.F.R.
including § 200.310, § 200.313, and § 200.316.
Subrecipients that allocate FY 2024 EMPG funds for
equipment are required to type and identify the capability
associated with that equipment. Also, per FEMA policy, the
purchase of weapons and weapon accessories are not
allowed with EMPG funds. Special rules apply to critical
emergency supplies; refer to the FEMA Preparedness Grants
Manual for additional information.
8
Section 2 ‒ Federal Changes and Initiatives | 2024
Equipment
Maintenance
and Sustainment
Use of EMPG funds for maintenance contracts, warranties,
repair or replacement costs, upgrades, and user fees are
allowable as described in FEMA Ibs 336 and 379, as well as
Grant Programs Directorate Policy FP 205-402-125-1.
Small
Unmanned
Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems
(SUAS) with FEMA grant funding must comply with FEMA
Policy 207-22-0002 and include copies of the policies and
procedures in place to safeguard individuals’ privacy, civil
rights, and civil liberties of the jurisdiction that will purchase,
take title to, or otherwise use the SUAS equipment.
Reference the Presidential Memorandum: Promoting
Economic Competitiveness While Safeguarding Privacy, Civil
Rights, and Civil Liberties in Domestic Use of Unmanned
Aircraft Systems for additional information. All SUAS purchase
requires FEMA approval prior to making purchase.
Telecommuni-
cations Equipment
or Services
Effective August 13, 2020, section 889(f)(2)-(3) of the
John S. McCain National Defense Authorization Act
for FY 2019 (NDAA), Pub. L. No. 115-232 (2018) and
2 C.F.R. § 200.216, 200.471, and Appendix II to 2 C.F.R.
Part 200 prohibits DHS/FEMA Recipients and Subrecipients
(including their contractors and subcontractors) from using
any FEMA funds under open or new awards for the following
covered telecommunications equipment or services:
Prohibitions
1) Telecommunications equipment produced by Huawei
Technologies Company or ZTE Corporation, (or any subsidiary
or affiliate of such entities);
2) For the purpose of public safety, security of government
facilities, physical security surveillance of critical infrastructure,
and other national security purposes, video surveillance and
telecommunications equipment produced by Hytera
Communications Corporation, Hangzhou Hikvision Digital
Technology Company, or Dahua Technology Company
(or any subsidiary or affiliate of such entities);
3) Telecommunications or video surveillance services provided
by such entities or using such equipment; or
4) Telecommunications or video surveillance equipment or
services produced or provided by an entity that the Secretary
of Defense, in consultation with the Director of National
Intelligence or the Director of the Federal Bureau of
Investigation, reasonably believes to be an entity owned or
9
Section 2 ‒ Federal Changes and Initiatives | 2024
Telecommuni-
cations Equipment
or Services
controlled by, or otherwise connected to, the People’s
Republic of China.
Additional guidance is available in FEMA Policy #405-143-1,
Prohibitions on Expending FEMA Award Funds for Covered
Telecommunications Equipment or Services.
Prohibitions Cont.
Emergency
Operations Plans
Subrecipients should update their Emergency Operations
Plan (EOP) at least once every two years to remain
compliant with the Comprehensive Preparedness Guide 101
version 2.0. Subrecipients are highly encouraged to include
an evacuation plan or annex as part of their EOP as well as
plans to exercise and validate the evacuation plan and
capabilities.
Conflict of
Interest
To eliminate and reduce the impact of conflicts of interest in
the subaward process, Subrecipients and pass-through
entities must follow their own policies and procedures
regarding the elimination or reduction of conflicts of interest
when making subawards. Subrecipients and pass-through
entities are also required to follow any applicable federal,
state, local, and tribal statutes or regulations governing
conflicts of interest in the making of subawards.
Subrecipients must disclose to their Grants Analyst, in writing,
any real or potential conflict of interest as defined by the
federal, state, local, or tribal statutes or regulations, which
may arise during the administration of the EMPG subaward
within five days of learning of the conflict of interest.
Integrated
Preparedness
Plan (IPP)
The IPP is a multi-year plan that identifies preparedness
priorities and activities. The IPP needs to be reviewed and
updated annually. For FY 2024 EMPG, the IPP needs to cover
a minimum of two years, from 2025 through 2026 to qualify as
a multi-year plan.
Prohibited and
Controlled
Equipment
Effective May 25, 2022, Executive Order (EO)14074,
Advancing Effective, Accountable Policing and Criminal
Justice Practices to Enhance Public Trust and Public Safety,
Section 12(a) directs the Department of Homeland Security
to review its grants, and consistent with applicable law,
prohibits the use of grant funding to purchase certain types
of military equipment by state, local, tribal, and territorial
(SLTT) law enforcement agencies (LEAs).
10
Section 2 ‒ Federal Changes and Initiatives | 2024
Prohibited and
Controlled
Equipment Cont.
For all awards issued on or after January 1, 2023, The policy
directly prohibits certain types of equipment outright
(prohibited equipment), whereas other types of equipment
may be controlled, or LEAs are required to submit
certifications prior to purchase.
Even if equipment is listed as controlled equipment and is
not outright prohibited, that does not automatically make it
allowable under a particular FEMA program. Recipients and
subrecipients should refer to applicable program guidance
or contact your Grants Analyst to determine if a particular
type of equipment is allowable under that program.
Additional information regarding Prohibited and Controlled
Equipment is available on FEMA Policy 207-22-0002.
Build America,
Buy America Act
(BABAA)
Under FEMA financial assistance programs, the BABAA
requirements apply to:
• New awards made on or after January 2, 2023,
• New funding that FEMA obligates to existing awards or
through renewal awards on or after January 2, 2023; and
• Infrastructure projects.
Funds provided under this program may not be used for a
project for infrastructure unless the iron and steel,
manufactured products, and construction materials used in
that infrastructure are produced in the United States.
The Buy America preference only applies to articles,
materials, and supplies that are consumed in, incorporated
into, or affixed to an infrastructure project. As such, it does
not apply to tools, equipment, and supplies, such as
temporary scaffolding, brought to the construction site and
removed at or before the completion of the infrastructure
project. Additionally, the Buy America preference does not
apply to equipment and furnishings, such as movable chairs,
desks, and portable computer equipment, that are used at
or within the finished infrastructure project but are not an
integral part of the structure or permanently affixed to the
infrastructure project.
11
Section 2 ‒ Federal Changes and Initiatives | 2024
Build America,
Buy America Act
(BABAA) Cont.
When necessary, Subrecipients may apply for a waiver from
these requirements. Additional information regarding the
BABAA can be found on FEMA’s website under
Buy America Preference.
12
Section 3 ‒ State Changes and Initiatives | 2024
California The State has prioritized the following California Homeland
Security Strategy Goals for the FY 2024 subawards:Homeland
Security Strategy
Goals 1. Enhance Information Collection, Analysis, and Sharing,
in Support of Public Safety Operations Across California;
2. Protect Critical Infrastructure and Key Resources from All
Threats and Hazards;
3. Strengthen Security and Preparedness Across
Cyberspace;
4. Strengthen Communications Capabilities Through
Planning, Governance, Technology, and Equipment;
5. Enhance Community Preparedness;
6. Enhance Multi-Jurisdictional/Inter-Jurisdictional All-
Hazards Incident Catastrophic Planning, Response, and
Recovery Capabilities;
7. Improve Medical and Health Capabilities;
8. Enhance Incident Recovery Capabilities;
9. Strengthen Food and Agriculture Preparedness;
10. Enhance Homeland Security Exercise, Evaluation, and
Training Programs; and
11. Protect Against Effects of Climate Change
“On Behalf Of”Cal OES may, in conjunction with local approval authorities,
designate funds “on behalf of” local entities who choose to
decline or fail to utilize their subaward in a timely manner.
Public Alert and
Warning
Cal OES encourages Subrecipients to consider use of this
funding to assist their jurisdiction’s alignment with the
State of California Alert and Warning Guidelines developed
pursuant to Senate Bill 833 of the 2018 Legislative Session.
13
Section 4 ‒ Required State Application Components | 2024
Financial The FY 2024 Cal OES FMFW includes:
Management
Forms
Workbook
Grant Subaward Face Sheet – Use the Grant Subaward
Face Sheet to apply for grant programs. The Grant
Subaward Face Sheet must be signed and submitted in
portrait format.
