Chapter 5: Project Management
Project management begins when a disaster occurs and does not end until an applicant has received final payment for the project. Good project management ensures successful recovery from the disaster, expedited payment of funds, and more efficient closeouts of PA Program grants. See FEMA Instruction 8610.8, Public Assistance (PA) Program Grants Administration Post Award Monitoring and Closeout Processes for additional information.
It is critical that the applicant establish and maintain accurate records of events and expenditures related to disaster recovery work. The information required for documentation describes the "who, what, when, where, why, and how much," for each item of disaster recovery work. This information should include the completed PW; completed Special Considerations Questions form; estimated and actual costs; force account labor; force account equipment, materials, and purchases; photographs of damage, work underway, and work completed; insurance information; environmental and/or historic alternatives and hazard mitigation opportunities considered; environmental review documents; receipt and disbursement documents; and records of donated goods and services, if any. The applicant should have a financial and record keeping system in place that can be used to track these elements. The importance of maintaining a complete and accurate set of records for each project cannot be over-emphasized. Good documentation facilitates the project formulation, validation, approval, and funding processes.
All of the documentation pertaining to a project should be filed with the corresponding PW and maintained by the applicant as the permanent record of the project. These records become the basis for verification of the accuracy of project cost estimates during validation of small projects, reconciliation of costs for large projects, and audits.
Applicants should begin the record keeping process before a disaster is declared by the President. To ensure that work performed both before and after a disaster declaration is well documented, potential applicants should:
- designate a person to coordinate the compilation and filing of records;
- establish a file for each site where work has been or will be performed; and
- maintain accurate disbursement and accounting records to document the work performed and the costs incurred.
Grantees must maintain records for a minimum of 3 years from the date of the final Financial Status Report (FSR) or follow their standard record retention policy requirements if that policy dictates record retention beyond the 3-year requirement. Applicants must meet their own record retention requirements if they are longer than the Grantee's. Otherwise, they must follow the Grantee's requirements. If the applicants are required to submit an FSR to the Grantee, the beginning date for record retention is the date of the final FSR. If the FSR is not required, the beginning date for record retention is the final certification of completion of the applicant's last project. Applicants may refer to the Public Assistance Applicant Handbook, FEMA 323, for additional information regarding record keeping.
Eligible work must be completed within timeframes established by regulation. These deadlines are measured from the declaration date of the major disaster or emergency. The deadlines are established according to the type of work, as shown in the following table:
Type of Work
The State has limited authority to grant extensions of the above deadlines on a case-by-case basis in situations of extenuating circumstances. However, the State may not grant extensions that modify the approved scope of work, such as where the project cost is dependent on the duration. For example, for a leased temporary facility, FEMA defines the eligible funding for this facility based on the duration of use. The State does not have the authority to extend the duration of the lease as this constitutes an increase in the approved scope of work and associated costs. Only FEMA can approve a scope of work modification.
For debris clearance and emergency protective measures, the State may grant up to an additional six months for the completion of the approved scope of work. For permanent restoration work, the State may grant up to an additional 30 months.
Requests by applicants for time extensions should include identification of the project by PW number, the dates and provisions of any previous extensions granted for the particular project, a detailed justification of the need for the extension, and a projected completion date. The justification should be based on extenuating circumstances or unusual project requirements beyond the control of the applicant. FEMA may review the State's actions on time extensions on a periodic basis to ensure compliance with the regulations.
If an applicant requests a time extension beyond the limit of the State's authority, the State must submit the request to the RA for approval. Information to be contained in the request is the same as in a request submitted for State approval. The RA will make a determination as to whether some or all of the requested extension should be granted and will inform the State in writing. The RA has authority to grant extensions appropriate to the situation. The RA may impose requirements upon the State to ensure that the project will be completed within the approved time limit.
FEMA provides assistance only for those costs incurred up to the latest approved completion date for a particular project. However, the project still must be completed for any funding to be eligible for that project.
Changes in Scope of Work and Costs
During the performance of work on a project, the applicant may discover hidden damage, additional work that is necessary to properly complete the project, or that certain costs are higher than those used to make the original estimate for the PW. Delays in the work schedule also may increase costs. This notification of additional damage or costs must be for a project already identified and approved by FEMA. Changes in the scope of work may result in additional environmental/ historic preservation compliance reviews and/or new permits.
