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Preparedness Grants Manual | February 2021
1
FEMA
Preparedness Grants
Manual
FEMA Grant Programs Directorate
Version 2, February 2021
Preparedness Grants Manual | February 2021
2
Table of Contents
Table of Contents
2
About the Federal Emergency Management Agency (FEMA)
7
Overview of FEMA
7
Overview of Preparedness Grant Programs
7
Homeland Security Grant Program (HSGP)
7
Tribal Homeland Security Grant Program (THSGP)
7
Nonprofit Security Grant Program (NSGP)
8
Transit Security Grant Program (TSGP)
8
Intercity Bus Security Grant Program (IBSGP)
8
Intercity Passenger Rail (IPR) Program – Amtrak
8
Port Security Grant Program (PSGP)
8
Emergency Management Performance Grant (EMPG) Program
8
Foreword
9
The National Preparedness Goal
9
Pre-Award Application and Submission
10
Pre-Submission Information
10
Agreeing to Terms and Conditions of the Award
10
Address to Request Application Package
11
Steps Required to Obtain a Unique Entity Identifier, Register in the System for Award Management
(SAM), and Submit an Application
11
Electronic Delivery
12
How to Register to Apply through Grants.gov
12
How to Submit an Initial Application to DHS/FEMA via Grants.gov
14
Submitting the Final Application in ND Grants
16
Timely Receipt Requirements and Proof of Timely Submission
16
Content and Form of Application Submission
17
Intergovernmental Review
17
Funding Restrictions and Allowable Costs
17
Award Determination and Obligation
20
Allocations
20
Risk Methodology
20
Application Evaluation Criteria
20
Supplemental Financial Integrity Review
21
Review and Selection Process
21
Federal Award Administration Information
21
Notice of Award
21
Pass-Through Requirements
22
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Administrative and National Policy Requirements
22
Post-Award Management and Implementation
26
Reporting
26
Federal Financial Reporting Requirements
26
Federal Financial Report (FFR)
26
Financial Reporting Periods and Due Dates
26
Program Performance Reporting Requirements
27
Performance Progress Report (PPR)
27
Program Performance Reporting Periods and Due Dates
27
Additional Programmatic Reporting Requirements and Information
27
Biannual Strategy Implementation Report (BSIR)
27
Closeout Reporting Requirements
28
Administrative Closeout
28
Disclosing Information per 2 C.F.R. § 180.335
29
Reporting of Matters Related to Recipient Integrity and Performance
29
Single Audit Report
29
Additional Information
30
Monitoring and Oversight
30
Overview
30
Financial Monitoring Overview and Approach
31
Programmatic Monitoring Overview and Approach
33
Environmental Planning and Historic Preservation (EHP)
34
Case Studies and Use of Grant-Funded Resources During Real-World Incident Operations
34
Conflicts of Interest in the Administration of Federal Awards or Subawards
35
Procurement Integrity
35
Important Changes to Procurement Standards in 2 C.F.R Part 200
36
Competition and Conflicts of Interest
36
Supply Schedules and Purchasing Programs
37
Termination Provisions
39
Period of Performance (POP) Extensions
39
Actions to Address Noncompliance
41
Audits
42
Payment Information
43
Disability Integration
43
National Campaigns and Programs
45
Whole Community Preparedness
45
Active Shooter Preparedness
45
Soft Targets and Crowded Places
46
Community Lifelines
46
Strategic Framework for Countering Terrorism and Targeted Violence
47
Program Appendix A: Homeland Security Grant Program (HSGP)
A-1
Alignment of HSGP to the National Preparedness System
A-1
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HSGP Funding Guidelines
A-2
Reporting on the Implementation of the National Preparedness System
A-20
Identifying and Assessing Risk and Estimating Capability Requirements
A-20
Building and Sustaining Capabilities
A-21
National Incident Management System (NIMS) Implementation
A-21
Planning to Deliver Capabilities
A-22
Validating Capabilities
A-22
Fusion Centers
A-23
Fusion Center Performance Measures
A-25
Continuity of Operations
A-26
Governance
A-27
Supplemental SHSP and UASI Guidance
A-31
Supplemental OPSG Program Guidance
A-34
OPSG Operational Guidance
A-36
HSGP Supplemental Material
A-42
Supplemental Emergency Communications Guidance
A-44
Program Appendix B: Tribal Homeland Security Grant Program (THSGP)
B-1
Alignment of THSGP to the National Preparedness System
B-1
THSGP Funding Guidelines
B-4
THSGP Priorities
B-4
Allowable Costs
B-4
THSGP Investment Modifications – Changes in Scope or Objective
B-12
Program Appendix C: Nonprofit Security Grant Program (NSGP)
C-1
NSGP Funding Guidelines
C-1
NSGP Priorities
C-1
Allowable Costs
C-1
NSGP Investment Modifications – Changes in Scope or Objective
C-7
Pass-Through Requirements
C-8
DUNS/SAM Requirements for Recipients and Subrecipients
C-8
Program Appendix D: Transit Security Grant Program (TSGP)
D-1
TSGP Funding Guidelines
D-1
Pre-Award Costs
D-1
TSGP Priorities
D-1
Security Plan Requirements
D-1
Allowable Direct Costs
D-2
Allowable Indirect Costs
D-12
Unallowable Costs
D-12
Maintenance and Sustainment Costs
D-12
Encouraged Use of Certain Products Produced in the United States
D-13
Program Appendix E: Intercity Bus Security Grant Program (IBSGP)
E-1
IBSGP Priorities
E-1
Pre-Award Costs
E-1
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Allowable Direct Costs
E-1
Indirect Costs (Facilities and Administration [F&A])
E-7
Unallowable Costs
E-8
Other Allowable Costs
E-8
Encouraged Use of Certain Products Produced in the United States
E-9
Program Appendix F: Intercity Passenger Rail (IPR) Program
F-1
IPR Funding Guidelines
F-1
IPR Priorities
F-1
Security Plan Requirements
F-1
Allowable Costs
F-2
Operational Activities
F-2
Funding Availability for OPacks
F-4
Specific Guidance on EDCT
F-5
EDCT Submission Requirements
F-5
Requirements for Small Unmanned Aircraft Systems
F-7
Cybersecurity Projects
F-8
Capital (Construction) Projects Guidance
F-8
Training and Awareness Campaigns
F-9
Management and Administration (M&A)
F-11
Indirect Costs
F-12
Unallowable Costs
F-12
Maintenance and Sustainment Costs
F-12
Encouraged Use of Certain Products Produced in the United States
F-13
Program Appendix G: Port Security Grant Program (PSGP)
G-1
PSGP Funding Guidelines
G-1
PSGP Priorities
G-1
Limitations on Funding
G-1
Allowable Direct Costs
G-2
Allowable Indirect Costs
G-14
Unallowable Costs
G-14
Maintenance and Sustainment Costs
G-15
Port-Wide Risk Management Plans
G-16
Sample Memorandum of Understanding/Agreement (MOU/MOA)
G-16
Program Appendix H: Emergency Management Performance Grant Program
H-1
Alignment of the EMPG Program to the National Preparedness System
H-1
Implementation of the National Preparedness System
H-2
Logistics Planning
H-3
Evacuation Planning
H-5
Disaster Housing Planning
H-5
State Disaster Recovery Coordinator
H-7
Disaster Financial Management Policies and Procedures
H-7
Training and Exercises
H-9
Reviewing and Updating Planning Products
H-12
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Additional Considerations
H-13
Program Performance Reporting Requirements
H-13
EMPG Program Funding Guidelines
H-15
Allowable Costs
H-15
Planning
H-15
Continuity Planning
H-17
Organization
H-17
Equipment
H-18
Training
H-19
Exercises
H-20
Construction and Renovation
H-21
Acquisition of Real Property
H-23
Leasing of Real Property
H-23
Maintenance and Sustainment
H-24
Unallowable Costs
H-24
EMPG Program Work Plan
H-25
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About the Federal Emergency Management
Agency (FEMA)
Overview of FEMA
FEMA has helped people before, during, and after disasters for more than 40 years. FEMA remains
committed to building and developing a culture of preparedness across the country and unifying all levels
of community and government in an integrated approach to emergency management. FEMA is part of a
larger team of federal agencies, state, local, tribal, and territorial (SLTT) governments, and non-
governmental partners that share responsibility for emergency management and national preparedness.
Those closest to impacted areas are the true first responders during any emergency or disaster—
individuals, families, neighbors, and local communities. FEMA’s role is to coordinate federal resources to
supplement SLTT capabilities. FEMA does this by coordinating through the levels of government,
meaning that states and their local political subdivisions, tribes, and territories are our primary partners.
Overview of Preparedness Grant Programs
FEMA has the statutory authority to deliver numerous disaster and non-disaster financial assistance
programs in support of its mission, and that of the Department of Homeland Security, largely through
grants and cooperative agreements. These programs account for a significant amount of the federal funds
for which FEMA is accountable. FEMA officials are responsible and accountable for the proper
administration of these funds pursuant to federal laws and regulations, Office of Management and Budget
circulars, and federal appropriations law principles. FEMA has developed this Manual to provide
additional direction on grant policy and implementation for the following grant programs:
Homeland Security Grant Program (HSGP)
The HSGP includes a suite of risk-based grants to assist SLTT efforts in preventing, preparing for,
protecting against, and responding to acts of terrorism. The grants under HSGP include:
•
State Homeland Security Program (SHSP)
SHSP assists state, local, tribal, and territorial efforts to build, sustain, and deliver the capabilities
necessary to prevent, prepare for, protect against, and respond to acts of terrorism.
•
Urban Area Security Initiative (UASI)
UASI assists high-threat, high-density urban areas’ efforts to build, sustain, and deliver the
capabilities necessary to prevent, prepare for, protect against and respond to acts of terrorism.
•
Operation Stonegarden (OPSG)
OPSG supports enhanced cooperation and coordination among Customs and Border Protection
(CBP), United States Border Patrol (USBP), and federal, state, local, tribal, and territorial law
enforcement agencies to improve overall border security. OPSG provides funding to support joint
efforts to secure the United States’ borders along routes of ingress/egress to and from
international borders, to include travel corridors in states bordering Mexico and Canada, as well
as states and territories with international water borders. SLTT law enforcement agencies utilize
their own law enforcement authorities to support the border security mission and do not receive
any additional authority as a result of participation in OPSG.
Tribal Homeland Security Grant Program (THSGP)
The THSGP provides funding directly to eligible tribes to strengthen their capacity to prevent, prepare
for, protect against, and respond to potential terrorist attacks.
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Nonprofit Security Grant Program (NSGP)
The NSGP provides funding for physical security enhancements and other security-related activities to
nonprofit organizations that are at high risk of a terrorist attack. The NSGP also seeks to integrate the
preparedness activities of nonprofit organizations with broader state and local preparedness efforts.
Transit Security Grant Program (TSGP)
The TSGP provides funds to eligible public transportation systems (which include intra-city bus, ferries,
and all forms of passenger rail) to protect critical transportation infrastructure and the travelling public
from terrorism, and to increase transportation infrastructure resilience.
Intercity Bus Security Grant Program (IBSGP)
The IBSGP provides funds to eligible private operators of intercity over-the-road bus transportation
systems to protect critical transportation infrastructure and travelling public from acts of terrorism, and to
increase transportation infrastructure resilience.
Intercity Passenger Rail (IPR) Program – Amtrak
The IPR provides funds to the National Railroad Passenger Corporation (Amtrak) to protect critical
transportation infrastructure and the travelling public from terrorism, and to increase transportation
infrastructure resilience.
Port Security Grant Program (PSGP)
The PSGP provides funding to port authorities, facility operators, and state and local agencies for
activities associated with implementing Area Maritime Security Plans, facility security plans, and other
port-wide risk management efforts.
Emergency Management Performance Grant (EMPG) Program
The EMPG Program provides funds to assist state, local, tribal, and territorial emergency management
agencies in obtaining the resources required for implementation of the National Preparedness System and
the National Preparedness Goal of a secure and resilient nation.
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Foreword
FEMA has developed this Preparedness Grants Manual to guide applicants and grant recipients on how
to manage their grants and other resources. Recipients seeking guidance on policies and procedures for
managing preparedness grants should reference this Manual for further information on both program-
specific information as well as overall guidance on rules and regulations that guide the proper
management of FEMA grants.
The National Preparedness Goal
The National Preparedness Goal (the Goal) is “[a] secure and resilient Nation with the capabilities
required across the whole community to prevent, protect against, mitigate, respond to, and recover from
the threats and hazards that pose the greatest risk.” See Department of Homeland Security, National
Preparedness Goal, Second Edition, 1 (Sept. 2015). The Goal essentially defines what it means for all
communities to be prepared collectively for the threats and hazards that pose the greatest risk to the
nation. The Goal identifies 32 distinct activities, called core capabilities, needed to address the risks. The
Goal organizes these core capabilities into five categories, called mission areas. Some core capabilities
apply to more than one mission area. For example, the first three core capabilities—Planning, Public
Information and Warning, and Operational Coordination—are cross-cutting capabilities, meaning they
apply to each of the five mission areas. The Goal describes the five mission areas as follows:
•
Prevention: Prevent, avoid or stop an imminent, threatened or actual act of terrorism.
•
Protection: Protect our citizens, residents, visitors, and assets against the greatest threats and
hazards in a manner that allows our interests, aspirations and way of life to thrive.
•
Mitigation: Reduce the loss of life and property by lessening the impact of future disasters.
•
Response: Respond quickly to save lives, protect property and the environment, and meet basic
human needs in the aftermath of an incident.
•
Recovery: Recover through a focus on the timely restoration, strengthening and revitalization of
infrastructure, housing and a sustainable economy, as well as the health, social, cultural, historic,
and environmental fabric of communities affected by an incident.
