Joint Emergency Operations Center and American Red Cross Shelter Staffing
Appeal Brief
Appeal Letter
Appeal Analysis
Citation: FEMA-1008-DR-CA, P.A. 000-92022, Department of Health Services (Sacramento), DSR 85574, Joint Emergency Operations Center (JEOC) and American Red Cross (ARC) shelter staffing
Cross-reference: Emergency Work, Public Health, American Red Cross
Summary: Following the January 17, 1994, Northridge Earthquake, the Department of Health Services (DHS) opened a Joint Emergency Operations Center (JEOC) to run the state's medical, public and environmental health response. Through the JEOC and district offices, DHS provided the public with health information, acquired medical personnel, and ensured the safety of the drinking water supply. At the request of the American Red Cross (ARC), DHS recruited and paid the salaries of 267 nurses to serve in shelters. ARC's volunteer capabilities had been overwhelmed. Nurses provided health services to shelter residents in nine-day shifts from January 25, 1994, to February 20, 1994. Damage Survey Report (DSR) 85574 was prepared for $729,570 and obligated for $0 on July 18, 1997, because the scope of work described staffing Disaster Application Centers (DACs) and ARC shelters. The DSR stated that DAC-related costs were covered by the State's administrative allowance and staffing ARC shelters was not DHS' responsibility. The first appeal dated September 24, 1997, stated that no DAC-related costs were claimed and presented information to support the position that DHS was legally responsible for the work. On November 8, 1998, FEMA denied the appeal stating that while the work was shown to be the responsibility of DHS and some work was eligible, the documentation submitted was inadequate and eligible costs could not be discerned from ineligible costs. DHS submitted its second appeal on February 2, 1999. It provided descriptions of work performed, and included timesheets and travel expenses related to the claim.
Issues:
The Northridge Earthquake struck California on January 17, 1994. As directed by a Memorandum of Understanding signed August 2, 1988, between the Department of Health Services (DHS) and the Emergency Medical Services Authority (EMSA), DHS immediately implemented a Joint Emergency Operations Center (JEOC) from which to run "the state's medical and public and environmental health emergency response." Under the direction of the California Office of Emergency Services (OES) and through an Administrative Order issued under the State of California Executive Order W-9-91 (May 29, 1991), DHS acted to "redirect all other resources, as necessary and appropriate, to accomplish the objectives of the California State Emergency Plan." These objectives included administering and coordinating disaster-related public health programs and ensuring the safety of domestic water supplies.
On January 21, 1994, the American Red Cross (ARC) contacted the JEOC and requested that DHS provide nurses to support ARC shelters. Nurses were needed to augment ARC capabilities and duties were to include first aid assessment and medical referral. The JEOC personnel acquisition team found they could not recruit volunteer nurses. ARC agreed to provide the nurses' housing, food and travel expenses. DHS agreed to pay the nurses' salaries. OES issued Mission #94-1066, Order #2 to provide 500 nurses to ARC shelters. The nurses were to be dispatched in seven groups of 75 and work nine-day shifts. The first group of 73 nurses began on January 25, 1994; the second group of 74 began on January 31, 1994; the third group of 70 began on February 6, 1994; and the final group of 50 began on February 12, 1994. The final group was sent home on February 20, 1994, as shelters were closed and consolidated to a point where outside nursing services were not needed. A total of 267 nurses served in 47 shelters, according to ARC.
Damage Survey Report (DSR) 85574 was prepared for $729,570. The scope of work was described as "staff DACS and Red Cross shelters with department personnel or nurses supplied by counties or hospitals. Staff district offices to answer phone call by the general public." The DSR was signed on May 17, 1997, and obligated for $0 on July 18, 1997, because Disaster Assistance Center (DAC) costs are covered by the administrative allowance and staffing ARC shelters is not the legal responsibility of DHS. In its June 27, 1997, non-concurrence statement OES claimed that the ARC Disaster Service Centers (DSCs) were confused with the state-run DACs and there were no DAC costs associated with the request.