Authorized Agent Contact Information – Provides the
contact information of Authorized Agents (AA), delegated
via the Governing Body Resolution (GBR) or Signature
Authorization Form, including staff related to grant activities.
More than one person is recommended for designation as
the AA; in the absence of an AA, an alternate AA can sign
documents.
Project Ledger – The Project Ledger is used in the
application process to submit funding information and is
used for submitting cash requests and Grant Subaward
Modifications, and assists with completion of the Biannual
Strategy Implementation Report (BSIR).
Planning Tab – Provides detailed information on grant-
funded planning activities with a final product identified.
Organization Tab – Provides detailed information on grant-
funded organizational activities.
Equipment Tab – Detailed information must be provided
under the equipment description for all grant-funded
equipment. AEL numbers must be included for all items of
equipment. Always refer to the AEL for a list of allowable
equipment and conditions, if any.
Training Tab – Provides detailed information on grant-
funded training activities. All training activities must receive
Cal OES approval prior to starting the event, including a
Training Feedback number. The Training Request Form must
be submitted and approved to obtain a Training Feedback
number and should be submitted at least 30 days in
advance.
Exercise Tab – Provides detailed information on grant-
funded exercises.
14
Section 4 ‒ Required State Application Components | 2024
Financial M&A Tab – Provides information on grant-funded M&A
Management
Forms Workbook
Cont.
activities.
Indirect Costs Tab – Provides information on indirect costs.
Consultant-Contractor Tab – Provides detailed information
on grant-funded consultants, and documents
maintenance and sustainment contracts and activities on
grant eligible items/equipment.
Personnel Tab – Provides detailed information on grant-
funded personnel activities.
Match Tab – Provides detailed information on match
activities.
Authorized Agent Page – The Authorized Agent (AA) Page
must be submitted with the application, all cash requests,
and Grant Subaward Modifications. The AA page must
include a valid signature on file with Cal OES and the date.
Subrecipient
Grants
Management
Assessment
Per 2 C.F.R. § 200.332, Cal OES is required to evaluate the
risk of non-compliance with federal statutes, regulations,
and grant terms and conditions posed by each
Subrecipient of pass-through funding. The Subrecipient
Grants Management Assessment contains questions
related to a Subrecipient organization’s experience in the
management of federal grant awards. It is used to
determine, and provide, an appropriate level of technical
assistance, training, and grant oversight to Subrecipients
during the subaward. The questionnaire must be
completed and returned with the Subrecipient’s grant
application.
Application
Attachments
Indirect Cost Rate Agreement – If claiming indirect costs at
a federally-approved rate, please provide a copy of the
approved Indirect Cost Rate Agreement.
Federal Funding Accountability and Transparency Act
(FFATA) Financial Disclosure – Use the FFATA Financial
Disclosure to provide information required by the Federal
Funding Accountability and Transparency Act of 2006.
15
Section 4 ‒ Required State Application Components | 2024
Standard
Assurances
The Standard Assurances list the requirements to which the
Subrecipients will be held accountable. All Applicants will
be required to submit an electronic signed FY 2024
Standard Assurances as part of their FY 2024 EMPG
application. The required Standard Assurances can be
found only in PDF format on the Cal OES website.
NOTE: Self-created Standard Assurances will not be accepted.
Program
Standard
Assurances
Addendum
The Program Standard Assurances Addendum specifies
additional requirements that Subrecipients must meet.
All Subrecipients must submit an electronic signed Program
Standard Assurances Addendum as part of the FY 2024
EMPG application. The required Program Standard
Assurances Addendum can be found only in PDF format on
the Cal OES website.
Governing Body
Resolution
The GBR appoints AAs (identified by the individual’s name
or by a position title) to act on behalf of the governing
body and the Applicant by executing any actions
necessary for each application and subaward. All
Applicants are required to submit a copy of an approved
GBR with their application. Resolutions may be valid for up
to three grant years given the following:
• The resolution identifies the applicable grant program
(e.g., EMPG and/or HSGP);
• The resolution identifies the applicable grant years,
(e.g., FY 2023, FY 2024, FY 2025); and
• Adheres to any necessary elements required by local
protocols, rules, etc., if applicable.
Resolutions that only identify a single grant program will only be
valid for that single program. Resolutions that do not identify
applicable grant years will only be valid for the grant year in
which the resolution was submitted.
Authorized
Agent
Information
For each person or position appointed by the Governing
Body, identify the individual in the AA and Contact
Information page of the FMFW.
All changes in AA and contact information must be
provided to Cal OES in writing. If the GBR identifies the AA
by name, a new Resolution is needed when changes are
16
Section 4 ‒ Required State Application Components | 2024
Authorized
Agent
Information
Cont.
made. If the GBR identifies the AA by position and/or title,
changes may be made by submitting a request on the
entity’s letterhead, signed by an existing AA.
Cal OES will not accept signatures of an AA’s designee,
unless authorized by the Governing Body’s resolution. A
change to an AA’s designee must be submitted on
agency letterhead and signed by the AA, announcing the
change to their designee.
17
Section 5 ‒ The State Application Process | 2024
Application
Submission
Subrecipients must submit an electronic copy of their
completed FMFW to their Grants Analyst for review no later
than fourteen calendar days before the final Application
due date. After the application is approved, all electronic
copies of the FMFW, along with the required documents
must be emailed, with original or electronic signatures, by
the application due date. During the application process, if
it is determined all allocated funds cannot be expended
by the end of the period of performance, inform your
Grants Analyst as soon as possible. The completed
application documents should be received by Cal OES no
later than the date provided in the FY 2024 EMPG Timeline,
referenced as Attachment B.
Late or
Incomplete
Application
Late or incomplete applications may be denied. If an
application is incomplete, the Grants Analyst may request
additional information. Requests for late submission of
applications must be made in writing to the Grants Analyst
prior to the application due date. Cal OES has sole
discretion to accept or reject a late or incomplete grant
application.
EMPG Contact
Information
Subrecipient questions, comments, and correspondence
should be directed to:
California Governor’s Office of Emergency Services
ATTN: Grants Management (Building F)
Emergency Management Performance Grants Unit
3650 Schriever Avenue
Mather, CA 95655
Brittany Estep – Regions I & VI
Eman Hariri – Region II
Ronak Patel – Region III
(916) 364-4622
(916) 364-4689
(916) 845-8124
Lauren Swearengin – Regions IV & V (916) 845-8950
Subaward
Approval
Subrecipients will receive a formal notification of
subaward. Subaward letters must be signed and the signed
copy be returned to Cal OES within 20 calendar days.
Once the completed application along with the signed
subaward letter is received and approved, reimbursement
of eligible subaward expenditures may be requested using
the Cal OES FMFW.
18
Section 6 ‒ Post Award Requirements | 2024
Payment Request
Process
The EMPG is a reimbursement program. To request a cash
reimbursement of EMPG funds, Subrecipients must first
complete a payment request using the Cal OES FMFW,
returning it to the appropriate Grants Analyst. Subrecipients
who fail to follow the workbook instructions may experience
delays in processing the payment request.
Payments can only be made if the Subrecipient has an
approved application.
Semi-Annual
Drawdown
Requirements
All Subrecipients must report expenditures and request funds
at least semi-annually throughout the period of
performance. Semi-annual drawdowns should occur in
March and October of each calendar year following final
approval of the subaward application, with the exception of
the final reimbursement request, which must be submitted
within twenty calendar days after the end of the period of
performance.
Modifications Post award budget and scope modifications must be
requested using the Cal OES EMPG FMFW, signed by the
Subrecipient’s AA, and submitted to the Grants Analyst.
The Subrecipient may implement grant modification
activities, and incur associated expenses, only after
receiving written final approval of the modification from
Cal OES.
Subrecipients must provide a written justification with all
modification requests. The justification may be included in
the body of the e-mail transmitting the request, or a
document attached to the transmittal e-mail. Refer to
GMM 2018-17 for additional information regarding
modification requests.
19
Section 6 ‒ Post Award Requirements | 2024
Training
Requirements
Training activities supported with EMPG Program funds
should align to NPG core capabilities identified in each
Subrecipient’s Training and Exercise Plan. Subrecipients must
obtain a Training Feedback Number from Cal OES before
beginning any training activities. This includes project
components like travel to, materials for, or attendance in
training courses. Training Feedback Numbers should be
obtained no later than 30 days before the first day of the
training or related activities. Subrecipients must complete a
Training Request Form and submit it electronically to
Cal OES.
