Summary: After completing several repair projects in 1994-5, and after having signed the "Project Completion and Certification Report" (P-4) for them on May 6, 1999, the subgrantee requested further funding because an internal audit conducted some time in 2000 revealed additional expenditures. The amount requested was $234,657. This was denied on first appeal as being a year too late. On first appeal, the subgrantee claimed not to have received the closeout letter.
Issues: Is there sufficient justification for exceeding the appeal deadline by a year? Is there a basis for appealing after having signed the P-4?
Findings: No, the subgrantee has not been able to provide anything other than the claim that they had not seen the closeout letter from FEMA. Also, since the closeout was based on the subgrantee's figures that are the same as those on the P-4, by signing this document the subgrantee has certified that the final numbers are correct. Two of the three appealed DSRs required supplemental DSRs to deobligate a portion of the funds because the expenditures listed on the P-4 were less than the original DSR amounts. Since the subgrantee signed and submitted the P-4 on which the deobligation DSRs was based, it must have been aware of the FEMA action to prepare them.