The mission areas and core capabilities organize the activities and tasks performed before, during, and
after disasters into a framework for achieving the goal of a secure and resilient Nation. Resilience is the
desired outcome, defined in the Goal as the “ability to adapt to changing conditions and withstand and
rapidly recover from disruption due to emergencies.” Id. at A-2. For more information about the Goal, go
to https://www.fema.gov/national-preparedness-goal.
Recipients will use the National Preparedness System to build, sustain, and deliver these core capabilities.
The components of the National Preparedness System are: Identifying and Assessing Risk, Estimating
Capability Requirements, Building and Sustaining Capabilities, Planning to Deliver Capabilities,
Validating Capabilities, and Reviewing and Updating. Additional information on the National
Preparedness System is available at http://www.fema.gov/national-preparedness-system. Additional
details regarding the National Preparedness System and how it is supported by these grant programs can
be found in the program-specific appendices.
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Pre-Award Application and Submission
Pre-Submission Information
These instructions apply to the following programs:
•
Homeland Security Grant Program1
•
Tribal Homeland Security Grant Program
•
Nonprofit Security Grant Program
•
Transit Security Grant Program
•
Intercity Bus Security Grant Program
•
Intercity Passenger Rail Program
•
Port Security Grant Program
•
Emergency Management Performance Grant Program
All applications must be received by the established deadline established in each program’s Notice of
Funding Opportunity (NOFO). The Non-Disaster (ND) Grants System has a date stamp that indicates
when an application is submitted. Applicants will receive an electronic message confirming receipt of
their submission. For additional information on how an applicant will be notified of application receipt,
see the section titled “Timely Receipt Requirements and Proof of Timely Submission.”
FEMA will not review applications that are received after the deadline nor will it consider these
late applications for funding. FEMA may, however, extend the application deadline on request for an
applicant who can demonstrate that good cause exists to justify extending the deadline. Good cause for an
extension may include technical problems outside of the applicant’s control that prevent submission of the
application by the deadline, other exigent or emergency circumstances, or statutory requirements for
FEMA to make an award.
Applicants experiencing technical problems outside of their control must notify the respective
FEMA Preparedness Officer or Program Manager as soon as possible and before the application
deadline. Failure to timely notify FEMA of the issue that prevented the timely filing of the application
may preclude consideration of the award. “Timely notification” of FEMA means the following: prior to
the application deadline and within 48 hours after the applicant became aware of the issue.
For additional assistance using the ND Grants System, please contact the ND Grants Service Desk at
(800) 865-4076 or NDGrants@fema.dhs.gov. The ND Grants Service Desk is available Monday through
Friday, 9:00 a.m. – 6:00 p.m. ET. For programmatic or grants management questions, please contact your
Preparedness Officer or Program Manager. If applicants do not know their FEMA Preparedness Officer
or if there are programmatic questions or concerns, please contact the Centralized Scheduling and
Information Desk (CSID) by phone at (800) 368-6498 or by e-mail at askcsid@fema.dhs.gov, Monday
through Friday, 9:00 a.m. – 5:00 p.m. ET.
Agreeing to Terms and Conditions of the Award
By submitting an application, the applicant agrees to comply with the requirements of the applicable
NOFO, this Manual, and the applicable appendix to this Manual, as well as the terms and conditions of its
award should it receive an award.
1 Under this program, these instructions apply to SHSP, UASI, and OPSG.
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Address to Request Application Package
Initial applications are processed through the Grants.gov portal. Final applications are completed and
submitted through FEMA’s ND Grants System. Application forms and instructions are available on
Grants.gov; hard copies of the NOFO and associated application materials are not available. To access
these materials, go to http://www.grants.gov, select “Applicants” then “Apply for Grants”. In order to
obtain the application package, select “Download a Grant Application Package”. Enter the Assistance
Listing (formerly CFDA) and/or the funding opportunity number located on the cover of the program’s
NOFO, select “Download Package,” and then follow the prompts to download the application package. In
addition, the following Telephone Device for the Deaf (TDD) and/or Federal Information Relay Service
(FIRS) number available for this Notice and all relevant NOFOs is (800) 462-7585.
Steps Required to Obtain a Unique Entity Identifier, Register in the System
for Award Management (SAM), and Submit an Application
Applying for an award under the programs covered by this Manual is a multi-step process and requires
time to complete. Applicants are encouraged to register early. The registration process can take four or
more weeks to be completed. Therefore, registration should be done with enough sufficient time to ensure
it does not impact the applicant’s ability to meet required submission deadlines. Failure of an applicant to
comply with any of the required steps in submitting an application before the deadline may disqualify that
application from funding consideration.
In order to apply for an award, all applicants must:
1. Apply for, update, or verify their Data Universal Numbering System (DUNS) number from Dun
& Bradstreet and Employer Identification Number (EIN) from the Internal Revenue Service;
2. In the application, provide a valid DUNS number, which is currently the unique entity identifier;
3. Have an account with login.gov;
4. Register for, update, or verify their SAM account and ensure the account is active before
submitting the application;
5. Create a Grants.gov account;
6. Add a profile to a Grants.gov account;
7. Establish an Authorized Organizational Representative (AOR) in Grants.gov;
8. Register in ND Grants;
9. Submit an initial application in Grants.gov;
10. Submit the final application in ND Grants, including electronically signing applicable
forms; and
11. Continue to maintain an active SAM registration with current information at all times during
which it has an active federal award or an application or plan under consideration by a federal
awarding agency.
Specific instructions on how to apply for, update, or verify a DUNS number or SAM registration or
establish an AOR are included in the steps below for applying through Grants.gov. Applicants are advised
that FEMA may not make a federal award until the applicant has complied with all applicable DUNS and
SAM requirements. Therefore, an applicant’s SAM registration must be active not only at the time of
application, but also during the application review period and when FEMA is ready to make a federal
award. Further, as noted above, an applicant’s or recipient’s SAM registration must remain active for the
duration of an active federal award. If an applicant’s SAM registration is expired at the time of
application, expires during application review, or expires any other time before award, FEMA may
determine that the applicant is not qualified to receive a federal award and use that determination as a
basis for making a federal award to another applicant.
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Electronic Delivery
FEMA is participating in the Grants.gov initiative to provide the grant community with a single site to
find and apply for grant funding opportunities. FEMA requires applicants to submit their initial
applications online through Grants.gov and to submit their final applications through ND Grants.
How to Register to Apply through Grants.gov
1. Instructions: Registering and applying for an award under these programs is a multi-step process
and requires time to complete. Read the instructions below about registering to apply for FEMA
funds. Applicants should read the registration instructions carefully and prepare the information
requested before beginning the registration process. Reviewing and assembling the required
information before beginning the registration process will alleviate last-minute searches for
required information.
The registration process can take up to four weeks to complete. To ensure an application
meets the deadline, applicants are advised to start the required steps well in advance of their
submission.
Organizations must have a DUNS Number, EIN, and an active SAM registration.
Organizations must also have a Grants.gov account to apply for an award under these programs.
Creating a Grants.gov account can be completed online in minutes, but DUNS and SAM
registrations may take several weeks. Therefore, an organization’s registration should be done in
sufficient time to ensure it does not impact the entity’s ability to meet the required application
submission deadlines. Complete organizational instructions can be found on Grants.gov.
If individual applicants are eligible to apply for a grant funding opportunity, refer to
https://www.grants.gov/web/grants/applicants/registration.html to create an account with
Grants.gov.
2. Obtain a DUNS Number: All entities applying for funding, including renewal funding, must
have a DUNS number from Dun & Bradstreet. Applicants must enter the DUNS number in the
data entry field labeled "Organizational DUNS" on the SF-424 form.
For more detailed instructions for obtaining a DUNS number, refer to
https://www.grants.gov/web/grants/applicants/organization-registration/step-1-obtain-duns-
number.html.
Note: At some point, the DUNS Number will be replaced by a “new, non-proprietary identifier”
requested in, and assigned by, SAM.gov. This new identifier is being called the Unique Entity
Identifier (UEI), or the Entity ID. Grants.gov has begun preparing for this transition by educating
users about the upcoming changes and updating field labels and references to the DUNS Number
(the current identifier) within the Grants.gov system. Users should continue using the DUNS
Number in UEI fields until further notice. To learn more about SAM’s rollout of the UEI, please
visit https://gsa.gov/entityid.
3. Obtain Employer Identification Number: In addition to having a DUNS number, all entities
applying for funding must provide an EIN. The EIN can be obtained from the IRS by visiting:
https://www.irs.gov/businesses/small-businesses-self-employed/apply-for-an-employer-
identification-number-ein-online.
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4. Create a login.gov account: Applicants must have a login.gov account in order to register with
SAM or update their SAM registration. Applicants can create a login.gov account here:
https://secure.login.gov/sign_up/enter_email?request_id=34f19fa8-14a2-438c-8323-
a62b99571fd3.
Applicants only have to create a login.gov account once. For applicants that are existing SAM
users, use the same email address for the login.gov account as with SAM.gov so that the two
accounts can be linked.
For more information on the login.gov requirements for SAM registration, refer to:
https://www.sam.gov/SAM/pages/public/loginFAQ.jsf.
5. Register with SAM: In addition to having a DUNS number, all organizations applying online
through Grants.gov must register with SAM. Failure to register with SAM will prevent your
organization from applying through Grants.gov. SAM registration must be renewed annually.
For more detailed instructions for registering with SAM, refer to
https://www.grants.gov/web/grants/applicants/organization-registration/step-2-register-with-
sam.html.
Note: As a new requirement per 2 C.F.R. § 25.200, applicants must also provide the applicant’s
immediate and highest-level owner, subsidiaries, and predecessors that have been awarded
federal contracts or federal financial assistance within the last three years, if applicable.
a. Additional SAM Reminders
Existing SAM.gov account holders should check their account to make sure it is “ACTIVE.”
SAM registration should be completed at the very beginning of the application period and
should be renewed annually to avoid being “INACTIVE.” Please allow plenty of time before
the grant application submission deadline to obtain a DUNS number and then to register
in SAM. It may be four weeks or more after an applicant submits the SAM registration
before the registration is active in SAM, and then it may be an additional 24 hours before
FEMA’s system recognizes the information.
It is imperative that the information applicants provide is correct and current. Please ensure that
your organization’s name, address, DUNS number, and EIN are up to date in SAM and that the
DUNS number used in SAM is the same one used to apply for all other FEMA awards.
Payment under any FEMA award is contingent on the recipient’s having a current SAM
registration.
b. Help with SAM
The SAM quick start guide for new recipient registration and SAM video tutorial for new
applicants are tools created by the General Services Administration to assist those registering
with SAM. If applicants have questions or concerns about a SAM registration, please contact
the Federal Support Desk at https://www.fsd.gov/fsd-gov/home.do or call toll free (866) 606-
8220.
6. Create a Grants.gov Account: The next step in the registration process is to create an account
with Grants.gov. Applicants must know their or their organization’s DUNS number to complete
this process.
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14
For more information, follow the on-screen instructions or refer to
https://www.grants.gov/web/grants/applicants/registration.html.
7. Add a Profile to a Grants.gov Account: A profile in Grants.gov corresponds to a single
applicant organization the user represents (i.e. an applicant) or an individual applicant. If you
work for or consult with multiple organizations and have a profile for each, you may log in to one
Grants.gov account to access all of your grant applications. To add an organizational profile to
your Grants.gov account, enter the DUNS Number for the organization in the DUNS field while
adding a profile.
For more detailed instructions about creating a profile on Grants.gov, refer to
https://www.grants.gov/web/grants/applicants/registration/add-profile.html.
8. EBiz POC Authorized Profile Roles: After you register with Grants.gov and create an
Organization Applicant Profile, the organization applicant’s request for Grants.gov roles and
access are sent to the EBiz POC. The EBiz POC will then log in to Grants.gov and authorize the
appropriate roles, which may include the AOR role, thereby giving you permission to complete
and submit applications on behalf of the organization. You will be able to submit your application
online any time after you have been assigned the AOR role.
For more detailed instructions about creating a profile on Grants.gov, refer to
https://www.grants.gov/web/grants/applicants/registration/authorize-roles.html.
9. Track Role Status: To track your role request, refer to
https://www.grants.gov/web/grants/applicants/registration/track-role-status.html.
10. Electronic Signature: When applications are submitted through Grants.gov, the name of the
organization applicant with the AOR role that submitted the application is inserted into the
signature line of the application, serving as the electronic signature. The EBiz POC must
authorize individuals who are able to make legally binding commitments on behalf of the
organization as an AOR. Please ensure you have been authorized by the EBiz POC as this step is
often missed, and it is crucial for valid and timely submissions.
How to Submit an Initial Application to DHS/FEMA via Grants.gov
Standard Form 424 (SF 424) is the initial application form.
Grants.gov applicants can apply online using a workspace. A workspace is a shared, online environment
where members of a grant team may simultaneously access and edit different web forms within an
application. For each NOFO, you can create individual instances of a workspace. Applicants are
encouraged to submit their initial applications in Grants.gov at least seven days before the application
deadline.
In Grants.gov, applicants need to submit the following forms:
•
SF-424, Application for Federal Assistance
•
Grants.gov Lobbying Form, Certification Regarding Lobbying
Below is an overview of applying on Grants.gov. For access to complete instructions on how to apply for
opportunities using a workspace, refer to: https://www.grants.gov/web/grants/applicants/workspace-
overview.html
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1. Create a Workspace: Creating a workspace allows you to complete it online and route it through
your organization for review before submitting.
2. Complete a Workspace: Add participants to the workspace to work on the application together,
complete all the required forms online or by downloading PDF versions, and check for errors
before submission.
3. Adobe Reader: If you decide not to apply by filling out web forms, you can download individual
PDF forms in Workspace so that they will appear similar to other Standard or DHS/FEMA forms.
The individual PDF forms can be downloaded and saved to your local device storage, network
drive(s), or external drives, and then accessed through Adobe Reader.
NOTE: Visit the Adobe Software Compatibility page on Grants.gov to download the appropriate
version of the software at https://www.grants.gov/web/grants/applicants/adobe-software-
compatibility.html.
