o The Applicant, Iowa Emergency Management Division, applied under disaster declaration DR-966-IA for State Management funding to complete the Iowa Geographical Information System (GIS). FEMA Region VII denied approval, the Applicant appealed, and Region VII denied the appeal.
• Reason for Denial
o The proposed use of State Management funding to complete the GIS did not meet the eligibility requirements of the HMGP provided in 44 CFR 206.439, limiting State Management funds to relief of administrative and management costs for major disasters, such as funding of State personnel salaries; and the application was not consistent with 44 CFR Section 13.22, that allowable grant costs must be necessary and reasonable for proper and efficient administration of the grant and not be a general expense required to carry out overall responsibilities of the Applicant.
o 44 CFR 206.439 HMGP Allowable Costs; 44 CFR 13.22 Uniform Administrative Requirements for Grants and Cooperative Agreements, Allowable Costs
o The Applicant claimed that the proposed completion of the GIS met the criteria for eligibility under 44 CFR Part 13.22, and 44 CFR, 206.439.
• FEMA Findings
o The 2nd appeal decision upheld the 1st appeal denial.
o The primary rationale for the decision was that the objectives detailed in the application were intended to benefit the State’s overall emergency management functions and responsibilities, instead of disaster-specific administrative management measures including funding of regular time salaries, applicant briefings, solicitation of projects or technical assistance. The decision stated also that the request to FEMA for State management cost funding was not made before HMGP funding was obligated, and that such a request should have identified needs consistent with the staffing requirements for HMGP grant administration described in the State’s Administrative Plan and based on the staffing pattern developed at the time of the disaster.