DHS submitted its first appeal on September 24, 1997. It stated that it had the legal responsibility to open a JEOC and that directed by OES, it was responsible for coordinating public health assistance following the earthquake. This included supplying nurses to ARC shelters under OES Mission #94-1066, Order #2. In addition, no DAC-related costs were submitted. DHS argued that staffing ARC shelters was necessary for the protection of public health and that nurses were not answering phone calls. Instead, costs associated with answering public calls were for DHS staff operating the JEOC and program field offices (overtime and limited travel only). DHS suggested that the scope of work be more accurately described with two distinct missions:"1. Activate and staff the Joint Emergency Operations Center and program field offices to coordinate the response to public health concerns and provide medical and public health assistance to Los Angeles and Ventura Counties.
2. Provide nurses . to staff Red Cross shelters, provide relief to county public health nurses, and support one hospital." On November 9, 1998, FEMA responded to the first appeal. FEMA agreed that the work described was the legal responsibility of DHS, but questioned whether the work performed was eligible emergency work. FEMA stated that a "fair amount" of the documentation showed "workers, mostly nurses, were answering phones and responding to questions." Timesheets were found to indicate both eligible and ineligible activities, though the total amount of eligible costs were indeterminable, according to FEMA. Citing "lack of adequate supporting documentation justifying the eligible costs," FEMA denied the appeal.
SECOND APPEAL
DHS submitted its second appeal on February 2, 1999. It claimed that all relevant documentation had been submitted and it was unclear how the materials were insufficient. It further clarified the activities of nurses in ARC shelters as opposed to DHS staff working in the JEOC or district offices. In terms of nurses, DHS stated that they were used for four weeks while shelters were in operation. They did not answer phones, but provided "direct medical and health services to victims in shelters." They did not provide information about FEMA services, but basic medical and nursing care. In addition, DHS explained the role of sanitary engineers that assessed the domestic water supply. These DHS employees provided the public with information about the decontamination of water, and ensured a safe and adequate supply of drinking water, as required by 42 USC 300g-2(a).
Two letters were referenced in support of the eligibility of the work performed by the nurses at ARC shelters. An April 2, 1997, letter from DHS to OES provided a summary of events related to DHS providing nurses to ARC. DHS stated that the shelter nurses were essential to ensuring the health and safety of shelter residents. A January 19, 1999, letter from ARC to OES stated that shelter nurses accomplished the following:
ANALYSIS
DHS Staff Overtime and Travel Costs
The role of DHS in responding to a disaster has been established and its legal responsibilities clarified. DHS is responsible for opening a JEOC through which medical and public health supplies, equipment, and personnel are acquired to respond to public health needs following a disaster. These needs include disease prevention and water supply safety. Timesheets indicate that DHS personnel began operating from the JEOC on the day of the earthquake. DHS staff in the JEOC and district offices were used to: acquire medical personnel, answer calls from the public regarding health issues, assess the safety of water supplies and inform the public about decontamination procedures, and operate the JEOC. Assigned work was based on skill, for example, sanitary engineers dealt with water safety issues and office assistants answered phones. TatARC shelters. The majority of costs related to DHS staff were incurred within a few days of the earthquake.
Section 403 of the Stafford Act allows for work and services essential to protecting and preserving public health, including warning of further risks and hazards and disseminating information and assistance regarding public health and safety issues. Public assistance guidance (Public Assistance Guide, FEMA 286/September 1996) includes the activation of an Emergency Operations Center (EOC) to coordinate and direct the response to a disaster among a list of activities that may be eligible emergency work. Based on these criteria and the work described in timesheets and in related materials, the majority of costs associated with DHS staff overtime and travel are eligible. (Attachments 1 and 2 provide a detailed breakdown of eligible costs).
Providing Nurses to ARC Shelters
When ARC requested assistance from DHS in recruiting nurses to augment voluntary capabilities, it stated that "the current and emerging health issues and threats which confront the Red Cross go beyond normal Red Cross health service delivery and exceed the scope of the ESF #6 mission." ESF #6 assigns ARC responsibility for providing First Aid in shelters. ARC described additional public health issues stating that "within shelters, chronic conditions deteriorate, the threat of infectious diseases increase" and the stress of the situation may create new health care concerns or adversely impact pre-existing conditions. Timesheets and activity logs from nurses assigned to ARC shelters indicate that they worked at various shelters for an average of nine days (including travel and limited training). An interoffice memorandum from Santa Cruz County Health Services Agency described the work performed by County nurses to include: health assessments of incoming residents, disease prevention in food preparation and distribution, and chronic disease and pregnancy monitoring. As stated previously, work was performed in shifts, some nurses began on January 25, 1994, and all were sent home by
February 20, 1994.