4. Mandatory Fields in Forms: In the forms, you will note fields marked with an asterisk and a
different background color. These fields are mandatory fields that must be completed to
successfully submit your application.
5. Complete SF-424 Fields First: The forms are designed to fill in common required fields across
other forms, such as the applicant name, address, and DUNS number. To trigger this feature, an
applicant must complete the SF-424 information first. Once it is completed, the information will
transfer to the other forms.
6. Submit a Workspace: An application may be submitted through workspace by clicking the
“Sign and Submit” button on the Manage Workspace page, under the Forms tab. Grants.gov
recommends submitting your application package at least 24-48 hours prior to the close date to
provide you with time to correct any potential technical issues that may disrupt the application
submission.
7. Track a Workspace: After successfully submitting a workspace package, a Grants.gov Tracking
Number (GRANTXXXXXXXX) is automatically assigned to the application. The number will be
listed on the confirmation page that is generated after submission. Using the tracking number,
access the Track My Application page under the Applicants tab or the Details tab in the submitted
workspace.
Additional Training and Applicant Support: For additional training resources, including video
tutorials, refer to https://www.grants.gov/web/grants/applicants/applicant-training.html.
Grants.gov provides applicants 24/7 support via the toll-free number 1-800-518-4726 and email at
support@grants.gov. For questions related to a specific grant contact the number listed in the NOFO of
the grant for which you are applying.
If you are experiencing difficulties with your submission, it is best to call the Grants.gov Support Center
and get a ticket number. The Support Center ticket number will assist FEMA with tracking your issue and
understanding background information on the issue.
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Submitting the Final Application in ND Grants
After submitting the initial application in Grants.gov, eligible applicants will be notified by FEMA and
asked to proceed with submitting their complete application package in ND Grants. Applicants can
register early with ND Grants and are encouraged to begin their ND Grants registration at the time of the
NOFO announcement or, at the latest, seven days before the application deadline. Early registration will
allow applicants to have adequate time to start and complete their applications.
Applicants needing assistance registering for the ND Grants system should contact
ndgrants@fema.dhs.gov or (800) 865-4076. For step-by-step directions on using the ND Grants system
and other guides, please see https://www.fema.gov/grants/guidance-tools/non-disaster-grants-
management-system.
In ND Grants, applicants will be prompted to submit the standard application information required as
described in the “Content and Form of Application Submission” section below. The Standard Forms
(SFs) are auto-generated in ND Grants, but applicants may access these forms in advance through the
Forms tab under the SF-424 family on Grants.gov. Applicants should review these forms before applying
to ensure they have all the information required.
An application submitted by an otherwise eligible non-federal entity (i.e., the applicant) may be deemed
ineligible when the person that submitted the application is not: 1) a current employee, personnel,
official, staff, or leadership of the non-federal entity; and 2) duly authorized to apply for an award on
behalf of the non-federal entity at the time of application.
Further, the AOR must be a duly authorized current employee, personnel, official, staff or leadership of
the recipient and provide an email address unique to the recipient at the time of application and upon
any change in assignment during the period of performance. Consultants or contractors of the
recipient are not permitted to be the AOR of the recipient.
For program-specific application submission requirements, please refer to the applicable program NOFO
and applicable appendix to this Manual.
Timely Receipt Requirements and Proof of Timely Submission
As application submission is a two-step process, the applicant with the AOR role who submitted the
application in Grants.gov will receive an acknowledgement of receipt, a tracking number
(GRANTXXXXXXXX) from Grants.gov with the successful transmission of its initial application. This
notification does not serve as proof of timely submission, as the application is not complete until it is
submitted in ND Grants. Applicants can also view the ND Grants Agency Tracking Number by
accessing the Details tab in the submitted workspace section in Grants.gov, under the Agency Tracking
Number column. Should the Agency Tracking Number not appear, the application has not yet migrated
from Grants.gov into the ND Grants system. Please allow 24 hours for your ND Grants application
tracking number to migrate.
All applications must be received in ND Grants by 5:00 PM ET on the application deadline. Proof of
timely submission is automatically recorded by ND Grants. An electronic date/time stamp is generated
within the system when the application is successfully received by ND Grants. Additionally, the
applicant(s) listed as contacts on the application will receive a system-generated email to confirm receipt.
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Content and Form of Application Submission
Standard Required Application Forms and Information
For all programs, the following forms or information are required to be submitted in either Grants.gov or
ND Grants. The SFs are submitted either through Grants.gov, through forms generated in ND Grants, or
as an attachment in ND Grants. Applicants may also access the SFs at
https://www.grants.gov/web/grants/forms/sf-424-family.html.
Grants.gov:
•
SF-424, Application for Federal Assistance, submitted through Grants.gov
•
Grants.gov Lobbying Form, Certification Regarding Lobbying, submitted through
Grants.gov
ND Grants:
•
SF-424A, Budget Information (Non-Construction), submitted via the forms generated by ND
Grants
o For construction under an award, submit: SF-424C, Budget Information
(Construction), submitted via the forms generated by ND Grants, in addition to or
instead of SF-424A
•
SF-424B, Standard Assurances (Non-Construction), submitted via the forms generated by ND
Grants
o For construction under an award, submit: SF-424D, Standard Assurances
(Construction), submitted via the forms generated by ND Grants, in addition to or
instead of SF-424B
•
SF-LLL, Disclosure of Lobbying Activities, submitted via the forms generated by ND Grants
•
Indirect Cost Agreement or Proposal, submitted as an attachment in ND Grants if the budget
includes indirect costs and the applicant is required to have an indirect cost rate agreement or
proposal. If the applicant does not have or is not required to have an indirect cost rate agreement
or proposal, please see the “Funding Restrictions and Allowable Costs” section in the relevant
program NOFO and the section below on indirect costs for further information regarding
allowability of indirect costs and whether alternatives to an indirect cost rate agreement or
proposal might be available, or contact the relevant Preparedness Officer or Program Manager for
further instructions.
Generally, applicants have to submit either the non-construction forms (i.e., SF-424A and SF-424B) or
construction forms (i.e., SF-424C and SF-424D), meaning that applicants that only have construction
work and do not have any non-construction work need only submit the construction forms (i.e., SF-424C
and SF-424D) and not the non-construction forms (i.e., SF-424A and SF-424B), and vice versa. However,
applicants who have both construction and non-construction work under these programs need to submit
both the construction and non-construction forms.
Intergovernmental Review
An intergovernmental review may be required. Applicants must contact their state’s Single Point of
Contact to comply with the state’s process under Executive Order 12372.
See https://www.archives.gov/federal-register/codification/executive-order/12372.html;
https://www.whitehouse.gov/wp-content/uploads/2020/01/spoc_1_16_2020.pdf.
Funding Restrictions and Allowable Costs
All costs charged to awards covered by this Manual must comply with the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements at 2 C.F.R. Part 200, unless otherwise indicated
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in this Manual, the applicable program NOFO, or the terms and conditions of the award. This includes,
among other requirements, that costs must be incurred, and products and services must be delivered,
within the period of performance of the award. See 2 C.F.R. § 200.403(h) (referring to budget periods,
which for FEMA preparedness grant awards is the same as the period of performance).
Federal funds made available through these awards may be used for the purposes set forth in this Manual,
the applicable program NOFO, and the terms and conditions of the award and must be consistent with the
statutory authority for the award. Award funds may not be used for matching funds for any other federal
awards, lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal
funds may not be used to sue the Federal Government or any other government entity.
In general, the Cost Principles establish standards for the allowability of costs, provide detailed guidance
on the cost accounting treatment of costs as direct or administrative costs, and set forth allowability
principles for selected items of cost. More specifically, except as otherwise stated in the applicable
program appendix to this Manual, the program NOFO, or the terms and condition of an award, costs
charged to awards covered by this Manual must be consistent with the Cost Principles for Federal Awards
located at 2 C.F.R. Part 200, Subpart E. In order to be allowable, all costs charged to a FEMA award or
applied to the cost share must be reasonable in nature and amount and allocable to the particular FEMA
award.
Additionally, all costs charged to awards must comply with the grant program’s applicable statutes,
policies, NOFOs, and requirements in this Manual as well as with the terms and conditions of the award.
If FEMA staff identify costs that are inconsistent with any of these requirements, these costs may be
disallowed, and FEMA may recover funds as appropriate, consistent with applicable laws, regulations,
and policies.
As part of those requirements, grant recipients and subrecipients may only use federal funds or funds
applied to a cost share for the purposes set forth in this Manual, applicable NOFOs, and the terms and
conditions of the award and must be consistent with the statutory authority for the award.
Specific investments made in support of the funding priorities discussed in the appendices to this Manual
generally fall into one of the following eight allowable expense categories:
1. Construction
2. Equipment
3. Exercises
4. Management & Administration (M&A)
5. Organization
6. Operational Activities
7. Planning
8. Training
Please refer to the relevant program-specific appendix for more information on funding restrictions,
funding priorities, and these categories.
Authorized Equipment List
The Authorized Equipment List (AEL) is a list of approved equipment types allowed under FEMA’s
preparedness grant programs. The intended audience of this tool is emergency managers, first responders,
and other homeland security professionals. The list consists of equipment categories divided into
categories, sub-categories and then individual equipment items.
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Prohibitions on Expending Grant or Cooperative Agreement Funds for Certain
Telecommunications and Video Surveillance Services or Equipment
Recipients and subrecipients of FEMA federal financial assistance are subject to the prohibitions
described in section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019
(FY 2019 NDAA), Pub. L. No. 115-232 (2018) and 2 C.F.R. §§ 200.216, 200.326, 200.471, and
Appendix II to 2 C.F.R. Part 200. Beginning August 13, 2020, the statute – as it applies to FEMA
recipients, subrecipients, and their contractors and subcontractors – prohibits obligating or expending
federal award funds on certain telecommunications and video surveillance products and contracting with
certain entities for national security reasons. For additional guidance, please refer to FEMA Policy #405-
143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or
Services (Interim).
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Award Determination and Obligation
Allocations
Risk Methodology
DHS defines risk as: “potential for an adverse outcome assessed as a function of hazard/threats, assets and
their vulnerabilities, and consequences.” See DHS Lexicon Terms and Definitions: 2017 Edition –
Revision 2, (Oct. 2017). The FEMA risk methodology is focused on three elements:
•
Threat: the likelihood of an attack being attempted by an adversary
•
Vulnerability: the likelihood that an attack is successful, given that it is attempted
•
Consequence: the effect of an event, incident, or occurrence
Please see the applicable appendix of this Manual for each award program for specific information on the
risk methodology applied for each program.
Application Evaluation Criteria
Programmatic Criteria
See the Manual appendices and relevant program NOFOs for specific information on the application
criteria specific to each program.
Financial Integrity Criteria
Prior to making a federal award, FEMA is required by 31 U.S.C. § 3354, as amended by the Payment
Integrity Information Act of 2019, Pub. L. No. 116-117 (2020); 41 U.S.C. § 2313; and 2 C.F.R. § 200.206
to review information available through any Office of Management and Budget (OMB)-designated
repositories of governmentwide eligibility qualification or financial integrity information, including
whether the applicant is suspended or debarred. FEMA may also pose additional questions to the
applicant to aid in conducting the pre-award risk review. Therefore, application evaluation criteria may
include the following risk-based considerations of the applicant:
i.
Financial stability.
ii. Quality of management systems and ability to meet management standards.
iii. History of performance in managing federal award.
iv. Reports and findings from audits.
v. Ability to effectively implement statutory, regulatory, or other requirements.
All investments selected for recommendation will also undergo an additional risk review conducted by
the FEMA Grants Management Specialist to evaluate the risk for noncompliance in carrying out the
federal award. Using their subject-matter expertise, the questions the FEMA Grants Management
Specialist may assess include, but are not limited to:
•
Is the applicant on any exclusion lists as identified in SAM.gov?
•
If the applicant has received federal funding in the past, has the applicant performed all audits
required by the Single Audit requirements under 2 C.F.R. Part 200, Subpart F?
•
Has the applicant provided sufficient budget information and justification as required by the
NOFO?
•
Are the costs proposed by the applicant in the budget information and justification allowable and
reasonable based on the criteria set forth in this Manual and the applicable appendix, NOFO, and
regulations?
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•
Is the budget representative of the total cost of performance of the projects?
•
If indirect costs are included, is the applicant required to have an approved indirect cost rate
agreement? If so, has the applicant provided an approved indirect cost rate agreement?
•
Is the applicant delinquent on any federal debt?
•
Has the applicant had substandard performance in a prior award?
•
Is the applicant on the Do Not Pay List?
Based on the outcome of this review, FEMA may determine that it will not make an award to an applicant
that poses a risk of noncompliance. FEMA may also determine that it will make an award to an at-risk
applicant, subject to additional terms and conditions as described in 2 C.F.R. § 200.208.
Supplemental Financial Integrity Review
Prior to making a federal award where the anticipated federal share will be greater than the simplified
acquisition threshold, currently $250,000:
•
FEMA is required to review and consider any information about the applicant in the designated
integrity and performance system accessible through SAM, which is currently the Federal
Awardee Performance and Integrity Information System (FAPIIS) and is accessible through the
SAM website.
•
An applicant, at its option, may review information in FAPIIS and comment on any information
about itself that a federal awarding agency previously entered.
•
FEMA will consider any comments by the applicant, in addition to the other information in
FAPIIS, in making a judgment about the applicant’s integrity, business ethics, and record of
performance under federal awards when completing the review of risk posed by applicants, as
described in 2 C.F.R. § 200.206.
Review and Selection Process
FEMA will follow all applicable statutes, rules, and requirements and will take into consideration
materials accompanying the annual appropriations acts, such as the Joint Explanatory Statement, as
appropriate, in reviewing and selecting recipients.
Please see the applicable NOFO for the review and selection process for that program.
Federal Award Administration Information
Notice of Award
Before accepting the award, the AOR and recipient should carefully review the award package. The
award package includes instructions on administering the grant award and the terms and conditions
associated with responsibilities under federal awards. Recipients must accept all conditions in the
applicable program NOFO as well as this Manual, in addition to any special terms and conditions in the
Notice of Award to receive an award under the applicable program.
