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Second Appeal Brief
PA ID# 000-URHXF-00; North Dakota Department of Emergency Services
PW ID# PW 1460; Grant Management Costs
Citation: FEMA-1279-DR-ND, North Dakota Department of Emergency Services,
Grant Management Costs, Project Worksheet (PW) 1460
FEMA prepared Project Worksheet (PW) 1460 for grant management costs for North Dakota Department of Emergency Services (Applicant) following
FEMA-1279-DR-ND declared on June 8, 1999. A 2002 Office of Inspector General (OIG) audit recommended that the Applicant develop a method to allocate labor costs between disasters to reflect actual effort expended. The Applicant concurred with OIG findings and attempted to correct its method of allocating hours between work activities by staff as reflected on timesheets after 2002. FEMA closed out PW 1460 in version 10 of PW 1460 for $846,571. PW 1460 version 10 disallowed $217,007 due to ineligible overtime, undocumented labor costs, ineligible training, and costs incurred prior to the declaration. FEMA considered hours not charged specifically to the disaster on timesheets after 2002 unsupported and denied those costs at closeout. In its first appeal, the Applicant requested that FEMA reinstate $5,991 for labor costs of three employees. The Applicant submitted revised timesheets for the three employees that included tables to reflect distribution of hours to various work activities. The Regional Administrator approved $417 based on new documentation supporting the eligibility of 22 hours worked by one employee.
In its second appeal, the Applicant reasserted its claim for labor costs for two employees for a total of $5,586. The Applicant claimed that the two employees reviewed assignments after original timesheets were submitted for closeout and subsequently allocated hours to the appropriate disaster. The Applicant resubmitted original timesheets and included new undated spreadsheets, signed by the employees, to reflect the distribution of hours per work activity. The Applicant argued that OMB Circular A-87, Cost Principles for State, Local, and Indian Tribe Governments
, does not include a timeframe requirement in which work time must be documented.
Are timesheets modified several years after the hours were worked acceptable supporting documentation?
OMB Circular A-87, Cost Principles for State, Local, and Indian Tribe Governments
; Response and Recovery Policy 9525.7, Labor Costs Emergency Work