Ron Campbell• University of North Carolina Chapel Hill,

Emergency Management Coordinator• 24 years of experience in emergency

management including more than a dozen disaster events including Hurricane Irene at UNC-CH

Peter Drenan• Dewberry, Vice President• 32 years of experience including 10 years with

FEMA’s Public Assistance program and 10+ years as architect at University of Virginia

Recent Experience What is Public Assistance Common Challenges Tools and Tips Recovery Program

Snow Storms Hurricane Irene Tornados Floods

Pre-disaster plan focused on mitigation• Minimize disruptions and closings• Protect research • Control insurance rates • Reduce damage to facilities

4 Phases:•Phase 1 - Organize Resources•Phase 2 – Hazard Identification & Risk

Assessment•Phase 3 – Developing The Mitigation Plan•Phase 4 – Adoption & Implementation

Disaster Resistant UniversitiesDisaster Resistant Universities

Post-disaster Federal financial assistance

What does it cover: •Debris removal•Emergency protective measures•Repair, replacement, or restoration•Mitigation of damaged facilities

75% Federal, 25% State/Local

MONEY $$$$$

Benefits:• Maximum reimbursement• Expeditious project approval• Maximize time and resources

Consequences:• Minimal reimbursement• Delays in project approval• Diminished credibility• Appeals• Audits• De-obligation of funding

Why YOU Need to Understand the ProgramWhy YOU Need to Understand the Program

Major storm hit a small university All 43 buildings flooded for weeks

• Classes were closed

• Students sent home

Administration’s stated goal was to open next semester for all students

Emergency Financing required to develop temporary teaching and research facilities

What are the issues and considerations for getting the work done and getting FEMA reimbursements?

A Real ExampleA Real Example

Project Accounting Unsupported Costs Duplication of Benefits Excessive Equipment Charges Unrelated Project Charges Excessive Labor and Fringe Benefits Charges Poor Contracting Practices Unapplied Credits

Criteria: Federal regulations (44 CFR 13.20 and 206.205) require each subgrantee to: • maintain a system that accounts for FEMA

funds on a project-by-project basis.• The system must disclose the financial results

for all FEMA-funded activities accurately, currently, and completely.

Examples:• Collecting or tracking the information well after

the incident• Notes were maintained by hand

Criteria: Federal regulations (OMB Circular A-87 and 44 CFR 13.20) require that costs claimed under federal programs be adequately supported by source documentation such as cancelled checks, payrolls, contracts, etc.

Examples:• Invoices do not provide detailed dates that

coincided with the storm.• Records for vehicle use does not match up with the

payroll records.• Records for vehicle use cannot be verified with

event related calls.• Receipts do not have an employees name

associated with it.

Criteria: Government laws and regulations (Stafford Act and 44 CFR 206.191) prohibit duplication of benefits.

Examples:• Insurance claim not submitted for a project

covered by insurance.• Reimbursement from another source was not

disclosed on the Project Worksheet.

Criteria: According to OMB Circular A-87, grants must be reduced by credits that offset or reduce expenses allocable to federal awards.

Examples:• Jurisdiction received proceeds from the sale

of scrap material related to the FEMA project but did not apply them.

• Jurisdiction received two credit discounts for early payments to a contractor that were not applied.

Criteria: Federal regulations (44 CFR 206.228) require that subgrantees use the FEMA schedule of equipment rates or their local rates, whichever are lower.

Example:• Claiming the FEMA equipment rate rather

than the lesser local rate.

Criteria: According to OMB Circular A-87, charges to federal grants must be necessary and reasonable to fulfill the objective of the grant program.

Examples:• Unrelated charges were included in a claim.• Funding received was not applied to the

correct project.

Criteria: According to OMB Circular A-87, allowable costs must be consistent with policies, regulations, and procedures that apply uniformly to both federal awards and other activities of the governmental unit. According to 44 CFR 206.228, straight or regular-time salaries and benefits of permanent employees engaged in emergency service work are not eligible for FEMA assistance.

Example:• Fringe benefit rates are applied differently to

overtime compared to regular time.• Regular time is almost always not eligible.

Criteria. According to federal regulations (44 CFR 13.36), a subgrantee must comply with specific procurement standards.

Examples:• Jurisdiction did not document the basis or

method for the contract selection.• Jurisdiction entered into a contract which

included an overhead and profit allowance of 25% of actual costs.

Xavier received $75.4 Million for damages 40 ‘large’ and 57 ‘small’ grant

authorizations Inspector General audit done in June 2010 At that time, $35 million had been

disbursed Final IG Recommendation:

• Disallow $75.4 million

Xavier University of Louisiana

Xavier University of Louisiana

#1- Disallow $25,648,720 due to unsupported costs

#2 – Disallow $49,409,570 due to ineligible contract costs

#3 – Disallow $281,430 due to ineligible insurance costs

#4 – Disallow $12,291 due to ineligible facilities

#5 – Finalize insurance review and allocate proceeds to repairs

#6 – Implement controls on time restrictions & extensions

Xavier University of Louisiana

Xavier University of Louisiana

Standard Systems• Documentation• Checks and balances• Use it everyday

Project Worksheet• How to fill them out

How to Think During an Event

Documentation is key!

Policies should require departments and personnel to: • maintain a system that accounts for

university funds on a project-by-project basis.

• The system must disclose the financial results for all university-funded activities accurately, currently, and completely

• Costs being claimed must be adequately supported by source documentation such as cancelled checks, payrolls, contracts, etc.

Duplication of Benefits Excessive Equipment Charges Excessive Labor and Fringe Benefits Poor Contracting Practices Unapplied Credits

The more you use it the easier it will be!

Basic Project Information

Damage Description and Dimensions

Scope of Work

Special Considerations

Cost

Describe the damage description and dimensions

Describe the cause of the damage Describe the pre-disaster condition Quantify the disaster related

damage Describe how you fixed the damage,

scope of work

Necessary vs. Unnecessary Justifiable vs. Unjustifiable Normal Policies/Process vs. Not

Normal

Next steps:•Review systems•Adjust/Develop systems•Establish/adjust processes and policies

•Train staff

Common Challenges Can be Navigated

Documentation, Documentation, Documentation!