Notification of award approval is made through the ND Grants system through an automatic electronic
mail to the recipient’s authorized official listed in the initial application. The award date will be the date
that FEMA approves the award. The recipient should follow the directions in the notification to confirm
acceptance of the award. Funds will remain on hold until the recipient accepts the award through the ND
Grants system and all other conditions of the award have been satisfied or until the award is otherwise
rescinded.
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Recipients must accept their awards no later than 60 days from the award date. The recipient shall notify
FEMA of its intent to accept and proceed with work under the award or provide a notice of intent to
decline through the ND Grants system. For instructions on how to accept or decline an award in the ND
Grants system, please see the Grant Recipient User Guide. Failure to accept a grant award within the 60-
day timeframe may result in a loss of funds.
Pass-Through Requirements
Please see the applicable NOFO and appendix to this Manual for information on pass-through
requirements for that program.
Administrative and National Policy Requirements
All successful applicants for all FEMA grant and cooperative agreements are required to comply with
DHS Standard Terms and Conditions.
The applicable DHS Standard Terms and Conditions will be those in effect at the time the award was
made. The specific terms and conditions that will apply for the award will be clearly stated in the award
package at the time of award.
Environmental Planning and Historic Preservation (EHP) Compliance
As a federal agency, FEMA is required to consider the effects of its actions on the environment and
historic properties to ensure that all activities and programs funded by FEMA, including grant-funded
projects, comply with federal EHP regulations, laws, and Executive Orders, as applicable.
Recipients and subrecipients proposing projects that have the potential to impact the environment,
including, but not limited to, the construction of communication towers, modification or renovation
of existing buildings, structures, and facilities, new construction including replacement of facilities,
and some training activities, must participate in the FEMA EHP review process. The EHP review
process involves the submission of a detailed project description along with any supporting
documentation requested by FEMA in order to determine whether the proposed project has the potential
to impact environmental resources or historic properties. A GPD EHP screening form and supporting
documentation for preparedness projects requiring EHP review should be submitted to
gpdehpinfo@fema.dhs.gov.
In some cases, FEMA is also required to consult with other regulatory agencies and the public in order to
complete the review process. The EHP review process must be completed before funds are released to
carry out the proposed project; otherwise, FEMA may not be able to fund the project due to
noncompliance with EHP laws, Executive Orders, regulations, and policies.
DHS and FEMA EHP policy is found in directives and instructions available on the FEMA.gov EHP
page, the FEMA website page that includes documents regarding EHP responsibilities and program
requirements, including implementation of the National Environmental Policy Act and other EHP
regulations and Executive Orders.
The GPD EHP screening form is located at https://www.fema.gov/media-library/assets/documents/90195.
Additionally, all recipients under this funding opportunity are required to comply with the FEMA GPD
EHP Policy Guidance, FEMA Policy #108-023-1, available at https://www.fema.gov/media-
library/assets/documents/85376.
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Ensuring the Protection of Civil Rights
As the Nation works towards achieving the National Preparedness Goal, it is important to continue to
protect the civil rights of individuals. Recipients must carry out their programs and activities, including
those related to the building, sustainment, and delivery of core capabilities, in a manner that respects and
ensures the protection of civil rights for protected populations.
Federal civil rights statutes, such as Section 504 of the Rehabilitation Act of 1973 and Title VI of the
Civil Rights Act of 1964, along with FEMA regulations, prohibit discrimination on the basis of race,
color, national origin, sex, religion, age, disability, limited English proficiency, or economic status in
connection with programs and activities receiving federal financial assistance from FEMA.
The DHS Standard Terms and Conditions include a fuller list of the civil rights provisions that apply to
recipients. These terms and conditions can be found in the DHS Standard Terms and Conditions.
Additional information on civil rights provisions is available at https://www.fema.gov/office-equal-rights.
Monitoring and oversight requirements in connection with recipient compliance with federal civil rights
laws are also authorized pursuant to 44 C.F.R Part 7.
FirstNet
The Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, as amended (codified in
part at 47 U.S.C. §§ 1401-1473) established the First Responder Network Authority (hereinafter FirstNet
Authority) as an independent authority within the National Telecommunications and Information
Administration (NTIA). 47 U.S.C. § 1424(a). The FirstNet Authority’s statutory mission is to establish a
nationwide public safety broadband network (FirstNet). 47 U.S.C. § 1426(b). FirstNet uses the 700 MHz
D block spectrum to provide Long-Term Evolution (LTE)-based broadband services and applications to
public safety entities. 47 U.S.C. §§ 1401(2), 1421(a). FirstNet became operational in March 2018 and is
based on a single, national network architecture that evolves with technological advances and consists of
a physically separate evolved packet core (EPC) network and radio access networks (RANs).
FirstNet provides public safety entities with mission-critical broadband data capabilities and services
including, but not limited to messaging, image sharing, video streaming, group text, voice, data storage,
application, location-based services, and Quality of Service, Priority, and Preemption. Public safety
entities seeking to enhance their operational capabilities using broadband technology may seek grant
funding from appropriate programs to support the following:
•
Planning for integration of information technology (IT) infrastructure, software, and site upgrades
necessary to connect to FirstNet
•
Handheld broadband devices including smartphones, feature phones, tablets, wearables, push-to-
talk (PTT) devices
•
Vehicle-mounted or otherwise field operated data devices, such as ruggedized laptops
•
Network access devices, including portable Wi-Fi devices, Universal Serial Bus (USB)
modems/dongles, trunk-mounted modems, routers
•
Customer-Owned and Managed (COAM) broadband deployable equipment, enabling public
safety to own and dispatch coverage expansion or capacity enhancement equipment within their
jurisdiction
•
Broadband device accessories that enable efficient and safe public safety operations such as
headsets, belt clips, earpieces, remote Bluetooth sensors, ruggedized cases
•
Subscriber Identification Modules (SIMs)/Universal Integrated Circuit Cards (UICCs) to allow
public safety users to update existing devices to operate on public safety prioritized services.
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•
One-time purchase and subscription-based applications for public safety use which could include,
among several other options, enterprise mobility management (EMM), mobile device
management (MDM), mobile Virtual Private Network (VPN), identity services, or cloud service
tools
As FirstNet is built out in all 56 states and territories and coverage and capacity for first responders
expands, recipients are strongly encouraged to coordinate with the Statewide Interoperability Coordinator
(SWIC) and FirstNet on the planning, deployment timelines, and operational availability of the network
deployment within a specific state or territory and to ensure that project does not conflict with network
planning efforts and complies with all technical requirements. FirstNet requires participating agencies to
demonstrate a subscription to public safety-prioritized broadband services to purchase FirstNet broadband
devices or applications. FEMA Information Bulletin (IB) #386 has been rescinded by prior NOFOs and
remains rescinded as the technical requirements and nationwide network architecture has been developed,
and FirstNet is operational. Recipients, however, must coordinate with FirstNet in advance of any
strategic acquisition of broadband LTE equipment to ensure that purchases adhere to all applicable
standards for public safety entities. Recipients with questions on FirstNet should contact
info@firstnet.gov. Please also refer to the most recent SAFECOM Guidance on Emergency
Communications Grants for additional guidance.
National Incident Management System (NIMS) Implementation
NIMS guides all levels of government, nongovernmental organizations (NGO), and the private sector to
work together to prevent, protect against, mitigate, respond to, and recover from incidents. NIMS
provides stakeholders across the whole community with the shared vocabulary, systems, and processes to
successfully deliver the capabilities described in the National Preparedness System.
The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarify the
NIMS implementation requirements in FEMA preparedness grant Notices of Funding Opportunities. As
recipients and subrecipients of federal preparedness (non-disaster) grant awards, jurisdictions and
organizations must achieve, or be actively working to achieve, all of the NIMS Implementation
Objectives. The objectives can be found on the NIMS webpage at https://www.fema.gov/emergency-
managers/nims/implementation-training.
Emergency management and incident response activities require carefully managed resources (personnel,
teams, facilities, equipment, and/or supplies) to meet incident needs. Utilization of the standardized
resource management concepts such as typing, credentialing, and inventorying promote a strong national
mutual aid capability needed to support the delivery of core capabilities. Additional information on
resource management, NIMS resource typing definitions, job titles, and position qualifications is
available at https://www.fema.gov/emergency-managers/nims/components. Please also see the individual
program appendices in this Manual for additional requirements regarding NIMS implementation for
specific programs.
FEMA developed the NIMS Guideline for the National Qualification System to describe the basic
principles of standard qualification, certification, and credentialing processes. This guideline supersedes
the NIMS Guideline for the Credentialing of Personnel.
The National Qualification System doctrine promotes interoperability by establishing a common language
for defining job titles and by enabling jurisdictions and organizations to plan for, request, and have
confidence in the capabilities of personnel deployed for disasters and emergencies from other entities
through mutual aid agreements and compacts. Following the concepts and processes in this Guideline will
enhance national preparedness by expanding the network of qualified incident management and support
personnel who can be deployed nationwide.
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State, local, tribal, territorial, and private sector partners (including nongovernmental organizations) are
not required but are strongly encouraged to credential their personnel in accordance with the NIMS
National Qualification System guidelines.
Additional information about NIMS implementation is available at https://www.fema.gov/emergency-
managers/nims/implementation-training.
SAFECOM Guidance Compliance
All entities using preparedness grant funding to support emergency communications investments are
required to comply with the SAFECOM Guidance on Emergency Communications Grants (SAFECOM
Guidance). The SAFECOM Guidance provides current information on emergency communications
policies, eligible costs, best practices, and technical standards for SLTT recipients investing federal funds
in emergency communications projects. It is also designed to promote and align with the National
Emergency Communications Plan (NECP). Conformance with the SAFECOM Guidance helps ensure
that federally funded investments are compatible, interoperable, resilient, and support national goals and
objectives for improving emergency communications. Applicants should use the SAFECOM Guidance
during planning, development, and implementation of emergency communications projects and in
conjunction with other planning documents (e.g., SCIPs). Specifically, Appendix D of the SAFECOM
Guidance contains compliance instructions for FEMA grant recipients.
Emergency communications investments also will be reviewed jointly by FEMA and the
Cybersecurity and Infrastructure Security Agency (CISA) to verify compliance with SAFECOM
Guidance. FEMA will coordinate directly with the recipient on any compliance concerns and will
provide technical assistance as necessary to help ensure full compliance.
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Post-Award Management and Implementation
Reporting
Recipients are required to submit various financial and programmatic reports as a condition of award
acceptance. Future awards and funds drawdown may be withheld if these reports are delinquent.
Consultants or contractors are not permitted to be the AOR of the recipient. The AOR, as the
Authorized Official for the award, is responsible for submitting programmatic and financial performance
reports, accepting award packages, signing assurances and certifications, and submitting award
amendments.
Federal Financial Reporting Requirements
Federal Financial Report (FFR)
Recipients must report obligations and expenditures to FEMA on a quarterly basis through the FFR form
(SF-425). Recipients may review the FFR Form (SF-425) at
https://www.grants.gov/web/grants/forms/post-award-reporting-forms.html#sortby=1. Recipients must
file the FFR electronically using the Payment and Reporting Systems (PARS).
Financial Reporting Periods and Due Dates
An FFR must be submitted quarterly throughout the period of performance (POP), including partial
calendar quarters, as well as in periods where no grant award activity occurs. The final FFR is due within
90 days after the end of the POP. Future awards and fund drawdowns may be withheld if these reports are
delinquent, demonstrate a lack of progress, or are insufficient in detail.
Except for the final FFR due at closeout
(and the last quarterly FFR) the
following reporting periods and due
dates apply for the FFR Reporting Period
Report Due Date
October 1 – December 31
January 30
January 1 – March 31
April 30
April 1 – June 30
July 30
July 1 – September 30
October 30
Because of a system limitation, if at the end of the POP a recipient still has funds to draw down, PARS
requires an FFR be submitted within 30 days of the end of the POP in order to access those funds. In that
case, the recipient will need to submit an FFR within 30 days of the end of the POP in addition to the final
FFR within 120 days of the end of the POP. All other recipients who do not need to draw down funds
after the end of the POP are only required to submit the final FFR within 120 days after the end of the
POP.
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Program Performance Reporting Requirements
Performance Progress Report (PPR)
Recipients are responsible for providing updated performance reports on a biannual basis as an
attachment in ND Grants. The PPR should include the following:
•
A brief narrative of overall project(s) status
•
A summary of project expenditures
•
A description of any potential issues that may affect project completion
Note: This requirement does NOT apply to the EMPG Program, which has different performance
reporting requirements. These are described in the EMPG Program Appendix in this Manual.
Program Performance Reporting Periods and Due Dates
The following reporting periods and due dates apply for the PPR:
Reporting Period
Report Due Date
January 1 – June 30
July 30
July 1 – December 31
January 30
Additional Programmatic Reporting Requirements and Information
Biannual Strategy Implementation Report (BSIR)2
In addition to the quarterly financial and biannual performance progress reports, recipients are responsible
for completing and submitting BSIRs through the Grants Reporting Tool (GRT). The BSIR is due within
30 days after the end of the reporting period: July 30 for the reporting period of January 1 through June 30
(summer BSIR report); and January 30 for the reporting period of July 1 through December 31 (winter
BSIR report). All required attributes of each project must be included. Updated obligations, expenditures,
and significant developments must be provided within the BSIR to show the progress of implementation
for every project as well as how expenditures support Planning, Organization, Equipment, Training, and
Exercises (POETE). The first BSIR will be due by January 30, or 30 days after the end of the first
reporting period of the award. Subsequent BSIR reports will require recipients to report on a project-by-
project basis.