For more information on this or other training-related
inquiries, contact the Cal OES Training Branch at
(916) 845-8745 or Training@CalOES.ca.gov.
All EMPG-funded personnel, including M&A staff, and any
staff being used for match, must complete either the
Independent Study courses identified in the Professional
Development Series (PDS) or the National Emergency
Management Basic Academy. Final reimbursement of
personnel salaries will not be approved until all training
requirements have been met. Proof of completion of the
training requirements must be kept on file by the
Subrecipient and be made available for review upon
request. When seeking approval of non-DHS/FEMA
developed courses, course materials must be submitted with
the approval requests. Conditional approvals are not
offered.
EMPG TRAINING- PDS
IS 100 (any version), Introduction to Incident Command
System (ICS)
IS 200 (any version), ICS for Single Resources and Initial Action
Incident
IS 700 (any version), National Incident Management System,
An Introduction
IS 800 (any version), National Response Framework, An
Introduction
20
Section 6 ‒ Post Award Requirements | 2024
Training
Requirements
Cont.
IS 120.c An Introduction to Exercises
IS 230.e Fundamentals of Emergency Management
IS 235.c Emergency Planning
IS 240.c Leadership and Influence
IS 241.c Decision Making and Problem Solving
IS 242.c Effective Communication
IS 244.b Developing and Managing Volunteers
EMPG TRAINING-Basic Academy
IS 100 (any version), Introduction to the Incident Command
System (ICS)
IS 700 (any version), National Incident Management System
(NIMS), An Introduction
IS 800 (any version), National Response Framework, An
Introduction
IS 230.e Fundamentals of Emergency Management
E/L101, Foundations of Emergency Management
E/L102, Science of Disaster
E/L103, Planning Emergency Operations
E/L104, Exercise Design
E/L105, Public Information & Warning
In the event that any of the listed courses have been
updated and the required version is no longer available, it is
acceptable to take the updated course in place of the
listed course (i.e., since IS-120.a has been replaced with
IS-120.c, the latter may be used in the place of the original
course). The courses listed above are the minimum
accepted versions for FY 2024 EMPG.
21
Section 6 ‒ Post Award Requirements | 2024
Training
Requirements
Cont.
Training activities should align to a current IPP, developed
through an annual IPP Workshop. The training should help
build core capabilities and fill gaps identified in real-world
incidents and exercises. Further guidance can be found in
the HSEEP.
EMPG and non-EMPG -funded personnel may claim EMPG
funds for tuition/travel costs for EMPG eligible trainings,
provided that the purpose of the travel and training is to
accomplish the objectives of the grant.
Exercises,Subrecipients should engage stakeholders to identify long-
term training and exercise priorities. These priorities should
address capability targets and gaps identified through a
Threat and Hazard Identification and Risk Assessment, real-
world events, previous exercises, and national areas for
improvement identified in the NPR.
Improvement
Plans and After
Action Reporting
Subrecipients must report on all exercises conducted with
EMPG grant funds. An After Action Report
(AAR)/Improvement Plan (IP) or Summary Report (for
Seminars, Drills & Workshops) must be completed and
submitted to Cal OES within 90 days after the
exercise/seminar/drill/workshop is conducted.
It is acceptable to submit an Exercise Summary Report for
Seminars, drills, and Workshops in lieu of a full AAR/IP.
AAR/Ips and Summary Reports should be e-mailed to:
• hseep@fema.dhs.gov
• exercise@caloes.ca.gov
• Your Grants Analyst
All EMPG-funded personnel, including M&A staff and any
staff being used for match, must participate in no less than
two exercises between July 1, 2024, and June 30, 2026. These
exercises must align to one of the priority areas via the
Performance Reports. The Great Shakeout drop, cover, and
hold drill is ineligible for the purpose of the two exercise
requirement.
Final reimbursement of personnel salaries will not be
approved until all exercise requirements have been met.
22
Section 6 ‒ Post Award Requirements | 2024
Exercises,Exercises used to meet this requirement during one period of
performance cannot be used to meet the requirement in
another. Extensions to the grant do not apply to this
requirement or its due date. There is no specific requirement
for level of participation in the exercises and the exercises
can be of any type, provided they are related to the
subrecipient’s identified long-term training and exercises
priorities. Proof of completion of the exercise requirements
must be kept on file by the Subrecipient and be made
available for review upon request.
Improvement
Plans and After
Action Reporting
Cont.
For exercise-related issues and/or questions, email the
Cal OES Exercise Team at exercise@caloes.ca.gov.
Exercise costs will not be considered for reimbursement until
an AAR/IP is received by Cal OES.
Procurement
Standards and
Written
Subrecipients must conduct procurement using documented
local government procurement procedures, or the federal
procurement standards found in 2 C.F.R. Part 200, whichever
are more strict. Subrecipients must also have written conflict of
interest policies governing the actions of its employees
engaged in the selection, award and administration of
contracts, including disciplinary actions for violations of such
standards.
Procedures
Procurement
Documentation
Non-federal entities, other than states and territories, are
required to maintain and retain records sufficient to detail
the history of procurements, covering at least the rationale
for the procurement method, contract type, contractor
selection or rejection, and the basis for the contract price.
For any cost to be allowable, it must be adequately
documented. Examples of the types of documents that
would meet this requirement include, but are not limited to:
• Solicitation documentation, such as requests for quotes,
invitations for bids, or requests for proposals;
• Responses to solicitations, such as quotes, bids, or
proposals;
• Pre-solicitation independent cost estimates and
Post-solicitation cost/price analyses on file for review by
federal personnel, if applicable;
• Contract documents and amendments;
23
Section 6 ‒ Post Award Requirements | 2024
Procurement
Documentation
Cont.
• Documents demonstrating inclusion of required contract
provisions, and
• Other documents required by federal regulations
applicable at the time the grant was awarded to the
Subrecipient.
Procurement
Thresholds
Under 2 C.F.R. Part 200, procurement thresholds are defined as
follows:
• Micro-purchase threshold: This is the maximum amount for
which purchases can be made without requiring competitive
quotes or formal procurement processes, provided the price is
reasonable. The micro-purchase threshold is set at $10,000.
• Simplified acquisition threshold: This sets the maximum amount
for which federal procurement procedures may be simplified.
The threshold is $250,000. For purchases at or below this
amount, subrecipients may use streamlined methods, such as
obtaining competitive price or rate quotations from an
adequate number of qualified sources. Purchases exceeding
$250,000 require more formal procurement procedures,
including sealed bids or competitive proposals.
Subrecipients must adhere to these thresholds and, in cases
of conflict between local procurement procedures and
federal requirements, must apply the more stringent
threshold.
Noncompetitive
Procurements
All noncompetitive procurements exceeding the simplified
acquisition threshold require Cal OES prior written approval to
be eligible for reimbursement. This method of procurement
must be approved by the local Purchasing Agent prior to
submitting a request for Cal OES approval. A copy of the
Purchasing Agent’s approval must be included with the
Cal OES Request for Noncompetitive Procurement
Authorization form. Cal OES may request additional
documentation that supports the procurement effort.
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Section 6 ‒ Post Award Requirements | 2024
Environmental
Planning and
Historic
DHS/FEMA is required to ensure all activities and programs
that are funded by the agency comply with federal
Environmental Planning and Historic Preservation (EHP)
regulations. Subrecipients proposing projects or activities
(including, but not limited to, training, exercises, the
installation of equipment, and construction or renovation
projects) that have the potential to impact the environment
or a historic structure must participate in the EHP review
process. EHP Screening Memos must include detailed
project information, explain the goals and objectives of the
proposed project, and include supporting documentation.
Preservation
DHS/FEMA may also require that the Subrecipient provide a
confidential California Historical Resources Information
System (CHRIS) report in addition to the EHP Screening Form.
Determination on the necessity of a CHRIS report is based
upon information disclosed on the EHP Screening Form.
Grants Analysts will provide additional instructions should this
report be required.
EHP requests should be submitted to Cal OES as early as
possible. All projects/activities triggering EHP must receive
DHS/FEMA written approval prior to commencement of the
funded activity.
Updated information may be referenced in the FEMA GPD
EHP Policy Guidance.