44 CFR 206.225(a)(3)(ii) states that to be eligible, emergency protective measures must "eliminate or lessen immediate threats to life, public health or safety." In addition, 44 CFR 206.225(a)(2) recommends the threat be identified and evaluated by state or federal officials. In this case, the U.S. Department of Health and Human Services, OES, and DHS each recommended that nurses were needed in shelters to augment ARC capabilities. The conditions found in shelters may indeed present an immediate threat to public health. In this case, nurses were provided to treat the medical needs of shelter residents and attend to other public health concerns in the aftermath of the Northridge Earthquake, and this work was an emergency protective measure. Based on the documentation and applicable federal regulations, the majority of the costs associated with the salaries of nurses provided to ARC shelters are eligible. (For a detailed list of eligible costs, see Attachment 1).
CONCLUSIONS
As stated previously and shown in the two attachments, the majority of claimed costs can be associated with emergency work and are, therefore, eligible for reimbursement. Of the $729,570 requested, $520,070 is eligible. The comments provided in the attachments explain the discrepancies between claimed and eligible costs.
Appeal Brief
| Disaster | FEMA-1008-DR |
| Applicant | Sacramento Department of Health Services |
| Appeal Type | Second |
| PA ID# | 000-92022 |
| PW ID# | 85574 |
| Date Signed | 1999-06-14T04:00:00 |
Cross-reference: Emergency Work, Public Health, American Red Cross
Summary: Following the January 17, 1994, Northridge Earthquake, the Department of Health Services (DHS) opened a Joint Emergency Operations Center (JEOC) to run the state's medical, public and environmental health response. Through the JEOC and district offices, DHS provided the public with health information, acquired medical personnel, and ensured the safety of the drinking water supply. At the request of the American Red Cross (ARC), DHS recruited and paid the salaries of 267 nurses to serve in shelters. ARC's volunteer capabilities had been overwhelmed. Nurses provided health services to shelter residents in nine-day shifts from January 25, 1994, to February 20, 1994. Damage Survey Report (DSR) 85574 was prepared for $729,570 and obligated for $0 on July 18, 1997, because the scope of work described staffing Disaster Application Centers (DACs) and ARC shelters. The DSR stated that DAC-related costs were covered by the State's administrative allowance and staffing ARC shelters was not DHS' responsibility. The first appeal dated September 24, 1997, stated that no DAC-related costs were claimed and presented information to support the position that DHS was legally responsible for the work. On November 8, 1998, FEMA denied the appeal stating that while the work was shown to be the responsibility of DHS and some work was eligible, the documentation submitted was inadequate and eligible costs could not be discerned from ineligible costs. DHS submitted its second appeal on February 2, 1999. It provided descriptions of work performed, and included timesheets and travel expenses related to the claim.
Issues:
- Is the work described, which was performed by DHS staff and contracted nurses, eligible emergency work?
- Are overtime and travel costs for DHS employees eligible?
- Are the costs of salaries for nurses contracted by DHS to work in ARC shelters eligible?
- Yes.
- Yes, when costs can be directly associated with eligible work.
- Yes, when costs can be directly associated with eligible work.
Appeal Letter
June 14, 1999
D.A. Christian
Governor's Authorized Representative
Governor's Office of Emergency Services
74 North Pasadena Avenue, West Annex, Second Floor
Pasadena, California 91103-3678
Re: Second Appeal - Department of Health Services (Sacramento), Joint Emergency Operations Center (JEOC) and American Red Cross (ARC) Shelter Staffing, FEMA-1008-DR-CA, DSR 85574
Dear Mr. Christian:
This is in response to the referenced second appeal submitted by your office on March 19, 1999. Following the Northridge Earthquake on January 17, 1994, the Department of Health Services (DHS) opened and staffed a Joint Emergency Operations Center (JEOC), ensured the safety of the drinking water supply, and contracted and paid the salaries of 267 nurses to provide health services at American Red Cross (ARC) shelters.
Damage Survey Report (DSR) 85574 was prepared for $729,570 to fund this work, but was obligated for $0 on July 18, 1997. The scope of work stated that DHS staffed Disaster Application Centers (DACs) and ARC shelters. FEMA determined that DAC-related costs were covered by the State's administrative allowance and staffing ARC shelters was not the legal responsibility of DHS. In its first appeal dated September 24, 1997, DHS claimed that no DAC-related costs were submitted and provided documentation to show that the work was its legal responsibility. FEMA denied the appeal on November 8, 1998, saying that while the work was shown to be the legal responsibility of DHS, the documentation submitted was inadequate and eligible costs could not be discerned from ineligible costs.