Recipients also are responsible for completing and submitting a closeout BSIR. When an award’s POP or
the liquidation period ends in the middle of a reporting period, a “regular” BSIR must be submitted with
full accounting of actual project information/expenditures before a Closeout BSIR can be created/
submitted. The last “regular” BSIR is required because the Closeout BSIR does NOT contain full
functionality to edit any project information/expenditures. Once the last “regular” BSIR is approved by
GPD, the Closeout BSIR can be created/submitted. Please contact your HQ Preparedness Officer for
guidance on the information required for the Closeout BSIR.
2 BSIR requirements are applicable to the following grant programs: HSGP (SHSP, UASI, and OPSG), THSGP,
EMPG, and NSGP.
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Closeout Reporting Requirements
Within 120 days after the end of the POP for the prime award or after an amendment has been issued to
close out an award before the original POP ends, whichever occurs first, recipients must liquidate all
financial obligations and submit the following documentation in ND Grants:
1. The final request for payment, if applicable;
2. The final FFR (SF-425);
3. The final PPR;
4. A qualitative narrative summary of the impact of those accomplishments throughout the entire
POP submitted to the respective FEMA Preparedness Officer; and
5. Other documents required by program guidance, NOFOs, appendices to this Manual, terms and
conditions of the award, or other FEMA guidance.
In addition, any recipient that issues subawards to any subrecipient is responsible for closing out those
subawards as described in 2 C.F.R. § 200.344; subrecipients are still required to submit closeout materials
within 90 days of the subaward POP end date. When a subrecipient completes all closeout requirements,
pass-through entities must promptly complete all closeout actions for subawards in time for the recipient
to submit all necessary documentation and information to FEMA during the closeout of their prime
award.
After the prime award closeout reports have been reviewed and approved by FEMA, a closeout notice
will be completed to close out the grant. The notice will indicate the POP as closed, list any remaining
funds that will be deobligated, and address the requirement of maintaining the award records for at least
three years from the date of the final FFR. The record retention period may be longer than three years due
to an audit, litigation, for equipment or real property used beyond the period of performance or other
circumstances outlined in 2 C.F.R. § 200.334.
Recipients are responsible for refunding to FEMA any unobligated cash that FEMA paid that are not
authorized to be retained per 2 C.F.R. § 200.344(d).
Administrative Closeout
Administrative closeout is a mechanism for FEMA to unilaterally move forward with closeout of an
award using available award information in lieu of final reports from the recipient per 2 C.F.R. §
200.344(h)-(i). It is a last resort available to FEMA, and if FEMA needs to administratively close an
award, this may negatively impact a recipient’s ability to obtain future funding. This mechanism can
also require FEMA to make cash or cost adjustments and ineligible cost determinations based on the
information it has, which may result in identifying a debt owed to FEMA by the recipient.
When a recipient is not responsive to FEMA’s reasonable efforts to collect required reports needed to
complete the standard closeout process, FEMA is required under 2 C.F.R. § 200.344(h) to start the
administrative closeout process within the regulatory timeframe. FEMA will make at least three written
attempts to collect required reports before initiating administrative closeout. If the recipient does not
submit all required reports in accordance with 2 C.F.R. § 200.344, the relevant program NOFO, this
Manual, and the terms and conditions of the award, FEMA must proceed to administratively close the
award with the information available within one year of the POP end date. Additionally, if the recipient
does not submit all required reports within one year of the POP end date, per 2 C.F.R. § 200.344(i),
FEMA must report in FAPIIS the recipient’s material failure to comply with the terms and conditions of
the award.
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If FEMA administratively closes an award where no final FFR has been submitted, FEMA uses that
administrative closeout date in lieu of the final FFR submission date as the start of the three-year record
retention period under 2 C.F.R. § 200.334.
In addition, if an award is administratively closed, FEMA may decide to impose remedies for
noncompliance per 2 C.F.R. § 200.339, consider this information in reviewing future award applications,
or apply special conditions to existing or future awards.
Disclosing Information per 2 C.F.R. § 180.335
This reporting requirement pertains to disclosing information related to government-wide suspension and
debarment requirements. Before a recipient enters into a grant award with FEMA, the recipient must
notify FEMA if it knows if it or any of the recipient’s principals under the award fall under one or more
of the four criteria listed at 2 C.F.R. § 180.335:
•
Are presently excluded or disqualified;
•
Have been convicted within the preceding three years of any of the offenses listed in 2 C.F.R. §
180.800(a) or had a civil judgment rendered against it or any of the recipient’s principals for one
of those offenses within that time period;
•
Are presently indicted for or otherwise criminally or civilly charged by a governmental entity
(federal, state, or local) with commission of any of the offenses listed in 2 C.F.R. § 180.800(a); or
•
Have had one or more public transactions (federal, state, or local) terminated within the preceding
three years for cause or default.
At any time after accepting the award, if the recipient learns that it or any of its principals falls under one
or more of the criteria listed at 2 C.F.R. § 180.335, the recipient must provide immediate written notice to
FEMA in accordance with 2 C.F.R. § 180.350.
Reporting of Matters Related to Recipient Integrity and Performance
Per 2 C.F.R. Part 200, Appendix I § F.3, the additional post-award reporting requirements in 2 C.F.R. Part
200, Appendix XII may apply to applicants who, if upon becoming recipients, have a total value of
currently active grants, cooperative agreements, and procurement contracts from all federal awarding
agencies that exceeds $10,000,000 for any period of time during the period of performance of an award
under these funding opportunities.
Recipients that meet these criteria must maintain current information reported in FAPIIS about civil,
criminal, or administrative proceedings described in paragraph 2 of Appendix XII at the reporting
frequency described in paragraph 4 of Appendix XII.
Single Audit Report
For fiscal years beginning on or after December 26, 2014, recipients that expend $750,000.00 or more
from all federal funding sources during their fiscal year are required to submit an organization-wide
financial and compliance audit report, also known as a “single audit” report.
The audit must be performed in accordance with the requirements of Government and Accountability
Office’s (GAO) Government Auditing Standards, located at https://www.gao.gov/yellowbook/overview,
and the requirements of Subpart F of 2 C.F.R. Part 200, located at http://www.ecfr.gov/cgi-bin/text-
idx?node=sp2.1.200.f.
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Additional Information
Monitoring and Oversight
Overview
Per 2 C.F.R. § 200.337, FEMA, through its authorized representatives, has the right, at all reasonable
times, to make site visits or conduct desk reviews to review project accomplishments and management
control systems to review award progress and to provide any required technical assistance. During site
visits or desk reviews, FEMA will review recipients’ files related to the award. As part of any monitoring
and program evaluation activities, recipients must permit FEMA, upon reasonable notice, to review grant-
related records and to interview the organization’s staff and contractors regarding the program. Recipients
must respond in a timely and accurate manner to FEMA requests for information relating to the award.
Effective monitoring and oversight help FEMA ensure that recipients use grant funds for their intended
purpose(s), verify that projects undertaken are consistent with approved plans, and ensure that recipients
make adequate progress towards stated goals and objectives. Additionally, monitoring serves as the
primary mechanism to ensure that recipients comply with applicable laws, rules, regulations, program
guidance, and requirements. FEMA regularly monitors all grant programs both financially and
programmatically in accordance with federal laws, regulations (including 2 C.F.R. Part 200), program
guidance, and the terms and conditions of the award. All monitoring efforts ultimately serve to evaluate
progress towards grant goals and proactively target and address issues that may threaten grant success
during the period of performance.
FEMA staff will periodically monitor recipients to ensure that administrative processes, policies and
procedures, budgets, and other related award criteria are meeting Federal Government-wide and FEMA
regulations. Aside from reviewing quarterly financial and programmatic reports, FEMA may also conduct
enhanced monitoring through desk-based reviews, onsite monitoring visits, or both. Enhanced monitoring
will involve the review and analysis of financial compliance and administrative processes, policies,
activities, and other attributes of each federal assistance award, and it will identify areas where the
recipient may need technical assistance, corrective actions, or other support
Financial and programmatic monitoring are complementary processes within FEMA’s overarching
monitoring strategy that function together to ensure effective grants management, accountability, and
transparency; validate progress against grant and program goals; and safeguard federal funds against
fraud, waste, and abuse. Financial monitoring primarily focuses on statutory and regulatory compliance
with administrative grant requirements, while programmatic monitoring seeks to validate and assist in
grant progress, targeting issues that may be hindering project goals and ensuring compliance with the
purpose of the grant and grant program. Both monitoring processes are similar in that they feature initial
reviews of all open awards, and in-depth monitoring of grants requiring additional attention.
Recipients and subrecipients who are pass-through entities are responsible for monitoring their
subrecipients in a manner consistent with the terms of the federal award at 2 C.F.R. Part 200, including 2
C.F.R. § 200.332. This includes the pass-through entity’s responsibility to monitor the activities of the
subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with
federal statutes, regulations, and the terms and conditions of the subaward; and that subaward
performance goals are achieved.
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In terms of overall award management, recipient and subrecipient responsibilities include, but are not
limited to: accounting of receipts and expenditures, cash management, maintaining adequate financial
records, reporting and refunding expenditures disallowed by audits, monitoring if acting as a pass-through
entity, other assessments and reviews, and ensuring overall compliance with the terms and conditions of
the award or subaward, as applicable, including the terms of 2 C.F.R. Part 200.
Financial Monitoring Overview and Approach
FEMA’s approach to financial monitoring provides a standard monitoring framework that promotes
consistent processes across all monitoring staff. There are four core components of the monitoring
process:
1. Monitoring Assessment: Monitoring staff measure each grant’s monitoring needs using a system
of pre-determined evaluation criteria. The criteria help assess the recipient and potential
challenges to the success of the grant award.
2. Monitoring Selection and Scheduling: Monitoring staff make selection and scheduling
decisions in accordance with applicable statutory requirements, such as the Homeland Security
Act of 2002, as amended (hereafter “HSA”), and consider the results of the monitoring assessment
process.
3. Monitoring Activities: Monitoring activities include cash analysis, desk reviews, and site visits.
Grants Management Specialists are responsible for conducting quarterly or semi-annual reviews
of all grants via cash analysis. Desk reviews and site visits are additional monitoring activities
conducted on grants where the monitoring assessment process identified the need for additional
monitoring and validated the use of FEMA resources for these activities.
4. Post-Monitoring Actions: Monitoring staff may follow up with recipients via post-monitoring
actions based on the outcomes of monitoring activities. Post-monitoring actions include
conducting additional monitoring; reviewing Corrective Action Plans (CAP) and monitoring the
progress of CAP deliverables; documenting the resolution of identified corrective actions and
issues; providing technical assistance and recipient training; and debt collection.
In addition to the monitoring guidance outlined above, section 2022(a)(2)(A) of the HSA mandates the
frequency of monitoring activities for applicable preparedness grants. The applicable section of the HSA
reads as follows:
Not less than once every 2 years, the Administrator shall conduct, for each state and high-risk
urban area receiving a grant administered by the Department, a programmatic and financial
review of all grants awarded by the Department to prevent, prepare for, protect against, or
respond to natural disasters, acts of terrorism, or other man-made disasters, excluding assistance
provided under section 203, title IV, or title V of the Robert T. Stafford Disaster Relief and
Emergency Assistance Act (42 U.S.C. 5133, 5170 et seq., and 5191 et seq.).
The following preparedness grant programs covered by this Manual are subject to HSA monitoring
requirements:
•
EMPG
•
HSGP
o SHSP
o UASI
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o OPSG
•
NSGP
•
TSGP
•
PSGP
Standard Monitoring Activity: Cash Analysis
Through cash analysis, a Grants Management Specialist assesses and reports on the recipients’ cash-on-
hand, expenditures, and unliquidated obligations; gauges potential cost share shortfalls; cash on hand
issues; and spend down activities within the POP. The analysis reconciles and compares grant
disbursement records with the recipient-submitted FFR. This process identifies recipients that may require
additional monitoring due to issues identified with drawdowns or FFR submissions.
Enhanced Monitoring Activities: Desk Review, Site Visit
Desk reviews and site visits are two forms of additional monitoring that FEMA conducts on a recipient.
Table 1 defines the key differences and similarities.
Table 1 - Enhanced Financial Monitoring Activities (Desk Review and Site Visit)
Attribute
Desk Review
Site Visit
Location/
Logistics
A detailed, paper-based review and
evaluation conducted at a FEMA office.
Desk reviews do not require travel.
A visit by FEMA grants management staff
conducted at the site of the recipient’s
operations and/or selected performance
sites. Site visits may require travel.
Materials
Reviewed
Required reports, correspondence, and
other documentation, including policies
and procedures, to substantiate
compliance. Additional documentation
available remotely may include
information available through the grant
file, financial reports, interviews, and
other documentation and correspondence
to verify compliance.
Includes documents listed under the desk
review in addition to all applicable
documents and required reports necessary
to assess recipient capability and progress,
validate records, and substantiate
compliance with laws, regulations, and
policies.
Goal of
Monitoring
Activity
The goals of FEMA’s financial desk
review monitoring activities are, as
applicable, to:
•
Review grant files to verify
compliance, conduct interviews to
confirm adherence to approved
program plans, and confirm
equipment acquisition, allowable
use, and inventory controls;
•
Document that recipient
institutions possess adequate
internal controls, policies,
processes, and systems to manage
FEMA grants effectively;
•
Assist the recipient with the grant
process and provide guidance to
The goals of FEMA’s financial site visit
monitoring activities are, as applicable, to:
•
Review grant files to verify
compliance, conduct interviews to
confirm adherence to approved
program plans, and confirm
equipment acquisition, allowable
use, and inventory controls;
•
Document that recipient institutions
possess adequate internal controls,
policies, processes, and systems to
manage FEMA grants effectively;
•
Assist the recipient with the grant
process and provide guidance to
improve recipient administrative
efficiencies;
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Attribute
Desk Review
Site Visit
improve recipient administrative
efficiencies;
•
Identify and analyze relevant
problems that might prevent the
program from achieving its
internal and external objectives;
and
•
Provide technical assistance.
•
Identify and analyze relevant
problems that might prevent the
program from achieving its
internal and external objectives;
and
•
Provide technical assistance.