Construction and
Renovation
When applying for construction activity at the time of
application, including communications towers, Subrecipients
must submit evidence of approved zoning ordinances,
architectural plans, any other locally required planning
permits, and a notice of federal interest. Additionally,
Subrecipients are required to submit a SF-424C Budget and
Budget Detail that cites the project costs. Communication
tower construction requests also require evidence that the
Federal Communications Commission’s Section 106 review
process has been completed.
Subrecipients using funds for construction projects must
comply with the Davis-Bacon Act. Subrecipients must ensure
that their contractors or subcontractors for construction
projects pay workers no less than the prevailing wages for
laborers and mechanics employed on projects of a
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Section 6 ‒ Post Award Requirements | 2024
Construction and
Renovation Cont.
character like the contract work in the civil subdivision of the
state in which the work is to be performed.
Written approval for construction must be provided by
DHS/FEMA prior to the use of any EMPG funds for construction
or renovation. No construction activities (including site
preparation, utility installations, and any groundbreaking
activities) or equipment installations on existing structures,
may begin until the EHP review process is complete.
Inventory Control
and Property
Management
Subrecipients must use standardized resource management
concepts for resource typing and credentialing, in addition
to maintaining an inventory by which to facilitate the
effective identification, dispatch, deployment, tracking and
recovery of resources.
Subrecipients must have an effective inventory
management system, to include:
• Property records that document description, serial/ID
number, fund source, title information, acquisition date,
cost, federal cost share, location, use, condition, and
ultimate disposition;
• A physical inventory conducted at least every two years;
• A control system to prevent loss, damage, and theft of
grant purchased equipment and supplies; and
• Adequate maintenance procedures must be developed
to keep the property in good condition.
Equipment
Disposition
When original or replacement equipment acquired under
the EMPG is no longer needed for program activities, the
Subrecipient must contact their Grants Analyst to request
disposition instructions. See 2 C.F.R. § 200.313(e).
Performance
Reporting
BSIR – Subrecipients must complete a BSIR each Winter and
Summer using the DHS/FEMA Grants Reporting Tool (GRT) for
the duration of the subaward period of performance or until
all grant activities are completed and the subaward is
formally closed by Cal OES. Failure to submit a BSIR could
result in subaward reduction, suspension, or termination.
Access to the BSIR may be obtained through the GRT. To
create a new account, click the link that reads, “Register for
an account” and follow the instructions provided. The
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Section 6 ‒ Post Award Requirements | 2024
Performance
Reporting Cont.
Subrecipient will be required to ensure up-to-date project
information is entered. The Project Ledger in the FMFW may
assist with the BSIR data entry process. For additional
assistance with the GRT, contact the appropriate Grants
Analyst.
Quarterly Performance Reports – Subrecipients must prepare
and submit Performance Reports to the State for the
duration of the subaward period of performance, or until all
grant activities are completed and the subaward is formally
closed by Cal OES. The quarterly reports must include the
progress made on identified activities, as well as other
required information. Failure to submit a quarterly
Performance Report could result in subaward reduction,
suspension, or termination.
In order to ensure that mandated performance metrics and
other data required under the subaward is reported
accurately, all EMPG Performance Reports must be
submitted electronically, via email, to their Cal OES Grants
Analyst for review and vetting. Electronic documents
submitted for Cal OES review and vetting should be
submitted as soon as possible, but no later than, seven
calendar days before the identified due date(s) associated
with the Performance Report. Submission of the electronic
copy is only to occur after their Cal OES Grants Analyst’s
review has concluded and the Subrecipient is directed by
their Cal OES Grants Analyst to submit the signed electronic
copy.
Extension
Requests
Extensions to the initial period of performance identified in
the subaward will only be considered through formal, written
requests to the Subrecipient’s Grants Analyst. Upon receipt
of the extension request, Cal OES will:
1. Verify compliance with performance reporting
requirements by confirming the Subrecipient has
submitted all necessary performance reports;
2. Confirm the Subrecipient has provided sufficient
justification for the request; and
3. If applicable, confirm the Subrecipient has demonstrated
sufficient progress in past situations where an extension
was authorized by Cal OES.
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Section 6 ‒ Post Award Requirements | 2024
Extension
Requests Cont.
Extension requests will be granted only due to compelling
legal, policy, or operational challenges, must be project
specific, and will only be considered for the following
reasons:
1. Contractual commitments with vendors that prevent
completion of the project within the period of
performance;
2. The project must undergo a complex environmental
review which cannot be completed within this timeframe;
3. Projects are long-term by design and therefore;
acceleration would compromise core programmatic
goals; and
4. Where other special circumstances exist.
To be considered, extension requests must be received no
later than 60 days prior to the end of the Subrecipient’s
period of performance and must contain specific and
compelling justifications as to why an extension is required.
All extension requests must address the following:
1. Grant program, fiscal year, and award number;
2. Reason for delay;
3. Current status of the activity/activities;
4. Approved period of performance termination date and
new project completion date;
5. Amount of funds drawn down to date;
6. Remaining available funds, both federal and non-federal;
7. Budget outlining how remaining federal and non-federal
funds will be expended;
8. Plan for completion, including milestones and timeframes
for each milestone and the position/person responsible
for implementing the plan for completion; and
9. Certification that the activity/activities will be completed
within the extended period of performance without any
modification to the original Statement of Work.
General questions regarding extension requirements and the
Extension Request form should be directed to your Grants
Analyst. Subrecipients are expected to complete all grant-
funded personnel activity by the end of the subaward
period of performance. Indirect Cost project may not be
extended.
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Section 6 ‒ Post Award Requirements | 2024
Progress Reports
on Grant
Extensions
All Subrecipients that receive Cal OES approval to extend
their FY 2024 grant subaward period of performance will be
required to submit progress reports indicating completed
and future project milestones on all extended projects.
Progress reports must be submitted electronically to their
Grants Analyst. Deadlines for the submission of progress
reports will be established at the time of extension approval.
Monitoring Cal OES Grants Monitoring actively monitors Subrecipients,
through day-to-day communications, programmatic site
visits, and desk and on-site compliance assessments. The
purpose of the compliance assessment is to ensure
Subrecipients are in compliance with applicable state and
federal regulations, grant guidelines, and programmatic
requirements. Monitoring activities may include, but are not
limited to:
• Verifying that entries recorded on the FMFW categories
are properly supported with source documentation;
• Eligibility of and support for expenditures, typically
covering two to three years of data;
• Comparing actual Subrecipient activities to those
approved in the grant application and subsequent
modifications, including the review of timesheets and
invoices as applicable;
• Procurements and contracts;
• Ensuring equipment lists are properly maintained and
physical inventories are conducted;
• Ensuring advances have been disbursed in accordance
with applicable guidelines; and
• Confirming compliance with:
o Standard Assurances, and
o Information provided on performance reports and
payment requests
NOTE: It is the responsibility of all Subrecipients that pass
down grant funds to other entities, to maintain and utilize a
formal process to monitor the grant activities of their
subawards. This requirement includes, but is not limited to,
on-site verification of grant activities, as required. It is
common for Subrecipients to receive findings in a
programmatic site visit or compliance assessment, which
29
Section 6 ‒ Post Award Requirements | 2024
Monitoring Cont.require a Corrective Action Plan (CAP) to be submitted by
Subrecipients. Those Subrecipients who fail to submit a CAP,
as required, shall have a “hold” placed on any future
reimbursements until the “finding”or an “advisory” is
resolved.
Failure to Submit
Required Reports
Periodic reporting is required by the grant. Subrecipients who
miss a single reporting due date may receive a letter
addressed to their Board of Supervisors informing them of the
failure to report. County OAs and tribes who fail to report
twice in a row may have subsequent awards reduced by
ten percent until timely reporting is reestablished.
Suspension/
Termination
Cal OES may suspend or terminate grant funding, in whole or
in part, or other measures may be imposed for any of the
following reasons:
• Failure to submit required reports.
• Failure to expend funds in a timely manner consistent with
the grant milestones, guidance, and assurances.
• Failure to comply with the requirements or statutory
progress toward the goals or objectives of federal or state
law.
• Failure to make satisfactory progress toward the goals or
objectives set forth in the Subrecipient application.
• Failure to follow Grant Subaward requirements or Special
Conditions.