DHS submitted its second appeal on February 2, 1999. As explained in the enclosed analysis, the documentation provided supports the claim that the work described is eligible emergency work. DHS submitted descriptions of work performed, and included timesheets and travel expenses related to the claim. By examining the timesheets and work descriptions, the majority of claimed costs can be directly related to the performance of eligible work. A total of $520,070 is eligible. By copy of this letter, I am asking that the Federal Coordinating Officer prepare a DSR for this amount.
Please inform the applicant of my determination. In accordance with the appeal procedure governing appeal decisions made on or after May 8, 1998, my decision constitutes the final decision on this matter. The current appeal procedure was published as a final rule in the Federal Register on April 8, 1998. It amends 44 CFR 206.206, which constitutes the final level of appeal in accordance with 44 CFR 206.206(e).
Sincerely,
/S/
Lacy E. Suiter
Executive Associate Director
Response and Recovery Directorate
Enclosure
cc: Christina Lopez
Federal Coordinating Officer
Northridge Long-Term Recovery Area Office
D.A. Christian
Governor's Authorized Representative
Governor's Office of Emergency Services
74 North Pasadena Avenue, West Annex, Second Floor
Pasadena, California 91103-3678
Re: Second Appeal - Department of Health Services (Sacramento), Joint Emergency Operations Center (JEOC) and American Red Cross (ARC) Shelter Staffing, FEMA-1008-DR-CA, DSR 85574
Dear Mr. Christian:
This is in response to the referenced second appeal submitted by your office on March 19, 1999. Following the Northridge Earthquake on January 17, 1994, the Department of Health Services (DHS) opened and staffed a Joint Emergency Operations Center (JEOC), ensured the safety of the drinking water supply, and contracted and paid the salaries of 267 nurses to provide health services at American Red Cross (ARC) shelters.
Damage Survey Report (DSR) 85574 was prepared for $729,570 to fund this work, but was obligated for $0 on July 18, 1997. The scope of work stated that DHS staffed Disaster Application Centers (DACs) and ARC shelters. FEMA determined that DAC-related costs were covered by the State's administrative allowance and staffing ARC shelters was not the legal responsibility of DHS. In its first appeal dated September 24, 1997, DHS claimed that no DAC-related costs were submitted and provided documentation to show that the work was its legal responsibility. FEMA denied the appeal on November 8, 1998, saying that while the work was shown to be the legal responsibility of DHS, the documentation submitted was inadequate and eligible costs could not be discerned from ineligible costs.
DHS submitted its second appeal on February 2, 1999. As explained in the enclosed analysis, the documentation provided supports the claim that the work described is eligible emergency work. DHS submitted descriptions of work performed, and included timesheets and travel expenses related to the claim. By examining the timesheets and work descriptions, the majority of claimed costs can be directly related to the performance of eligible work. A total of $520,070 is eligible. By copy of this letter, I am asking that the Federal Coordinating Officer prepare a DSR for this amount.
Please inform the applicant of my determination. In accordance with the appeal procedure governing appeal decisions made on or after May 8, 1998, my decision constitutes the final decision on this matter. The current appeal procedure was published as a final rule in the Federal Register on April 8, 1998. It amends 44 CFR 206.206, which constitutes the final level of appeal in accordance with 44 CFR 206.206(e).
Sincerely,
/S/
Lacy E. Suiter
Executive Associate Director
Response and Recovery Directorate
Enclosure
cc: Christina Lopez
Federal Coordinating Officer
Northridge Long-Term Recovery Area Office
Appeal Analysis
BACKGROUNDThe Northridge Earthquake struck California on January 17, 1994. As directed by a Memorandum of Understanding signed August 2, 1988, between the Department of Health Services (DHS) and the Emergency Medical Services Authority (EMSA), DHS immediately implemented a Joint Emergency Operations Center (JEOC) from which to run "the state's medical and public and environmental health emergency response." Under the direction of the California Office of Emergency Services (OES) and through an Administrative Order issued under the State of California Executive Order W-9-91 (May 29, 1991), DHS acted to "redirect all other resources, as necessary and appropriate, to accomplish the objectives of the California State Emergency Plan." These objectives included administering and coordinating disaster-related public health programs and ensuring the safety of domestic water supplies.