Programmatic Monitoring Overview and Approach
Programmatic monitoring involves oversight throughout the award lifecycle in order for FEMA to verify
that programs and projects undertaken by recipients are consistent with approved plans and comply with
applicable laws, regulations, program guidance, and the terms and conditions of the award.
FEMA’s monitoring approach complies with the monitoring requirements described in section 2022 of
the HSA. Programmatic monitoring also plays an important role in ensuring that FEMA preparedness
grant funding builds and sustains capabilities at the SLTT levels that advance the National Preparedness
Goal. Programmatic monitoring also is an opportunity for FEMA staff to build relationships with
recipients and to work collaboratively to identify and mitigate factors that may impede programmatic
performance.
Programs covered by this Manual that are included in the programmatic monitoring approach are listed
below, including the programs subject to section 2022 of the HSA and three additional programs
(THSGP, IPR, and IBSGP):
•
EMPG
•
HSGP
o SHSP
o UASI
o OPSG
•
THSGP
•
NSGP
•
PSGP
•
TSGP
•
IBSGP
•
IPR
FEMA uses a risk- and project-based programmatic monitoring framework for its preparedness grant
programs that is designed for data-driven grants management and which interacts seamlessly with other
aspects of the grant lifecycle. FEMA uses monitoring as a vehicle to validate data previously self-reported
by recipients in applications and reporting tools. FEMA does not utilize monitoring as a data collection
tool in and of itself. By specializing monitoring in this way, FEMA avoids duplicative data collection,
targets its resources more effectively, and provides stronger and more proactive technical assistance to its
recipients. The framework also comprehensively documents grant management decisions for resource
allocation.
This programmatic monitoring approach establishes baseline monitoring of all open awards across the
FEMA preparedness grant portfolio using a First Line Review (FLR). The FLR identifies recipients and
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awards with a high potential for noncompliance with regulations or failure to meet project objectives. The
FLR uses quantifiable measures (criteria) to prioritize and rank recipients and awards according to
identified risks that threaten the success of FEMA’s preparedness grant awards. Results of this
prioritization process determine which high-risk recipients and awards will receive advanced monitoring.
Post-monitoring actions document and communicate findings and recommendations for resolution to the
recipients and FEMA leadership and allow for increasingly cohesive programmatic and financial
monitoring processes.
Environmental Planning and Historic Preservation (EHP)
As a federal agency, FEMA is required to consider the effects of its actions on the environment and
historic properties to ensure that all activities and programs funded by FEMA, including grant-funded
projects, comply with federal EHP laws, Executive Orders, regulations, and policies, as applicable.
Recipients and subrecipients proposing projects that have the potential to impact the environment,
including, but not limited to, the construction of communication towers, modification or renovation
of existing buildings, structures, and facilities, or new construction including replacement of
facilities, must participate in the FEMA EHP review process. The EHP review process involves the
submission of a detailed project description along with any supporting documentation requested by
FEMA in order to determine whether the proposed project has the potential to impact environmental
resources or historic properties.
In some cases, FEMA is also required to consult with other regulatory agencies and the public in order to
complete the review process. Federal law requires EHP review to be completed before federal funds are
released to carry out proposed projects. FEMA may not be able to fund projects that are not incompliance
with applicable EHP laws, Executive Orders, regulations, and policies.
DHS and FEMA EHP policy is found in directives and instructions available on the FEMA.gov EHP
page, the FEMA website page that includes documents regarding EHP responsibilities and program
requirements, including implementation of the National Environmental Policy Act and other EHP
regulations and Executive Orders.
The GPD EHP screening form is located at https://www.fema.gov/media-library/assets/documents/90195.
Additionally, all preparedness grants recipients are required to comply with the FEMA GPD EHP Policy
Guidance, FEMA Policy #108-023-1, available at https://www.fema.gov/media-
library/assets/documents/85376.
Please refer to the program appendices for additional program-specific EHP requirements and
information.
Case Studies and Use of Grant-Funded Resources During Real-World
Incident Operations
Analyzing the use of grant-funded investments in real-world incidents will improve the ability of FEMA
and its SLTT partners to assess the effectiveness of these investments and to better understand how grant
funds support improvements in nationwide capability levels. Currently, FEMA conducts case studies with
a limited number of grant recipients each year to explore how jurisdictions prioritize grant investments
based on risk and capability assessments and the ways specific investments improve SLTT preparedness
(https://www.fema.gov/grants/preparedness/about/case-studies). By accepting the award, the recipient
agrees to participate in a case study or evaluation if requested.
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Conflicts of Interest in the Administration of Federal Awards or
Subawards
For conflicts of interest under grant-funded procurements and contracts, refer to the section on
Procurement Integrity in the applicable NOFO, this Manual, and 2 C.F.R. §§ 200.317 – 200.327.
To eliminate and reduce the impact of conflicts of interest in the subaward process, recipients and pass-
through entities must follow their own policies and procedures regarding the elimination or reduction of
conflicts of interest when making subawards. Recipients and pass-through entities are also required to
follow any applicable federal or SLTT statutes or regulations governing conflicts of interest in the making
of subawards.
The recipient or pass-through entity must disclose to the respective Preparedness Officer or Program
Manager, in writing, any real or potential conflict of interest that may arise during the administration of
the federal award, as defined by the federal or SLTT statutes or regulations or their own existing policies,
within five days of learning of the conflict of interest. Similarly, subrecipients, whether acting as
subrecipients or as pass-through entities, must disclose any real or potential conflict of interest to the
recipient or next-level pass-through entity as required by the recipient or pass-through entity’s conflict of
interest policies, or any applicable federal or SLTT statutes or regulations.
Conflicts of interest may arise during the process of FEMA making a federal award in situations where an
employee, officer, or agent, any members of his or her immediate family, his or her partner has a close
personal relationship, a business relationship, or a professional relationship, with an applicant,
subapplicant, recipient, subrecipient, or FEMA employees.
Procurement Integrity
Through audits conducted by the DHS Office of Inspector General (OIG) and FEMA grant monitoring,
findings have shown that some FEMA recipients have not fully adhered to the proper procurement
requirements when spending grant funds. Anything less than full compliance with federal procurement
requirements jeopardizes the integrity of the grant as well as the grant program. To assist with
determining whether an action is a procurement or instead a subaward, please consult 2 C.F.R § 200.331.
The below highlights the federal procurement requirements for FEMA recipients when procuring goods
and services with federal grant funds. FEMA will include a review of recipients’ procurement practices as
part of the normal monitoring activities. All procurement activity must be conducted in accordance
with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. Select requirements under
these standards are listed below. The recipient and any of its subrecipients must comply with all
requirements, even if they are not listed below.
Under 2 C.F.R. § 200.317, when procuring property and services under a federal award, states (including
territories) must follow the same policies and procedures they use for procurements from their non-federal
funds; additionally, states must now follow 2 C.F.R. § 200.321 regarding socioeconomic steps, § 200.322
regarding domestic preferences for procurements, § 200.323 regarding procurement of recovered
materials, and § 200.327 regarding required contract provisions.
All other non-federal entities, such as tribes (collectively, non-state entities), must have and use their
own documented procurement procedures that reflect applicable SLTT laws and regulations, provided
that the procurements conform to applicable federal law and the standards identified in 2 C.F.R. Part 200.
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These standards include, but are not limited to, providing for full and open competition consistent with
the standards of 2 C.F.R. § 200.319 and § 200.320.
Important Changes to Procurement Standards in 2 C.F.R Part 200
OMB recently updated various parts of Title 2 of the Code of Federal Regulations, among them, the
procurement standards. States are now required to follow the socioeconomic steps in soliciting small and
minority businesses, women’s business enterprises, and labor surplus area firms per 2 C.F.R. § 200.321.
All non-federal entities should also, to the greatest extent practicable under a federal award, provide a
preference for the purchase, acquisition, or use of goods, products, or materials produced in the United
States per 2 C.F.R. § 200.322.
The recognized procurement methods in 2 C.F.R. § 200.320 have been reorganized into informal
procurement methods, which include micro-purchases and small purchases; formal procurement methods,
which include sealed bidding and competitive proposals; and noncompetitive procurements. The federal
micro-purchase threshold is currently $10,000, and non-state entities may use a lower threshold when
using micro-purchase procedures under a FEMA award. If a non-state entity wants to use a micro-
purchase threshold higher than the federal threshold, it must follow the requirements of 2 C.F.R. §
200.320(a)(1)(iii)-(iv). The federal simplified acquisition threshold is currently $250,000, and a non-state
entity may use a lower threshold but may not exceed the federal threshold when using small purchase
procedures under a FEMA award.
See 2 C.F.R. §§ 200.216, 200.471, and Appendix II as well as FEMA Policy #405-143-1, the relevant
program NOFO, and this Manual regarding prohibitions on covered telecommunications equipment or
services.
Competition and Conflicts of Interest
Among the requirements of 2 C.F.R. § 200.319(b) applicable to all non-federal entities other than states,
in order to ensure objective contractor performance and eliminate unfair competitive advantage,
contractors that develop or draft specifications, requirements, statements of work, or invitations for bids
or requests for proposals must be excluded from competing for such procurements. FEMA considers
these actions to be an organizational conflict of interest and interprets this restriction as applying to
contractors that help a non-federal entity develop its grant application, project plans, or project budget.
This prohibition also applies to the use of former employees to manage the grant or carry out a contract
when those former employees worked on such activities while they were employees of the non-federal
entity.
Under this prohibition, unless the non-federal entity solicits for and awards a contract covering both
development and execution of specifications (or similar elements as described above), and this contract
was procured in compliance with 2 C.F.R. §§ 200.317 – 200.327, federal funds cannot be used to pay a
contractor to carry out the work if that contractor also worked on the development of those specifications.
This rule applies to all contracts funded with federal grant funds, including pre-award costs, such as grant
writer fees, as well as post-award costs, such as grant management fees.
Some of the situations considered to be restrictive of competition include but are not limited to:
•
Placing unreasonable requirements on firms in order for them to qualify to do business;
•
Requiring unnecessary experience and excessive bonding;
•
Noncompetitive pricing practices between firms or between affiliated companies;
•
Noncompetitive contracts to consultants that are on retainer contracts;
•
Organizational conflicts of interest;
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•
Specifying only a “brand name” product instead of allowing “an equal” product to be offered and
describing the performance or other relevant requirements of the procurement; and
•
Any arbitrary action in the procurement process.
Per 2 C.F.R. § 200.319(c), non-federal entities other than states must conduct procurements in a manner
that prohibits the use of statutorily or administratively imposed SLTT geographical preferences in the
evaluation of bids or proposals, except in those cases where applicable federal statutes expressly mandate
or encourage geographic preference. Nothing in this section preempts state licensing laws. When
contracting for architectural and engineering services, geographic location may be a selection criterion
provided its application leaves an appropriate number of qualified firms, given the nature and size of the
project, to compete for the contract.
Under 2 C.F.R. § 200.318(c)(1), non-federal entities other than states are required to maintain written
standards of conduct covering conflicts of interest and governing the actions of their employees engaged
in the selection, award, and administration of contracts. No employee, officer, or agent may participate
in the selection, award, or administration of a contract supported by a federal award if he or she
has a real or apparent conflict of interest. Such conflicts of interest would arise when the employee,
officer, or agent, any member of his or her immediate family, his or her partner, or an organization that
employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a
tangible personal benefit from a firm considered for a contract.
The officers, employees, and agents of the non-federal entity may neither solicit nor accept gratuities,
favors, or anything of monetary value from contractors or parties to subcontracts. However, non-federal
entities may set standards for situations in which the financial interest is not substantial, or the gift is an
unsolicited item of nominal value. The standards of conduct must provide for disciplinary actions to be
applied for violations of such standards by officers, employees, or agents of the non-federal entity. If the
recipient or subrecipient (other than states) has a parent, affiliate, or subsidiary organization that is not a
state, local, tribal, or territorial government, the non-federal entity must also maintain written standards of
conduct covering organizational conflicts of interest. In this context, organizational conflict of interest
means that because of a relationship with a parent company, affiliate, or subsidiary organization, the non-
federal entity is unable or appears to be unable to be impartial in conducting a procurement action
involving a related organization. 2 C.F.R. § 200.318(c)(2). The non-federal entity must disclose in writing
any potential conflicts of interest to FEMA or the pass-through entity in accordance with applicable
FEMA policy.
Supply Schedules and Purchasing Programs
Generally, a non-federal entity may seek to procure goods or services from a federal supply schedule,
state supply schedule, or group purchasing agreement.
General Services Administration Schedules
States, tribes, and local governments, and any instrumentality thereof (such as local education agencies or
institutions of higher education) may procure goods and services from a General Services Administration
(GSA) schedule. GSA offers multiple efficient and effective procurement programs for state, tribal, and
local governments, and instrumentalities thereof, to purchase products and services directly from pre-
vetted contractors. The GSA Schedules (also referred to as the Multiple Award Schedules and the Federal
Supply Schedules) are long-term government-wide contracts with commercial firms that provide access to
millions of commercial products and services at volume discount pricing.
Information about GSA programs for states, tribes, and local governments, and instrumentalities thereof,
can be found at https://www.gsa.gov/resources-for/programs-for-State-and-local-governments and
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https://www.gsa.gov/buying-selling/purchasing-programs/gsa-schedules/schedule-buyers/state-and-local-
governments.
For tribes, local governments, and their instrumentalities that purchase off of a GSA schedule, this will
satisfy the federal requirements for full and open competition provided that the recipient follows the GSA
ordering procedures; however, tribes, local governments, and their instrumentalities will still need to
follow the other rules under 2 C.F.R. §§ 200.317 – 200.327, such as solicitation of minority businesses,
women’s business enterprises, small businesses, or labor surplus area firms (§ 200.321), domestic
preferences (§ 200.322), contract cost and price (§ 200.324), and required contract provisions (§ 200.327
and Appendix II).