• Proposing or implementing substantial plan changes to
the extent that, if originally submitted, the application
would not have been selected for funding.
• False certification in the application or other document.
• Failure to adequately manage, monitor, or direct the
grant funding activities of their Subrecipients.
Before taking action, Cal OES will provide the Subrecipient
reasonable notice of intent to impose corrective measures
and will make every effort to informally resolve the problem.
Closeout Cal OES will close-out Subrecipient awards when it
determines all applicable administrative actions and all
required work of the federal award have been completed.
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Section 6 ‒ Post Award Requirements | 2024
Closeout Cont.Subawards will be closed after:
• Receiving any applicable Subrecipient Performance
Report indicating all approved work has been
completed, and all funds have been distributed;
• All funds have been requested and reimbursed, or
disencumbered;
• 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.
Documents related to equipment purchased must be
retained for three years after it has been disposed, per
2 CFR 200.313.
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
31
Section 6 ‒ Post Award Requirements | 2024
Records associated with the unsupported activities.
Retention Cont.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.
32
Attachment A ‒ FY 2024 EMPG Allocations | 2024
Operational Area Total Award Operational Area Total Award
ALAMEDA
ALPINE
AMADOR
BUTTE
CALAVERAS
COLUSA
CONTRA COSTA
DEL NORTE
EL DORADO
FRESNO
409,218 PLACER 196,272
128,300
548,711
398,146
136,406
504,038
692,978
269,472
261,559
173,350
253,134
201,528
452,624
170,520
156,169
125,555
132,565
202,082
208,062
219,833
142,188
136,165
127,768
207,522
134,483
268,421
163,369
139,361
188,021
125,205 PLUMAS
131,920 RIVERSIDE
160,713 SACRAMENTO
132,798 SAN BENITO
128,781 SAN BERNARDINO
324,355 SAN DIEGO
129,621 SAN FRANCISCO
157,831 SAN JOAQUIN
300,704 SAN LUIS OBISPO
129,975 SAN MATEO
148,285 SANTA BARBARA
156,176 SANTA CLARA
128,282 SANTA CRUZ
282,635 SHASTA
151,232 SIERRA
136,604 SISKIYOU
129,912 SOLANO
1,820,586 SONOMA
152,472 STANISLAUS
168,940 SUTTER
127,942 TEHAMA
140,488 TRINITY
174,565 TULARE
126,481 TUOLUMNE
127,286 VENTURA
199,757 YOLO
148,388 YUBA
142,496 TRIBAL NATIONS
669,946
GLENN
HUMBOLDT
IMPERIAL
INYO
KERN
KINGS
LAKE
LASSEN
LOS ANGELES
MADERA
MARIN
MARIPOSA
MENDOCINO
MERCED
MODOC
MONO
MONTEREY
NAPA
NEVADA
ORANGE
Total 14,202,196
Attachment B ‒ FY 2024 EMPG Timeline | 2024
DHS Announcement of FY 2024 EMPG NOFO April 16, 2024
June 24, 2024
July 1, 2024
Cal OES Application due to DHS
Subrecipient period of performance begins
DHS/FEMA Award to California
Integrated Preparedness Plan (IPP) due
Notification of Subrecipient Award
Subrecipient Workshops
September 25, 2024
September 30, 2024
October 28, 2024
October 2024
FY 2024 California Supplement release January 2025
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2024 – 9/30/2024
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2024 – 12/31/2024
Subrecipient Final Applications due to Cal OES
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2023 – 3/31/2025
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2024 – 6/30/2025
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2024 – 9/30/2025
All FY 2024 EMPG EHP-related documents must
be received by Grants Analyst
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2024 – 12/31/2025
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2023 – 3/31/2026
Subrecipient period of performance ends
Submission of the FY 2024 EMPG Performance
Report for the period of 7/1/2023 – 6/30/2026
Final Request for Reimbursement due
October 14, 2024
January 14, 2025
February 10, 2025
April 14, 2025
July 14, 2025
October 14, 2025
December 31, 2025
January 14, 2026
April 14, 2026
June 30, 2026
July 14, 2026
Within 20 calendar days of
the subaward expiration date
Cal OES’s period of performance ends September 30, 2026
Attachment C ‒ FY 2024 EMPG Program Checklist | 2024
Subrecipient:FIPS#:
Grants Analyst:
Financial Management Forms Workbook:
Grant Subaward Face Sheet
Authorized Agent and Contact Tab
Project Ledger Tab
Planning Tab
Organization Tab
Equipment Tab
Training Tab
Exercise Tab
Management and Administration Tab
Indirect Cost Tab
Consultant-Contractor Tab
Personnel Tab
Match Tab
Indirect Cost Rate Summary (If Applicable)
Authorized Agent Sheet
Required Documents:
Counter-signed Award Letter
EHP Screening Form (If Applicable)
FFATA Financial Disclosure
Governing Body Resolution
Subrecipient Grants Management Assessment form
2024 EMPG Standard Assurances
Program Standard Assurances Addendum
Indirect Cost Rate Agreement (If Applicable)
ATTACHMENT D
FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
As the duly authorized representative of the Applicant, I hereby certify that the
Applicant has the legal authority to apply for federal assistance and the institutional,
managerial, and financial capability (including funds sufficient to pay any non-federal
share of project cost) to ensure proper planning, management, and completion of the
project described in this application, within prescribed timelines.
The requirements outlined in these assurances apply to Applicant and any of its
subrecipients.
I further acknowledge that the Applicant is responsible for reviewing and adhering to all
requirements within the:
(a) Applicable Federal Regulations (see below);
(b) Federal Program Notice of Funding Opportunity (NOFO);
(c) Federal Preparedness Grants Manual;
(d) California Supplement to the NOFO; and
(e) Federal and State Grant Program Guidelines.
Federal Regulations
Government cost principles, uniform administrative requirements, and audit
requirements for federal grant programs are set forth in Title 2, Part 200 of the Code of
Federal Regulations (C.F.R.) and adopted by the Department of Homeland Security
(DHS) at 2 C.F.R. Part 3002.10. Updates are issued by the Office of Management and
Budget (OMB) and can be found at http://www.whitehouse.gov/omb/.
In the event Cal OES determines that changes are necessary to the subaward after a
subaward has been made, including changes to period of performance or terms and
conditions, Applicants will be notified of the changes in writing. Once notification has
been made, any subsequent request for funds will indicate Applicant acceptance of
the changes to the subaward.
State and federal grant award requirements are set forth below. The Applicant hereby
agrees to comply with the following:
1. Proof of Authority
The Applicant will obtain proof of authority from the city council, governing board, or
authorized body in support of this project. This written authorization must specify that
the Applicant and the city council, governing board, or authorized body agree:
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FY 2024 Standard Assurances For Cal OES Federal
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(a) To provide all matching funds required for the grant project and that any cash
match will be appropriated as required;
(b) Any liability arising out of the performance of this agreement shall be the
responsibility of the Applicant and the city council, governing board, or
authorized body;
(c) Grant funds shall not be used to supplant expenditures controlled by the city
council, governing board, or authorized body;
(d) The Applicant is authorized by the city council, governing board, or authorized
body to apply for federal assistance, and the institutional, managerial and
financial capability (including funds sufficient to pay the non-federal share of
project cost, if any) to ensure proper planning, management and completion
of the project described in this application; and
(e) The official executing this agreement is authorized by the Applicant.
This Proof of Authority must be maintained on file and readily available upon request.
2. Period of Performance
The period of performance is specified in the Award. The Applicant is only authorized
to perform allowable activities approved under the award, within the period of
performance.
3. Lobbying and Political Activities
As required by Section 1352, Title 31 of the United States Code (U.S.C.), for persons
entering into a contract, grant, loan, or cooperative agreement from an agency or
requests or receives from an agency a commitment providing for the United States to
insure or guarantee a loan, the Applicant certifies that:
(a) No federal appropriated funds have been paid or will be paid, by or on behalf
of the undersigned, to any person for influencing or attempting to influence an
officer or employee of an agency, a Member of Congress, an officer or
employee of Congress, or an employee of a Member of Congress in
connection with the awarding of any Federal contract, the making of any
federal grant, the making of any federal loan, the entering into of any
cooperative agreement, and the extension, continuation, renewal,
amendment, or modification of any federal contract, grant, loan, or
cooperative agreement.