On January 21, 1994, the American Red Cross (ARC) contacted the JEOC and requested that DHS provide nurses to support ARC shelters. Nurses were needed to augment ARC capabilities and duties were to include first aid assessment and medical referral. The JEOC personnel acquisition team found they could not recruit volunteer nurses. ARC agreed to provide the nurses' housing, food and travel expenses. DHS agreed to pay the nurses' salaries. OES issued Mission #94-1066, Order #2 to provide 500 nurses to ARC shelters. The nurses were to be dispatched in seven groups of 75 and work nine-day shifts. The first group of 73 nurses began on January 25, 1994; the second group of 74 began on January 31, 1994; the third group of 70 began on February 6, 1994; and the final group of 50 began on February 12, 1994. The final group was sent home on February 20, 1994, as shelters were closed and consolidated to a point where outside nursing services were not needed. A total of 267 nurses served in 47 shelters, according to ARC.
Damage Survey Report (DSR) 85574 was prepared for $729,570. The scope of work was described as "staff DACS and Red Cross shelters with department personnel or nurses supplied by counties or hospitals. Staff district offices to answer phone call by the general public." The DSR was signed on May 17, 1997, and obligated for $0 on July 18, 1997, because Disaster Assistance Center (DAC) costs are covered by the administrative allowance and staffing ARC shelters is not the legal responsibility of DHS. In its June 27, 1997, non-concurrence statement OES claimed that the ARC Disaster Service Centers (DSCs) were confused with the state-run DACs and there were no DAC costs associated with the request.
DHS submitted its first appeal on September 24, 1997. It stated that it had the legal responsibility to open a JEOC and that directed by OES, it was responsible for coordinating public health assistance following the earthquake. This included supplying nurses to ARC shelters under OES Mission #94-1066, Order #2. In addition, no DAC-related costs were submitted. DHS argued that staffing ARC shelters was necessary for the protection of public health and that nurses were not answering phone calls. Instead, costs associated with answering public calls were for DHS staff operating the JEOC and program field offices (overtime and limited travel only). DHS suggested that the scope of work be more accurately described with two distinct missions:
2. Provide nurses . to staff Red Cross shelters, provide relief to county public health nurses, and support one hospital."
SECOND APPEAL
DHS submitted its second appeal on February 2, 1999. It claimed that all relevant documentation had been submitted and it was unclear how the materials were insufficient. It further clarified the activities of nurses in ARC shelters as opposed to DHS staff working in the JEOC or district offices. In terms of nurses, DHS stated that they were used for four weeks while shelters were in operation. They did not answer phones, but provided "direct medical and health services to victims in shelters." They did not provide information about FEMA services, but basic medical and nursing care. In addition, DHS explained the role of sanitary engineers that assessed the domestic water supply. These DHS employees provided the public with information about the decontamination of water, and ensured a safe and adequate supply of drinking water, as required by 42 USC 300g-2(a).
Two letters were referenced in support of the eligibility of the work performed by the nurses at ARC shelters. An April 2, 1997, letter from DHS to OES provided a summary of events related to DHS providing nurses to ARC. DHS stated that the shelter nurses were essential to ensuring the health and safety of shelter residents. A January 19, 1999, letter from ARC to OES stated that shelter nurses accomplished the following:
- Monitored the health of shelter residents
- Assessed and treated minor illnesses and injuries
- Cared for those with chronic conditions
- Provided public health information
- Ensured that shelters were sanitary
- Monitored and reported abusive situations
- Supervised unlicensed or inexperienced volunteer and paid medical staff
- Were a vital part of closing shelters - saw to ongoing health care needs and reassured those afraid to return home
ANALYSIS
DHS Staff Overtime and Travel Costs
The role of DHS in responding to a disaster has been established and its legal responsibilities clarified. DHS is responsible for opening a JEOC through which medical and public health supplies, equipment, and personnel are acquired to respond to public health needs following a disaster. These needs include disease prevention and water supply safety. Timesheets indicate that DHS personnel began operating from the JEOC on the day of the earthquake. DHS staff in the JEOC and district offices were used to: acquire medical personnel, answer calls from the public regarding health issues, assess the safety of water supplies and inform the public about decontamination procedures, and operate the JEOC. Assigned work was based on skill, for example, sanitary engineers dealt with water safety issues and office assistants answered phones. TatARC shelters. The majority of costs related to DHS staff were incurred within a few days of the earthquake.