Other Supply Schedules and Programs
For non-federal entities other than states, such as tribes, local governments, and nonprofits, that want to
procure goods or services from a state supply schedule, cooperative purchasing program, or other similar
program, in order for such procurements to be permissible under federal requirements, the following must
be true:
•
The procurement of the original contract or purchasing schedule and its use by the non-federal
entity complies with state and local law, regulations, and written procurement procedures;
•
The state or other entity that originally procured the original contract or purchasing schedule
entered into the contract or schedule with the express purpose of making it available to the non-
federal entity and other similar types of entities;
•
The contract or purchasing schedule specifically allows for such use, and the work to be
performed for the non-federal entity falls within the scope of work under the contract as to type,
amount, and geography;
•
The procurement of the original contract or purchasing schedule complied with all the
procurement standards applicable to a non-federal entity other than states under at 2 C.F.R. §§
200.317 – 200.327; and
•
With respect to the use of a purchasing schedule, the non-federal entity must follow ordering
procedures that adhere to applicable state, tribal, and local laws and regulations and the minimum
requirements of full and open competition under 2 C.F.R. Part 200.
If a non-federal entity other than a state seeks to use a state supply schedule, cooperative purchasing
program, or other similar type of arrangement, FEMA recommends the recipient discuss the procurement
plans with its FEMA Preparedness Officer or Program Manager.
Procurement Documentation
Per 2 C.F.R. § 200.318(i), non-federal entities other than states and territories are required to maintain and
retain records sufficient to detail the history of procurement covering at least the rationale for the
procurement method, contract type, contractor selection or rejection, and the basis for the contract price.
States and territories are encouraged to maintain and retain this information as well and are reminded that
in order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g).
Examples of the types of documents that would cover this information include but are not limited to:
•
Solicitation documentation, such as requests for quotes, invitations for bids, or requests for
proposals;
•
Responses to solicitations, such as quotes, bids, or proposals;
•
Pre-solicitation independent cost estimates and post-solicitation cost/price analyses on file for
review by federal personnel, if applicable;
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•
Contract documents and amendments, including required contract provisions; and
•
Other documents required by federal regulations applicable at the time a grant is awarded to a
recipient.
Termination Provisions
FEMA may terminate a federal award in whole or in part for one of the following reasons. FEMA and the
recipient must still comply with closeout requirements at 2 C.F.R. §§ 200.344-200.345 even if an award is
terminated in whole or in part. To the extent that subawards are permitted under the respective program’s
NOFO, pass-through entities should refer to 2 C.F.R. § 200.340 for additional information on termination
regarding subawards.
1. Noncompliance. If an applicant fails to comply with the terms and conditions of a federal award,
FEMA may terminate the award in whole or in part. If the noncompliance can be corrected,
FEMA may first attempt to direct the recipient to correct the noncompliance. This may take the
form of a Compliance Notification. If the noncompliance cannot be corrected or the recipient is
non-responsive, FEMA may proceed with a Remedy Notification, which could impose a remedy
for noncompliance per 2 C.F.R. § 200.339, including termination. Any action to terminate based
on noncompliance will follow the requirements of 2 C.F.R. §§ 200.341-200.342 as well as the
requirement of 2 C.F.R. § 200.340(c) to report in FAPIIS the recipient’s material failure to
comply with the award terms and conditions.
2. With the Consent of the Recipient. FEMA may also terminate an award in whole or in part with
the consent of the recipient, in which case the parties must agree upon the termination
conditions, including the effective date, and in the case of partial termination, the portion to be
terminated.
3. Notification by the Recipient. The recipient may terminate the award, in whole or in part, by
sending written notification to FEMA setting forth the reasons for such termination, the effective
date, and in the case of partial termination, the portion to be terminated. In the case of partial
termination, FEMA may determine that a partially terminated award will not accomplish the
purpose of the federal award, so FEMA may terminate the award in its entirety. If that occurs,
FEMA will follow the requirements of 2 C.F.R. §§ 200.341-200.342 in deciding to fully
terminate the award
Period of Performance (POP) Extensions
Extensions to the POP for programs addressed in this Manual are allowed under limited circumstances.
Extensions to the initial POP identified in the award will only be considered through formal, written
requests to the recipient’s FEMA Preparedness Officer or Program Manager and must contain specific
and compelling justifications as to why an extension is required. Recipients are advised to coordinate with
the FEMA Preparedness Officer or Program Manager as needed when preparing an extension request.
All extension requests must address the following:
1. The grant program, fiscal year, and award number;
2. Reason for the delay–including details of the legal, policy, or operational challenges that prevent
the final outlay of awarded funds by the deadline;
3. Current status of the activity(is);
4. Approved POP termination date and new project completion date;
5. Amount of funds drawn down to date;
6. Remaining available funds, both federal and, if applicable, non-federal;
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7. Budget outlining how remaining federal and, if applicable, non-federal funds will be expended;
8. Plan for completion, including milestones and timeframes for achieving each milestone and the
position or person responsible for implementing the plan for completion; and
9. Certification that the activity(ies) will be completed within the extended POP without any
modification to the original statement of work, as described in the investment justification and as
approved by FEMA.
Extension requests will be granted only due to compelling legal, policy, or operational challenges.
Extension requests will only be considered for the following reasons:
•
Contractual commitments by the recipient or subrecipient with vendors prevent completion of the
project within the existing POP;
•
The project must undergo a complex environmental review that cannot be completed
within the existing POP;
•
Projects are long-term by design, and therefore acceleration would compromise core
programmatic goals; or
•
Where other special or extenuating circumstances exist.
Recipients should submit all proposed extension requests to FEMA for review and approval at least 120
days prior to the end of the POP to allow sufficient processing time. Extensions are typically granted for
no more than a six-month period. Recipients are advised to coordinate with the FEMA Preparedness
Officer as needed when preparing an extension request.
Records Retention
Record Retention Period
Financial records, supporting documents, statistical records, and all other non-federal entity records
pertinent to a federal award generally must be maintained for at least three years from the date the final
FFR is submitted. See 2 C.F.R. § 200.334. Further, if the recipient does not submit a final FFR and the
award is administratively closed, FEMA uses the date of administrative closeout as the start of the general
record retention period.
The record retention period may be longer than three years or have a different start date in certain
cases. These include:
•
Records for real property and equipment acquired with federal funds must be retained for three
years after final disposition of the property. See 2 C.F.R. § 200.334(c).
•
If any litigation, claim, or audit is started before the expiration of the three-year period, the
records must be retained until all litigation, claims, or audit findings involving the records have
been resolved and final action taken. See 2 C.F.R. § 200.334(a).
•
The record retention period will be extended if the recipient is notified in writing of the
extension by FEMA, the cognizant or oversight agency for audit, or the cognizant agency for
indirect costs. See 2 C.F.R. § 200.334(b).
•
Where FEMA requires recipients to report program income after the period of performance ends,
the program income record retention period begins at the end of the recipient’s fiscal year
in which program income is earned. See 2 C.F.R. § 200.334(e).
•
For indirect cost rate proposals, cost allocation plans, or other rate computations records, the start
of the record retention period depends on whether the indirect cost rate documents were
submitted for negotiation. If the indirect cost rate documents were submitted for negotiation,
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the record retention period begins from the date those documents were submitted for
negotiation. If indirect cost rate documents were not submitted for negotiation, the record
retention period begins at the end of the recipient’s fiscal year or other accounting period
covered by that indirect cost rate. See 2 C.F.R. § 200.334(f).
Types of Records to Retain
FEMA requires that non-federal entities maintain the following documentation for federally funded
purchases:
•
Specifications
•
Solicitations
•
Competitive quotes or proposals
•
Basis for selection decisions
•
Purchase orders
•
Contracts
•
Invoices
•
Cancelled checks
Non-federal entities should keep detailed records of all transactions involving the grant. FEMA may at
any time request copies of any relevant documentation and records, including purchasing documentation
along with copies of cancelled checks for verification. See, e.g., 2 C.F.R. §§ 200.318(i), 200.334,
200.337.
In order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g). Non-
federal entities who fail to fully document all purchases may find their expenditures questioned and
subsequently disallowed.
Actions to Address Noncompliance
Non-federal entities receiving financial assistance from FEMA are required to comply with requirements
in the terms and conditions of their awards or subawards, including the terms set forth in applicable
federal statutes, regulations, NOFOs, policies, and this Manual. Throughout the award lifecycle or even
after an award has been closed, FEMA or the pass-through entity may discover potential or actual
noncompliance on the part of a recipient or subrecipient. This potential or actual noncompliance may be
discovered through routine monitoring, audits, closeout, or reporting from various sources.
In the case of any potential or actual noncompliance, FEMA may place special conditions on an award
per 2 C.F.R. §§ 200.208 and 200.339, FEMA may place a hold on funds until the matter is corrected, or
additional information is provided per 2 C.F.R. § 200.339, or it may do both. Similar remedies for
noncompliance with certain federal civil rights laws are authorized pursuant to 44 C.F.R Parts 7 and 19.
In the event the noncompliance is not able to be corrected by imposing additional conditions or the
recipient or subrecipient refuses to correct the matter, FEMA might take other remedies allowed under 2
C.F.R. § 200.339. These remedies include actions to disallow costs, recover funds, wholly or partly
suspend or terminate the award, initiate suspension and debarment proceedings, withhold further federal
awards, or take other remedies that may be legally available. For further information on termination due
to noncompliance, see the section on Termination Provisions in the relevant NOFO.
FEMA may discover and take action on noncompliance even after an award has been closed. The
closeout of an award does not affect FEMA’s right to disallow costs and recover funds as long as the
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action to disallow costs takes place during the record retention period. See 2 C.F.R. §§ 200.334,
200.345(a). Closeout also does not affect the obligation of the non-federal entity to return any funds due
as a result of later refunds, corrections, or other transactions. See 2 C.F.R. § 200.345(a)(2).
The types of funds FEMA might attempt to recover include, but are not limited to, improper payments,
cost share reimbursements, program income, interest earned on advance payments, or equipment
disposition amounts.
FEMA may seek to recover disallowed costs through a Notice of Potential Debt Letter, a Remedy
Notification, or other letter. The document will describe the potential amount owed, the reason why
FEMA is recovering the funds, the recipient’s appeal rights, how the amount can be paid, and the
consequences for not appealing or paying the amount by the deadline.
If the recipient neither appeals nor pays the amount by the deadline, the amount owed will become final.
Potential consequences if the debt is not paid in full or otherwise resolved by the deadline include the
assessment of interest, administrative fees, and penalty charges; administratively offsetting the debt
against other payable federal funds; and transferring the debt to the U.S. Department of the Treasury for
collection.
FEMA notes the following common areas of noncompliance for the preparedness grant programs:
•
Insufficient documentation and lack of record retention.
•
Failure to follow the procurement under grants requirements.
•
Failure to submit closeout documents in a timely manner.
•
Failure to follow EHP requirements.
•
Failure to comply with the POP deadline.
Audits
FEMA grant recipients are subject to audit oversight from multiple entities including the DHS OIG, the
GAO, the pass-through entity, or independent auditing firms for single audits, and may cover activities
and costs incurred under the award. Auditing agencies such as the DHS OIG, the GAO, and the pass-
through entity (if applicable), and FEMA in its oversight capacity, must have access to records pertaining
to the FEMA award. Recipients and subrecipients must retain award documents for at least three years
from the date the final FFR is submitted, and even longer in many cases subject to the requirements of 2
C.F.R. § 200.334. In the case of administrative closeout, documents must be retained for at least three
years from the date of closeout, or longer subject to the requirements of 2 C.F.R. § 200.334. If documents
are retained longer than the required retention period, the DHS OIG, the GAO, and the pass-through
entity, as well as FEMA in its oversight capacity, have the right to access these records as well. See 2
C.F.R. §§ 200.334, 200.337.
Additionally, non-federal entities must comply with the single audit requirements at 2 C.F.R. Part 200,
Subpart F. Specifically, non-federal entities, other than for-profit subrecipients, that expend $750,000 or
more in federal awards during their fiscal year must have a single or program-specific audit conducted for
that year in accordance with Subpart F. 2 C.F.R. § 200.501. A single audit covers all federal funds
expended during a fiscal year, not just FEMA funds. The cost of audit services may be allowable per 2
C.F.R. § 200.425, but non-federal entities must select auditors in accordance with 2 C.F.R. § 200.509,
including following the proper procurement procedures. For additional information on single audit
reporting requirements, see the section in this Manual titled “Single Audit Report.”
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The objectives of single audits are to:
•
Determine if financial statements conform to generally accepted accounting principles (GAAP);
•
Determine whether the schedule of expenditures of federal awards is presented fairly;
•
Understand, assess, and test the adequacy of internal controls for compliance with major
programs; and
•
Determine if the entity complied with applicable laws, regulations, and contracts or grants.
For single audits, the auditee is required to prepare financial statements reflecting its financial position, a
schedule of federal award expenditures, and a summary of the status of prior audit findings and
questioned costs. The auditee also is required to follow up and take appropriate corrective actions on new
and previously issued but not yet addressed audit findings. The auditee must prepare a corrective action
plan to address the new audit findings. See 2 C.F.R. §§ 200.508, 200.510, 200.511.
Non-federal entities must have an audit conducted, either single or program-specific, of their financial
statements and federal expenditures annually or biennially pursuant to 2 C.F.R. § 200.504. Non-federal
entities must also follow the information submission requirements of 2 C.F.R. § 200.512, including
submitting the audit information to the Federal Audit Clearinghouse within the earlier of 30 calendar days
after receipt of the auditor’s report(s) or nine months after the end of the audit period. The audit
information to be submitted include the data collection form described at 2 C.F.R. § 200.512(c) and
Appendix X to 2 C.F.R. Part 200 as well as the reporting package described at 2 C.F.R. § 200.512(b).
The non-federal entity must retain one copy of the data collection form and one copy of the reporting
package for three years from the date of submission to the Federal Audit Clearinghouse. 2 C.F.R. §
200.512; see also 2 C.F.R. § 200.517 (setting requirements for retention of documents by the auditor and
access to audit records in the auditor’s possession).