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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
(b) If any funds other than federal appropriated funds have been paid or will be
paid to any person for influencing or attempting to influence an officer or
employee of any agency, a Member of Congress, an officer or employee of
Congress, or an employee of a Member of Congress in connection with this
federal contract, grant, loan, or cooperative agreement, the undersigned shall
complete and submit Standard Form-LLL, “Disclosure Form to Report
Lobbying”, in accordance with its instructions.
(c) The Applicant shall require that the language of this certification be included in
the award documents for all subawards at all tiers (including subcontracts,
subgrants, and contracts under grants, loans, and cooperative agreements)
and that all subrecipients shall certify and discloseaccordingly.
The Applicant will also comply with provisions of the Hatch Act (5 U.S.C. §§ 1501- 1508
and §§ 7324-7328) which limit the political activities of employees whose principal
employment activities are funded in whole or in part with federal funds.
Finally, the Applicant agrees that federal funds will not be used, directly or indirectly,
to support the enactment, repeal, modification or adoption of any law, regulation, or
policy without the express written approval from the California Governor’s Office of
Emergency Services (Cal OES) or the federal awarding agency.
4. Debarment and Suspension
As required by Executive Orders 12549 and 12689, and 2 C.F.R. § 200.214 and codified
in 2 C.F.R. Part 180, Debarment and Suspension, the Applicant will provide protection
against waste, fraud, and abuse by debarring or suspending those persons deemed
irresponsible in their dealings with the federal government. The Applicant certifies that
it and its subrecipients:
(a) Are not presently debarred, suspended, proposed for debarment, declared
ineligible, or voluntarily excluded from covered transactions by any federal
department or agency;
(b) Have not within a three-year period preceding this application been convicted
of or had a civil judgment rendered against them for commission of fraud or
a criminal offense in connection with obtaining, attempting to obtain, or
performing a public (federal, state, or local) transaction or contract under a
public transaction; violation of federal or state antitrust statutes or commission
of embezzlement, theft, forgery, bribery, falsification or destruction of records,
making false statements, or receiving stolen property;
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FY 2024 Standard Assurances For Cal OES Federal
Non-Disaster Preparedness Grant Programs
(c) Are not presently indicted for or otherwise criminally or civilly charged by a
governmental entity (federal, state, or local) with commission of any of the
offenses enumerated in paragraph (4)(b) of this certification; and
(d) Have not within a three-year period preceding this application had one or
more public transaction (federal, state, or local) terminated for cause or
default.
Where the Applicant is unable to certify to any of the statements in this certification,
he or she shall attach an explanation to this application.
5. Non-Discrimination and Equal Employment Opportunity
The Applicant will comply with all state and federal statutes relating to non-
discrimination, including:
(a) Title VI of the Civil Rights Act of 1964 (Public Law (P.L.) 88-352 and
42 U.S.C. § 2000d et. seq.) which prohibits discrimination on the basis of race,
color, or national origin and requires that recipients of federal financial
assistance take reasonable steps to provide meaningful access to persons
with limited English proficiency (LEP) to their programs and services;
(b) Title IX of the Education Amendments of 1972, (20 U.S.C. §§ 1681-1683, and
1685-1686), which prohibits discrimination on the basis of sex in any federally
funded educational program or activity;
(c) Section 504 of the Rehabilitation Act of 1973, (29 U.S.C. § 794), which prohibits
discrimination against those with disabilities or access and functional needs;
(d) Americans with Disabilities Act (ADA) of 1990 (42 U.S.C. § 12101et seq.), which
prohibits discrimination on the basis of disability and requires buildings and
structures be accessible to those with disabilities and access and functional
needs;
(e) Age Discrimination Act of 1975, (42 U.S.C. §§ 6101-6107), whichprohibits
discrimination on the basis of age;
(f) Public Health Service Act of 1912 (42 U.S.C. §§ 290 dd—2), relating to
confidentiality of patient records regarding substance abuse treatment;
(g) Title VIII of the Civil Rights Act of 1968 (42 U.S.C. § 3601 et seq.), relating to
nondiscrimination in the sale, rental or financing of housing as implemented by
the Department of Housing and Urban Development at 24 C.F.R. Part100. The
prohibition on disability discrimination includes the requirement that new
multifamily housing with four or more dwelling units — i.e., the public and
common use areas and individual apartment units (all units in buildings with
elevators and ground-floor units in buildings without elevators) — be designed
and constructed with certain accessible features (See 24 C.F.R. § 100.201);
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FY 2024 Standard Assurances For Cal OES Federal
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(h) Executive Order 11246, which prohibits federal contractors and federally
assisted construction contractors and subcontractors, who do over $10,000 in
Government business in one year from discriminating in employmentdecisions
on the basis of race, color, religion, sex, sexual orientation, gender
identification or national origin;
(i) Executive Order 11375, which bans discrimination on the basis of race, color,
religion, sex, sexual orientation, gender identification, or national origin in hiring
and employment in both the United States federal workforce and on the part
of government contractors;
(j) California Public Contract Code § 10295.3, which prohibits discrimination based
on domestic partnerships and those in same sex marriages;
(k) DHS policy to ensure the equal treatment of faith-based organizations, under
which the Applicant must comply with equal treatment policies and
requirements contained in
6 C.F.R. Part 19;
(l) The California’s Fair Employment and Housing Act (FEHA) (California
Government Code §§12940-12957), as applicable. FEHA prohibits harassment
and discrimination in employment because of ancestry, familial status, race,
color, religious creed (including religious dress and grooming practices), sex
(which includes pregnancy, childbirth, breastfeeding and medical conditions
related to pregnancy, childbirth or breastfeeding), gender, gender identity,
gender expression, sexual orientation, marital status, national origin, ancestry,
mental and physical disability, genetic information, medical condition, age,
pregnancy, denial of medical and family care leave, or pregnancy disability
leave, military and veteran status, and/or retaliation for protesting illegal
discrimination related to one of these categories, or for reporting patient
abuse in tax supported institutions;
(m)Any other nondiscrimination provisions in the specific statute(s) under which
application for federal assistance is being made; and
(n) The requirements of any other nondiscrimination statute(s) that may apply to this
application.
Civil Rights Policies for Program Beneficiaries and Subrecipients of DHS funding,
pertaining to the following are available on the Cal OES website:
• Non-discrimination in Programs & Services
• Reasonable Accommodation for Program Beneficiaries
• Language Access Policy
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FY 2024 Standard Assurances For Cal OES Federal
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6. Drug-Free Workplace
As required by the Drug-Free Workplace Act of 1988 (41 U.S.C. § 701 et seq.),the
Applicant certifies that it will maintain a drug-free workplace and a drug-free
awareness program as outlined in the Act.
7. Environmental Standards
The Applicant will comply with state and federal environmental standards, including:
(a) The California Environmental Quality Act (CEQA) (California Public Resources Code
§§ 21000-21177), to include coordination with the city or county planning
agency;
(b) CEQA Guidelines (California Code of Regulations, Title 14, Division 6, Chapter 3,
§§ 15000-15387);
(c) The Federal Clean Water Act (CWA) (33 U.S.C. § 1251 et seq.), which establishes
the basic structure for regulating discharges of pollutants into the waters of the
United States and regulating quality standards for surface waters;
(d) The Federal Clean Air Act of 1955 (42 U.S.C. § 7401) which regulates air
emissions from stationary and mobile sources;
(e) Institution of environmental quality control measures under the National
Environmental Policy Act (NEPA) of 1969 (P.L. 91-190); the Council on
Environmental Quality Regulations for Implementing the Procedural Provisions
of NEPA; and Executive Order 12898 which focuses on the environmentaland
human health effects of federal actions on minority and low-income
populations with the goal of achieving environmental protection for all
communities;
(f) Evaluation of flood hazards in floodplains in accordance with Executive Order
11988;
(g) Executive Order 11514 which sets forth national environmental standards;
(h) Executive Order 11738 instituted to assure that each federal agency
empowered to enter into contracts for the procurement of goods, materials, or
services and each federal agency empowered to extend federal assistance by
way of grant, loan, or contract shall undertake such procurement and
assistance activities in a manner that will result in effective enforcement of the
Clean Air Act and the Federal Water Pollution Control Act Executive Order
11990 which requires preservation of wetlands;
(i) The Safe Drinking Water Act of 1974, (P.L. 93-523);
(j) The Endangered Species Act of 1973, (P.L. 93-205);
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(k) Assurance of project consistency with the approved state management
program developed under the Coastal Zone Management Act of 1972
(16 U.S.C. §§1451 et seq.);
(l) Conformity of Federal Actions to State (Clear Air) Implementation Plans under
Section 176(c) of the Clean Air Act of 1955, as amended (42 U.S.C. §§7401 et
seq.); and
(m)The Wild and Scenic Rivers Act of 1968 (16 U.S.C. § 1271 et seq.) related
to protecting components or potential components of the national wild
and scenic rivers system.