Assistance for any newly discovered damaged facilities must be requested within 60 days of the first substantive meeting (typically the Kickoff Meeting) with the applicant.
For large projects, when a change in scope or a need for additional funding is discovered, the applicant should notify the State as soon as possible. It should not be assumed that such costs can be reported at the end of the project and that the additional funds will be approved automatically. The request should contain justification for the eligibility of the additional work or costs. If additional damage to the facility is involved, it may be necessary to show how that damage is disaster-related. The State forwards the request to FEMA with a written recommendation. To determine eligibility, FEMA and the State, in cooperation with the local representatives, may conduct a site visit. The timing of the request should be such that the damaged element can be inspected before it is covered up or repaired. FEMA renders a decision and notifies the State either with an amended PW for additional funding or a written denial of the request.
Small projects are handled differently. If there is a gross error or omission in the scope of work of a small project, the applicant should make a request for a change as described above. Cost overruns are not handled on a project-by-project basis; rather, the applicant may request supplemental funding for a net cost overrun on all small projects by submitting an appeal through the State to FEMA. An appeal should be submitted only when the total costs for all small projects significantly exceed the total cost approved for all small projects. The appeal must be submitted within 60 days of the completion of all of that applicant's small projects. The appeal must include documentation of actual costs including reasons for increased cost or scope of work of all of the projects, including projects with underruns as well as those with overruns.
Except when an appeal is to be submitted, cost documentation for small projects does not need to be submitted to FEMA, but should be retained for 3 years after the date of the applicant's final FSR to the Grantee. If there is no FSR, it should be retained for 3 years from the date of the final certification of completion of the applicant's last project.
Progress reports are critical to ensuring that FEMA and the State have up-to-date information on PA Program grants. Reporting requirements for the PA Program generally concentrate on large projects. Recipients of assistance should check with their State to determine the particular reporting requirements.
The State submits reports quarterly to the RA for projects for which a final payment has not been made. The date of the first report will be determined jointly by the State and the DRM, depending on the circumstances at the time. The progress report will include:
- the status of the project, such as "in design" or "percentage of construction completed";
- time extensions granted, if any;
- a projected completion date;
- the amount of expenditures and amount of payment for each project; and
- any problems or circumstances that could delay the project or result in noncompliance with the conditions of the FEMA approval.
As final payment is made on each large project, the project may be dropped from the report. Final payment for small projects is made at the time of project approval by FEMA and, therefore, small projects do not need to be reported to FEMA.
Other reporting requirements for small projects may vary depending upon the requirements of each State.
FEMA has no reporting requirements for applicants, but the State is expected to impose some reporting requirements on applicants so that it can prepare quarterly reports. The format in which the applicants submit project reports to the State will be determined by the State.
Public assistance grant recipients are required to comply with the provisions set forth under the Single Audit Act of 1984 (Public Law 98-502), as amended in 1996. The act requires grant recipients expending $500,000 or more in Federal funds in a fiscal year ending after December 31, 2003 to perform a single audit or program-specific audit in accordance with OMB Circular A-133, Audits for States, Local Governments, and Non-Profit Organizations.
Even though a single audit must be performed, grant recipients also are subject to additional audits by the DHS Office of the Inspector General and State auditors. OMB requires grant recipients to maintain financial and program records for 3 years beyond the date of final FSR or follow their and the Grantee's standard record retention policy if that policy requires record retention beyond the 3-year requirement. If an FSR is not required, records must be maintained for 3 years from the date of the final certification of completion of the applicant's last project.
Typically, applicants will be informed of audit requirements during the Applicants' Briefing. Any questions after the briefing regarding the single audit, or audits in general, should be directed to the appropriate State official or the DHS's Office of the Inspector General.
This guide describes FEMA's Public Assistance Program's basic provisions and application procedures. Because this document is not exhaustive and the provisions are subject to modification, the information contained herein should be verified with FEMA PA Program officials before becoming the basis for decision making.