Section 403 of the Stafford Act allows for work and services essential to protecting and preserving public health, including warning of further risks and hazards and disseminating information and assistance regarding public health and safety issues. Public assistance guidance (Public Assistance Guide, FEMA 286/September 1996) includes the activation of an Emergency Operations Center (EOC) to coordinate and direct the response to a disaster among a list of activities that may be eligible emergency work. Based on these criteria and the work described in timesheets and in related materials, the majority of costs associated with DHS staff overtime and travel are eligible. (Attachments 1 and 2 provide a detailed breakdown of eligible costs).
Providing Nurses to ARC Shelters
When ARC requested assistance from DHS in recruiting nurses to augment voluntary capabilities, it stated that "the current and emerging health issues and threats which confront the Red Cross go beyond normal Red Cross health service delivery and exceed the scope of the ESF #6 mission." ESF #6 assigns ARC responsibility for providing First Aid in shelters. ARC described additional public health issues stating that "within shelters, chronic conditions deteriorate, the threat of infectious diseases increase" and the stress of the situation may create new health care concerns or adversely impact pre-existing conditions. Timesheets and activity logs from nurses assigned to ARC shelters indicate that they worked at various shelters for an average of nine days (including travel and limited training). An interoffice memorandum from Santa Cruz County Health Services Agency described the work performed by County nurses to include: health assessments of incoming residents, disease prevention in food preparation and distribution, and chronic disease and pregnancy monitoring. As stated previously, work was performed in shifts, some nurses began on January 25, 1994, and all were sent home by
February 20, 1994.
44 CFR 206.225(a)(3)(ii) states that to be eligible, emergency protective measures must "eliminate or lessen immediate threats to life, public health or safety." In addition, 44 CFR 206.225(a)(2) recommends the threat be identified and evaluated by state or federal officials. In this case, the U.S. Department of Health and Human Services, OES, and DHS each recommended that nurses were needed in shelters to augment ARC capabilities. The conditions found in shelters may indeed present an immediate threat to public health. In this case, nurses were provided to treat the medical needs of shelter residents and attend to other public health concerns in the aftermath of the Northridge Earthquake, and this work was an emergency protective measure. Based on the documentation and applicable federal regulations, the majority of the costs associated with the salaries of nurses provided to ARC shelters are eligible. (For a detailed list of eligible costs, see Attachment 1).
CONCLUSIONS
As stated previously and shown in the two attachments, the majority of claimed costs can be associated with emergency work and are, therefore, eligible for reimbursement. Of the $729,570 requested, $520,070 is eligible. The comments provided in the attachments explain the discrepancies between claimed and eligible costs.
Attachment 1 -Claimed vs. Eligible Costs
Invoice Date | Claimed | Amount Claimed | Eligible Amount |
April 26, 1995 | Gail A. Morgan | 1,882.44 | 1,882.44 |
June 13, 1995 | Almeda County8 | 71,625.61 | 10,879.70 |
June 30, 1995 | DHS Overtime Expense10 | 45,554.95 | 33,020.99 |
August 2, 1995 | Mercy Healthcare Sacramento | 897.49 | 897.49 |
October 2, 1995 | San Diego County13 | 40,746.14 | 0 |
November 20, 1995 | San Bernardino County | 12,705.64 | 12,705.64 |
Totals: | $729,569.80 | $520,069.93 |
Comments
- Gardner Health Center submitted a claim for $44,270. Ines fnel; $2,000, lodging; $500, airfare; $120, car rental; $100, telephone; $400, vehicle expenses; and $350/day, 105 days for a mobile health clinic. There is no documentation from DHS to support the eligibility of this claim. No timesheets were included and there is nothing to relate this expense to eligible emergency work.
- Timesheets were not included, but summary of costs for personnel indicates that the total cost for personnel was $36,251.70.
- There are no timesheets, descriptions of work, or information to tie costs to eligible work.
- There are no timesheets, descriptions of work, or information to tie costs to eligible work.
- There are no timesheets, descriptions of work, or information to tie costs to eligible work.