The Applicant shall not be: 1) in violation of any order or resolution promulgated by
the State Air Resources Board or an air pollution district; 2) subject to a cease-and-
desist order pursuant to section 13301 of the California Water Code for violation of
waste discharge requirements or discharge prohibitions; or 3) determined to be in
violation of federal law relating to air or water pollution.
8. Audits
For subrecipients expending $1,000,000 or more in federal grant funds annually, the
Applicant will perform the required financial and compliance audits in accordance
with the Single Audit Act Amendments of 1996 and C.F.R., Part 200, Subpart F Audit
Requirements.
9. Cooperation and Access to Records
The Applicant must cooperate with any compliance reviews or investigations
conducted by DHS. In accordance with 2 C.F.R. § 200.337, the Applicant will give the
awarding agency, the Comptroller General of the United States and, if appropriate,
the state, through any authorized representative, access to and the right to examine
all records, books, papers, or documents related to the award. The Applicant will
require any subrecipients, contractors, successors, transferees and assignees to
acknowledge and agree to comply with this provision.
10. Conflict of Interest
The Applicant will establish safeguards to prohibit the Applicant’s employees from
using their positions for a purpose that constitutes or presents the appearance of
personal or organizational conflict of interest, or personal gain.
11. Financial Management
False Claims for Payment - The Applicant will comply with 31 U.S.C §§ 3729-3733
which provides that Applicant shall not submit a false claim for payment,
reimbursement, or advance.
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12. Reporting - Accountability
The Applicant agrees to comply with applicable provisions of the Federal Funding
Accountability and Transparency Act (FFATA) (P.L. 109-282), including but not limited
to (a) the reporting of subawards obligating $30,000 or more in federal funds, and (b)
executive compensation data for first-tier subawards as set forth in 2 C.F.R. Part 170,
Appendix A. The Applicant also agrees to comply with the requirements set forth in
the government-wide financial assistance award term regarding the System for
Award Management and Universal Identifier Requirements located at 2 C.F.R.
Part 25, Appendix A.
13. Whistleblower Protections
The Applicant must comply with statutory requirements for whistleblower protections
at 10 U.S.C. § 2409, 41 U.S.C. § 4712, and 10 U.S.C. § 2324, 41 U.S.C. § 4304 and § 4310.
14. Human Trafficking
The Applicant will comply with the requirements of Section 106(g) of the Trafficking
Victims Protection Act of 2000, as amended (22 U.S.C. § 7104) which prohibits the
Applicant or its subrecipients from: (1) engaging in trafficking in persons during the
period of time that the award is in effect; (2) procuring a commercial sex act during
the period of time that the award is in effect; or (3) using forced labor in the
performance of the award or subawards under the award.
15. Labor Standards
The Applicant will comply with the following federal labor standards:
(a) The Davis-Bacon Act (40 U.S.C. §§ 276a to 276a-7), as applicable, and the
Copeland Act (40 U.S.C. § 3145 and 18 U.S.C. § 874) and the Contract Work
Hours and Safety Standards Act (40 U.S.C. §§ 327-333), regarding labor
standards for federally-assisted construction contracts or subcontracts, and
(b) The Federal Fair Labor Standards Act (29 U.S.C. § 201 et seq.) as they apply
to employees of institutes of higher learning (IHE), hospitals and other non-
profit organizations.
16. Worker’s Compensation
The Applicant must comply with provisions which require every employer to be
insured to protect workers who may be injured on the job at all times during the
performance of the work of this Agreement, as per the workers compensation laws
set forth in California Labor Code §§ 3700 et seq.
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17. Property-Related
If applicable to the type of project funded by this federal award, the Applicant will:
(a) Comply with the requirements of Titles II and III of the Uniform Relocation
Assistance and Real Property Acquisition Policies Act of 1970 (P.L. 91-646) which
provide for fair and equitable treatment of persons displaced or whose
property is acquired as a result of federal or federally-assisted programs. These
requirements apply to all interests in real property acquired for project purposes
regardless of federal participation in purchase;
(b) Comply with flood insurance purchase requirements of Section 102(a) of the
Flood Disaster Protection Act of 1973 (P.L. 93-234) which requires federal award
subrecipients in a special flood hazard area to participate in the program and
to purchase flood insurance if the total cost of insurable construction and
acquisition is $10,000 or more;
(c) Assist the awarding agency in assuring compliance with Section 106 of the
National Historic Preservation Act of 1966, as amended (16 U.S.C. § 470),
Executive Order 11593 (identification and protection of historic properties), and
the Archaeological and Historic Preservation Act of 1974 (16 U.S.C. § 469a-1 et
seq.); and
(d) Comply with the Lead-Based Paint Poisoning Prevention Act (42 U.S.C. § 4831
and 24 CFR Part 35) which prohibits the use of lead-based paint in construction
or rehabilitation of residence structures.
18. Certifications Applicable Only to Federally-Funded Construction Projects
For all construction projects, the Applicant will:
(a) Not dispose of, modify the use of, or change the terms of the real property title
or other interest in the site and facilities without permission and instructions from
the awarding agency. Will record the federal awarding agency directives and
will include a covenant in the title of real property acquired in whole or in part
with federal assistance funds to assure nondiscrimination during the useful life of
the project;
(b) Comply with the requirements of the awarding agency with regard to the
drafting, review and approval of construction plans and specifications;and
(c) Provide and maintain competent and adequate engineering supervision at
the construction site to ensure that the complete work conforms with the
approved plans and specifications and will furnish progressive reports and such
other information as may be required by the assistance awarding agency or
State.
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19. Use of Cellular Device While Driving is Prohibited
The Applicant is required to comply with California Vehicle Code sections 23123 and
23123.5. These laws prohibit driving motor vehicle while using an electronic wireless
communications device to write, send, or read a text-based communication. Drivers
are also prohibited from the use of a wireless telephone without hands-free listening
and talking, unless to make an emergency call to 911, law enforcement, or similar
services.
20. California Public Records Act and Freedom of Information Act
The Applicant acknowledges that all information submitted in the course of applying
for funding under this program, or provided in the course of an entity’s grant
management activities that are under Federal control, is subject to the Freedom of
Information Act (FOIA), 5 U.S.C. § 552, and the California Public Records Act,
California Government Code §7920.000 et seq. The Applicant should consider these
laws and consult its own State and local laws and regulations regarding the release
of information when reporting sensitive matters in the grant application, needs
assessment, and strategic planning process.
21. Acknowledgment of Federal Funding from DHS
The Applicant must acknowledge its use of federal funding when issuing statements,
press releases, requests for proposals, bid invitations, and other documents describing
projects or programs funded in whole or in part with federal funds.
22. Activities Conducted Abroad
The Applicant must coordinate with appropriate government authorities when
performing project activities outside the United States and obtain all appropriate
licenses, permits, or approvals.
23. Best Practices for Collection and Use of Personally Identifiable Information (PII)
DHS defines PII as any information that permits the identity of an individual to
be directly or indirectly inferred, including any information that is linked or linkable to
that individual. If the Applicant collects PII, the Applicant is required to have a
publicly-available privacy policy that describes standards on the usage and
maintenance of the PII they collect. The Applicant may refer to the DHS Privacy
Impact Assessments: Privacy Guidance and Privacy Template as a useful resource.
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24. Copyright
Recipients must affix the applicable copyright notices of 17 U.S.C. §§ 401 or 402 to
any work first produced under federal awards and also include an acknowledgement
that the work was produced under a federal award (including the federal award
number and federal awarding agency). As detailed in 2 C.F.R. § 200.315, a federal
awarding agency reserves a royalty-free, nonexclusive, and irrevocable right to
reproduce, publish, or otherwise use the work for federal purposes and to authorize
others to do so.
