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Second Appeal Brief
PA ID# 000-U9344-00; Oregon Department of Forestry
PW ID# 5, 6, & 9; Eligibility
Citation: FM2657 Project Worksheet 5 and 6, and FM2659 Project Worksheet 9
Reference: Cost Eligibility and Grant Compliance
Summary: Two issues comprise this second appeal. In the first appeal the Applicant was denied reimbursement for $342,452 for fire suppression costs generated by the I-Suite software that did not have supporting source documentation. $7,827 was denied for Bureau of Land Management Incident Management Team personnel costs that were generated by the I-Suite software. Applicant was also denied payment of $127 for in-State pre-positioning costs. Total costs denied on first appeal are $350,406.
The I-Suite system uses annually updated labor rates or historic labor rates when generating generic personnel costs. It does not however, have a similar rate determination process for equipment costs. I-Suite generated generic personnel costs are therefore allowable if they are accurate and reasonable. I-Suite generated equipment costs however, must be substantiated with source documents. 44 CFR 13.20 Standards for Financial Management Systems (b)(6) Source Documentation states, “Accounting records must be supported by such source documentation as canceled checks, paid bills, payrolls, time and attendance records, contract and subgrant award documents, etc.”
The second issue involves payment for in-State pre-positioning costs of $127 associated with the Applicant’s fire suppression activities. 44 CFR 204.42 Eligible Costs (e) (1) Pre-positioning Costs allows payment for prepositioning of out-of-State, Federal, and international resources, but not in-State costs.
Issues: 1) Do rates generated by the I-Suite software meet grant compliance standards?
2) Are in-State pre-positioned resources eligible for payment?
Findings: 1) I-Suite rates assigned for personnel costs do meet compliance standards. I-Suite rates for equipment rates do not meet compliance standards
Rationa le: 1) 44 CFR §13.20, Standards for Financial Management
2) 44 CFR §204.42, Eligible Costs