- Costs related to the following employees were found ineligible for the reason stated. D. Broadway, P. Miller - informed the public about the IFG program. S. Strege - no work location or description that could be directly linked to eligible work.
- Indirect costs are not eligible. For large projects reimbursement is based on actual costs, according to 44 CFR 206.203(c)(1). In addition, 44 CFR 206.228(b)(2) categorically excludes indirect costs for subgrantees: "No indirect costs of a subgrantee are separately eligible because the percentage allowance in paragraph (a)(2)(ii) of this section covers necessary costs of requesting, obtaining and administering Federal assistance."
- The total amount requested was $71,625.61. A table summarizes costs for 15 employees, but timesheets are included for just six. From these timesheets it is evident that only three days work for each employee was disaster-related. For example, Evelyn Carver worked Sunday through Tuesday at a shelter, but for Wednesday through Friday states: "Normal duty hours at regular work site." Her disaster-related salary and benefits total $1,640.62, yet the table indicates a total of $5,964.80. Only the disaster-related costs for the six employees whose timesheets are included are eligible.
- See 7.
- Costs related to the following employees were found ineligible for the reason stated. L. Goodman, F. Montez - no description of work. D. Gosch - no overtime hours reported on timesheet. L. Meza - no description of work for 2/8-2/22. W. O'Neil, A. Robles, and D. Salazar - report DAC-related work. J. Rangel - majority of overtime reported one month after disaster, cannot tie description to eligible work. P. Singh - no location, cannot tie description to eligible work. M. Stanfield - listed as "DAC employee." R. Steyall, R. Trent - cannot tie description to eligible work.
- See 7.
- See 7.
- As stated in letter dated April 18, 1997, from DHS to OES: "reimbursement to the County of San Diego would be direct, as this agency did not reimburse San Diego." FEMA can reimburse only actual costs incurred by an eligible applicant, according to 44 CFR 206.223(a)(3) and 44 CFR 206.203(c)(1). DHS did not incur a cost and the County of San Diego is not an eligible applicant. Therefore, this amount cannot be reimbursed.
- See Attachment 2.
- See 7.
Attachment 2 - DHS Travel Expenditures
Employee
Claimed
Eligible
Comments
Abbott, D
281.12
281.12
Adam, D
10.40
10.40
Ali, M
57.90
57.90
Bond, S
105.00
0
Includes pre-disaster travel. Remainder cannot be tied to eligible work.
Cheng, T
62.40
62.40
Curphy, J
90.00
59.40
Includes pre-disaster travel. $59.40 can be tied to eligible work.
Dryer, R
44.26
0
Includes pre-disaster travel. Remainder cannot be tied to eligible work.
Faught, J
66.50
66.50
Forbes, C
178.29
178.29
Ford, J
1,114.04
0
Includes pre-disaster travel. Remainder cannot be tied to eligible work.
Greenhalsh, R
263.9
0
Cannot be tied to eligible work.
Hamrah, L
83.68
83.68
Hoegh, H
115.95
115.95
Hook, R
55.25
55.25
Hull, S
65.88
65.88
Jordan, A
341.0
163.42
Includes pre-disaster travel. $163.42 can be tied to eligible work.
Kashinkunti, R
50.40
50.40
Kastratovic, T
24.96
24.96
Koppinger, S
59.72
34.00
Unclear what amount was paid. $19 for meals and $6.72 for private car were crosout.<.
Martin, M
40.00
40.00
Meza, L
206.64
143.36
Some travel on days deemed ineligible. Also, pre-disaster travel. $143.36 can be tied to eligible work.
Moersfelder, J
32.16
32.16
Murray, R
361.42
361.42
Newton, G
112.50
112.50
Rizk, F
705.03
346.83
Includes non-disaster related expenses. $346.83 can be tied to eligible work.
Saba, N
158.40
158.40
Schneider, E
1,111.80
1,111.80
Sertich, R
28.24
0
Cannot be tied to eligible work.
Shefer, A
724.95
724.95
Federal employee.
Singh, P
55.20
55.20
Souza, K
43.20
43.20
Vugia, D
141.60
141.60
Werner, S
523.71
302.81
Includes non-emergency work. $302.81 can be tied to eligible work.
Wen, J
98.40
98.40
Whitsell, E
85.56
85.56
$7,499.46
$5,067.74
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