25. Duplicative Costs
Applicants are prohibited from charging any cost to this federal award that will be
included as a cost or used to meet cost sharing or matching requirements of any other
federal award in either the current or a prior budget period. (See 2 C.F.R. § 200.403(f)).
However, recipients may shift costs that are allowable under two or more federal
awards where otherwise permitted by federal statutes, regulations, or the federal
financial assistance award terms and conditions.
26. Energy Policy and Conservation Act
The Applicant must comply with the requirements of 42 U.S.C. § 6201 which contain
policies relating to energy efficiency that are defined in the state energy
conservation plan issued in compliance with this Act.
27. Federal Debt Status
The Applicant is required to be non-delinquent in its repayment of any federal debt.
Examples of relevant debt include delinquent payroll and other taxes, audit
disallowances, and benefit overpayments. See OMB Circular A-129.
28. Fly America Act of 1974
The Applicant must comply with Preference for United States Flag Air Carriers:
(a list of certified air carriers can be found at: Certificated Air Carriers List | US
Department of Transportation, https://www.transportation.gov/policy/aviation-
policy/certificated-air-carriers-list) for international air transportation of people and
property to the extent that such service is available, in accordance with the
International Air Transportation Fair Competitive Practices Act of 1974 (49 U.S.C.
§ 40118) and the interpretative guidelines issued by the Comptroller General of the
United States in the March 31, 1981, amendment to Comptroller General Decision
B-138942.
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29. Hotel and Motel Fire Safety Act of 1990
In accordance with Section 6 of the Hotel and Motel Fire Safety Act of 1990, the
Applicant must ensure that all conference, meeting, convention, or training space
funded in whole or in part with federal funds complies with the fire prevention and
control guidelines of the Federal Fire Prevention and Control Act of 1974, as
amended, 15 U.S.C. § 2225a.
30. Non-supplanting Requirement
If the Applicant receives federal financial assistance awards made under programs
that prohibit supplanting by law, the Applicant must ensure that federal funds do not
replace (supplant) funds that have been budgeted for the same purpose through
non- federal sources.
31. Patents and Intellectual Property Rights
Recipients are subject to the Bayh-Dole Act, 35 U.S.C. § 200 et seq. and applicable
regulations governing inventions and patents, including the regulations issued by the
Department of Commerce at 37 C.F.R. Part 401 (Rights to Inventions Made by
Nonprofit Organizations and Small Business Firms under Government Awards,
Contracts, and Cooperative Agreements) and the standard patent rights clause set
forth at 37 C.F.R. § 401.14.
32. SAFECOM
If the Applicant receives federal financial assistance awards made under programs
that provide emergency communication equipment and its related activities, the
Applicant must comply with the SAFECOM Guidance for Emergency Communication
Grants, including provisions on technical standards that ensure and enhance
interoperable communications.
33. Terrorist Financing
The Applicant must comply with Executive Order 13224 and United States law that
prohibit transactions with, and the provisions of resources and support to, individuals
and organizations associated with terrorism. The Applicant is legally responsible for
ensuring compliance with the Order and laws.
34. Reporting of Matters Related to Recipient Integrity andPerformance
If the total value of the Applicant’s currently active grants, cooperative agreements,
and procurement contracts from all federal assistance offices exceeds $10,000,000 for
any period of time during the period of performance of this federal financial
assistance award, the Applicant must comply with the requirements set forth in the
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government-wide Award Term and Condition for Recipient Integrity and
Performance Matters located at 2 C.F.R. Part 200, Appendix XII, the full text of which is
incorporated here by reference in the award terms and conditions.
35. USA Patriot Act of 2001
The Applicant must comply with requirements of the Uniting and Strengthening
America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism
Act (USA PATRIOT Act), which amends 18 U.S.C. §§ 175–175c.
36. Use of DHS Seal, Logo, and Flags
The Applicant must obtain written permission from DHS prior to using the DHS seals,
logos, crests, or reproductions of flags, or likenesses of DHS agency officials. This includes
use of DHS component (e.g., FEMA, CISA, etc.) seals, logos, crests, or reproductions of
flags, or likenesses of component officials.
37. Performance Goals (HSGP and NSGP)
In addition to the Biannual Strategy Implementation Report submission requirements
outlined in the Preparedness Grants Manual, the Applicant must demonstrate how
the grant-funded project addresses the core capability gap associated with each
project. The capability gap reduction must be addressed in the Project Description of
the BSIR for each project.
38. Applicability of DHS Standard Terms and Conditions to Tribes
The DHS Standard Terms and Conditions are a restatement of general requirements
imposed upon the Applicant and flow down to any of its subrecipients as a matter of
law, regulation, or executive order. If the requirement does not apply to Indian tribes
or there is a federal law or regulation exempting its application to Indian tribes, then
the acceptance by Tribes of, or acquiescence to, DHS Standard Terms and
Conditions does not change or alter its inapplicability to an Indian tribe. The
execution of grant documents is not intended to change, alter, amend, or impose
additional liability or responsibility upon the Tribe where it does not already exist.
39. Required Use of American Iron, Steel, Manufactured Products, and Construction
Materials
The Applicant must comply with the “Build America, Buy America” Act (BABAA),
enacted as part of the Infrastructure Investment and Jobs Act and Executive Order
14005. Applicants receiving a federal award subject to BABAA requirements may not
use federal financial assistance funds for infrastructure projects unless:
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(a) All iron and steel used in the project are produced in the United States – this
means all manufacturing processes, from the initial melting stage through the
application of coatings, occurred in the United States;
(b) All manufactured products used in the project are produced in the
United States – this means the manufactured product was manufactured in
the United States; and the cost of the components of the manufactured
product that are mined, produced, or manufactured in the United States is
greater than 55 percent of the total cost of all components of the
manufactured product, unless another standard for determining the
minimum amount of domestic content of the manufactured product has
been established under applicable law or regulation; and
(c) All construction materials are manufactured in the United States – this means
that all manufacturing processes for the construction material occurred in the
United States.
The “Buy America” preference only applies to articles, materials, and supplies that
are consumed in, incorporated into, or affixed to an infrastructure project. It does not
apply to tools, equipment, and supplies, such as temporary scaffolding, brought to
the construction site and removed at or before the completion of the infrastructure
project. Nor does a Buy America preference apply to equipment and furnishings,
such as movable chairs, desks, and portable computer equipment, that are used at
or within the finished infrastructure project but are not an integral part of the structure
or permanently affixed to the infrastructure project.
Per section 70914(c) of BABAA, FEMA may waive the application of a Buy America
preference under an infrastructure program in certain cases.
40. E.O. 14074 – Advancing Effective, Accountable Policing and Criminal Justice Practices
to Enhance Public Trust and Public Safety
Recipient State, Tribal, local, or territorial law enforcement agencies must comply with
the requirements of section 12(c) of E.O. 14074. Recipient State, Tribal, local, or
territorial law enforcement agencies are also encouraged to adopt and enforce
policies consistent with E.O. 14074 to support safe and effective policing.
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IMPORTANT
The purpose of these assurances is to obtain federal and state financial assistance,
including any and all federal and state grants, loans, reimbursement, contracts, etc.
Applicant recognizes and agrees that state financial assistance will be extended based
on the representations made in these assurances. These assurances are binding on
Applicant, its successors, transferees, assignees, etc. as well as any of its subrecipients.
Failure to comply with any of the above assurances may result in suspension, termination,
or reduction of grant funds.
All appropriate documentation, as outlined above, must be maintained on file by the
Applicant and available for Cal OES or public scrutiny upon request. Failure to comply
with these requirements may result in suspension of payments under the grant or
termination of the grant or both and the Applicant may be ineligible for award of any
future grants if Cal OES determines that the Applicant: (1) has made false certification,
or (2) violates the certification by failing to carry out the requirements as noted above.
All of the language contained within this document must be included in the award
documents for all subawards at all tiers. Applicants are bound by the DHS Standard
Terms and Conditions 2024, Version 2, hereby incorporated by reference, which can be
found at: https://www.dhs.gov/publication/fy15-dhs- standard-terms-and-conditions.
The undersigned represents that he/she is authorized to enter into this agreement for and
on behalf of the Applicant.
Applicant:
Signature of Authorized Agent:
Printed Name of Authorized Agent:
Title:Date:
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