FEMA, the DHS OIG, the GAO, and the pass-through entity (if applicable), as part of monitoring or as
part of an audit, may review a non-federal entity’s compliance with the single audit requirements. In cases
of continued inability or unwillingness to have an audit conducted in compliance with 2 C.F.R. Part 200,
Subpart F, FEMA and the pass-through entity, if applicable, are required to take appropriate remedial
action under 2 C.F.R. § 200.339 for noncompliance, pursuant to 2 C.F.R. § 200.505.
Payment Information
FEMA uses the Direct Deposit/Electronic Funds Transfer (DD/EFT) method of payment to recipients. To
enroll in the DD/EFT, the recipient must complete the SF-119A, Direct Deposit Form.
FEMA utilizes the Payment and Reporting System (PARS) for financial reporting, invoicing and tracking
payments. For additional information, refer to
https://isource.fema.gov/sf269/execute/LogIn?sawContentMessage=true.
Disability Integration
Pursuant to Section 504 of the Rehabilitation Act of 1973, recipients of FEMA financial assistance must
ensure that their programs and activities do not discriminate against other qualified individuals with
disabilities.
Preparedness grant recipients should engage with the whole community to advance individual and
community preparedness and to work as a nation to build and sustain resilience. In doing so, recipients
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are encouraged to consider the needs of individuals with disabilities into the activities and projects funded
by the grant.
FEMA expects that the integration of the needs of people with disabilities will occur at all levels,
including planning; alerting, notification, and public outreach; training; purchasing of equipment and
supplies; protective action implementation; and exercises/drills.
The following are examples that demonstrate the integration of the needs of people with disabilities in
carrying out FEMA awards:
•
Include representatives of organizations that work with/for people with disabilities on planning
committees, work groups and other bodies engaged in development and implementation of the
grant programs and activities.
•
Hold all activities related to the grant in locations that are accessible to persons with physical
disabilities to the extent practicable.
•
Acquire language translation services, including American Sign Language, that provide public
information across the community and in shelters.
•
Ensure shelter-specific grant funds are in alignment with FEMA’s Guidance on Planning for
Integration of Functional Needs Support Services in General Population Shelters.
•
If making alterations to an existing building to a primary function area utilizing federal funds,
complying with the most recent codes and standards and making path of travel to the primary
function area accessible to the greatest extent possible.
•
Implement specific procedures used by public transportation agencies that include evacuation and
passenger communication plans and measures for individuals with disabilities.
•
Identify, create, and deliver training to address any training gaps specifically aimed toward
whole-community preparedness. Include and interact with individuals with disabilities, aligning
with the designated program capability.
•
Establish best practices in inclusive planning and preparedness that consider physical access,
language access, and information access. Examples of effective communication access include
providing auxiliary aids and services such sign language interpreters, Computer Aided Real-time
Translation (CART), and materials in Braille or alternate formats.
FEMA grant recipients can fund projects towards the resiliency of the whole community, including
people with disabilities, such as training, outreach, and safety campaigns, provided that the project aligns
with the applicable NOFO, this Manual, applicable appendix to this Manual, and the terms and conditions
of the award. For specific guidelines on funding a disability inclusive project, please refer to the program-
specific appendix in this Manual.
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National Campaigns and Programs
Preparedness grant funding can generally be used to support the following campaigns and programs that
have been developed by or in partnership with DHS or FEMA.
Whole Community Preparedness
Preparedness is a shared responsibility that calls for the involvement of everyone—not just the
government—in preparedness efforts. By working together, everyone can help keep the nation safe from
harm and help keep it resilient when struck by hazards, such as natural disasters, acts of terrorism, and
pandemics.
Whole Community includes:
•
Individuals and families, including those with access and functional needs
•
Businesses
•
Faith-based and community organizations
•
Nonprofit groups
•
Schools and academia
•
Media outlets
•
All levels of government, including state, local, tribal, territorial, and federal partners
The phrase “Whole Community” often appears repeatedly in preparedness materials, as it is one of the
guiding principles. It means two things:
1. Involving people in the development of national preparedness documents.
2. Ensuring their roles and responsibilities are reflected in the content of the materials.
Additional information on incorporating whole community preparedness is available in the relevant
program-specific appendix to this Manual, as applicable.
Active Shooter Preparedness
DHS aims to enhance national preparedness through a whole-community approach by providing the
necessary products, tools, and resources to help all stakeholders prepare for and respond to an active
shooter incident. To that end, DHS has developed a comprehensive Active Shooter Preparedness website,
which includes informational resources, available at https://www.cisa.gov/active-shooter-preparedness.
An additional resource, the Joint DHS and Federal Bureau of Investigation (FBI) Countering Violent
Extremism (CVE) and Active Shooter Web Portal is located within the Homeland Security Information
Network (HSIN). The portal provides a restricted-access forum to share Unclassified, For Official Use
Only (FOUO), Sensitive but Unclassified (SBU), and Law Enforcement Sensitive (LES) information. The
portal provides users and training practitioners with accurate, appropriate, and relevant CVE and Active
Shooter training development resources, subject-matter expert information, and outreach initiatives. It
also has forums to provide feedback, products useful to others, and allows participants to ask questions
concerning CVE or the Active Shooter Program. Persons with a job-related duty, public service interest,
or who support a CVE and/or Active Shooter program can request access to this Portal. Additional
information can be found at: https://www.dhs.gov/cveas-portal#.
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States and Urban Areas are encouraged to review the referenced active shooter guidance, evaluate their
preparedness needs, and consider applying for funding to address any needs identified in this area (please
see the most current NOFO for allowable costs). To address training needs associated with active shooter
incidents, FEMA’s Emergency Management Institute provides a free, web-based training course entitled
IS-907: Active Shooter: What You Can Do, available at the following website:
https://training.fema.gov/is/courseoverview.aspx?code=is-907.
Soft Targets and Crowded Places
There are continued and growing threats facing Soft Targets and Crowded Places (ST-CP) throughout the
nation. ST-CPs are those locations or environments that are easily accessible to large numbers of people
on a predictable or semi-predictable basis that have limited security or protective measures in place.
These locations are vulnerable to attack using simple tactics and readily accessible weapons such as small
arms, edged weapons, vehicles, improvised explosive devices, and unmanned aircraft systems. ST-CPs
can include places such as town centers, shopping malls, open-air venues, outside hard targets/venues
perimeters, and other places of meeting and gathering. DHS is committed to reducing the risk of attacks
against ST-CPs and the impact of attacks if they do occur. However, the protection and security of ST-
CPs is a shared responsibility among whole community partners including the public, ST-CP owners and
operators, security industry partners, the Federal Government, and SLTT government partners. States,
territories, urban areas, and public and private sector partners are encouraged to identify security gaps and
build capabilities that address security needs of ST-CPs, understanding the unique challenges related to
protecting locations that are open to the public. States, territories, urban areas, and public and private
sector partners are also encouraged to use resources to instill a culture of awareness, vigilance, and
preparedness. For more information and additional resources, please see the DHS’s Hometown Security
Program.
Community Lifelines
FEMA created Community Lifelines to reframe incident information, understand and communicate
incident impacts using plain language, and promote unity of effort across the whole community to
prioritize efforts to stabilize the lifelines during incident response. While lifelines were developed to
support response planning and operations, the concept can be applied across the entire preparedness cycle.
Efforts to protect lifelines, prevent and mitigate potential impacts to them, and build back stronger and
smarter during recovery will drive overall resilience of the nation. Applying the lifelines construct allows
decision-makers to:
•
Prioritize, sequence, and focus response efforts towards maintaining or restoring the most critical
services and infrastructure;
•
Utilize a common lexicon to facilitate unity of purpose among all stakeholders;
•
Promote a response that facilitates unity of purpose and better communication among the whole
community (federal, state, tribal, territorial, and local governments, and private sector and non-
governmental entities); and
•
Clarify which components of the disaster are complex (multifaceted) or complicated (difficult),
requiring cross-sector coordination.
Lifelines are used to:
•
Enhance the ability to gain, maintain, and communicate situational awareness for the whole
community in responding to disasters;
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•
Analyze impacts to the various lifelines and develop priority focus areas for each operational
period during response;
•
Identify and communicate complex interdependencies to identify major limiting factors hindering
stabilization; and
•
Update the National Response Framework to reflect use of lifelines in response planning.
Lifelines include opportunities to:
•
Enable a true unity of effort between government, non-governmental organizations, and the
private sector, including infrastructure owners and operators;
•
Integrate preparedness efforts, existing plans, and identify unmet needs to better anticipate
response requirements; and
•
Refine reporting sources and products to enhance situational awareness, best determine capability
gaps, and demonstrate progress towards stabilization.
For more information on lifelines, please visit Community Lifelines | FEMA.gov and
https://www.fema.gov/media-library/assets/documents/177222.
Strategic Framework for Countering Terrorism and Targeted Violence
The United States faces increasingly complex threats from terrorism and targeted violence. Both continue
to pose a grave threat in ways that have evolved dramatically in the nearly two decades since the 9/11
attacks. Although foreign terrorist organizations remain intent on striking our Homeland, we also face a
growing threat from domestic actors. Combating terrorism and targeted violence requires the combined
efforts of DHS, our federal and SLTT government partners, and civil society.
To address these threats, in September 2019 DHS adopted the DHS Strategic Framework for Countering
Terrorism and Targeted Violence which explains how the department will use the tools and expertise that
have protected and strengthened the country from foreign terrorist organizations to address the evolving
challenges of today. DHS has also now finalized a corresponding Public Action Plan. Preparedness grant
recipients are encouraged to familiarize themselves with these documents and consider adopting the
concepts, principals, and goals they outline.
HSGP Appendix | February 2021
Page A-1
Program Appendix A:
Homeland Security Grant Program (HSGP)
As a reminder, while this appendix contains HSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the HSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
Alignment of HSGP to the National Preparedness System
The Nation uses the National Preparedness System to build, sustain, and deliver core capabilities to
achieve the National Preparedness Goal (the Goal). Recipients will use the National Preparedness System
to support their efforts to build, sustain, and deliver these core capabilities. The components of the National
Preparedness System are Identifying and Assessing Risk, Estimating Capability Requirements, Building
and Sustaining Capabilities, Planning to Deliver Capabilities, Validating Capabilities, and Reviewing and
Updating. Additional information on the National Preparedness System is available at
http://www.fema.gov/national-preparedness-system.
As the National Preparedness System matures, we are getting better data on our capabilities as a Nation
that can be used to drive our focus and our resources at all levels. States and territories provide annual
data on their proficiency across 32 core capabilities through the Threat and Hazard Identification and Risk
Assessment (THIRA), Stakeholder Preparedness Review (SPR), exercise and real world after-action
reports, and other preparedness data. This data feeds into the National Preparedness Report and forms a
shared national picture of needs relative to capability gaps—including what threats and hazards are posing
the greatest risks, and what core capabilities are most in need of improvement or sustainment.
Communities and federal agencies alike use this data to prioritize, synchronize, and guide programs and
activities to build and sustain capabilities. Analytic results help shape prioritization decisions at FEMA
and across the nation to make sure we are focusing our time and our resources in the right areas.
The HSGP provides financial support to state, local, tribal, and territorial (SLTT) jurisdictions to help
them build, sustain, and deliver core capabilities identified in the Goal. A key focus and requirement of
the HSGP is to prevent terrorism and other catastrophic events and to prepare the Nation for the threats
and hazards that pose the greatest risk to the security of the United States, including risks along the
Nation’s borders. When applicable, funding should support deployable assets that can be used anywhere
in the Nation through automatic assistance and mutual aid agreements, including, but not limited to, the
Emergency Management Assistance Compact (EMAC).
The HSGP supports investments that improve the ability of jurisdictions nationwide to:
•
Prevent a threatened or an actual act of terrorism;
•
Protect citizens, residents, visitors, and assets against the threats that pose the greatest risk to the
security of the United States;
•
Mitigate the loss of life and property by lessening the impact of future catastrophic events;
•
Respond quickly to save lives, protect property and the environment, and meet basic human
needs in the aftermath of a catastrophic incident; and/or
•
Recover through a focus on the timely restoration, strengthening, accessibility, and revitalization
of infrastructure, housing, and a sustainable economy, as well as the health, social, cultural,
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historic, and environmental fabric of communities affected by a catastrophic incident, and do so
in a manner that engages the whole community while ensuring the protection of civil rights.
HSGP Funding Guidelines
Recipients must comply with all the requirements in 2 C.F.R. Part 200 (Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards). In general, recipients should
consult with their FEMA HQ Preparedness Officer prior to making any investment that does not clearly
meet the allowable expense criteria. Funding guidelines established within this section support the five
mission areas—Prevention, Protection, Mitigation, Response, and Recovery—and associated core
capabilities within the Goal. Allowable investments made in support of the national priorities, as well as
other capability-enhancing projects must have a nexus to terrorism preparedness and fall into the
categories of planning, organization, exercises, training, or equipment, aligned to closing capability gaps
or sustaining capabilities identified in the THIRA/SPR. Recipients are encouraged to use grant funds for
evaluating grant-funded project effectiveness and return on investment. FEMA encourages recipients to
provide the results of that analysis to FEMA.
Multiple Purpose or Dual-Use of Funds
For both the State Homeland Security Program (SHSP) and Urban Area Security Initiative (UASI), many
activities that support the achievement of core capabilities related to the national priorities and terrorism
preparedness may simultaneously support enhanced preparedness for other hazards unrelated to acts of
terrorism. However, all SHSP- and UASI-funded projects must assist recipients and subrecipients in
achieving core capabilities related to preventing, preparing for, protecting against, or responding to acts of
terrorism per section 2008(c) of the Homeland Security Act of 2002 (6 U.S.C. § 609(c)).
Planning (SHSP and UASI)
SHSP and UASI funds may be used for a range of emergency preparedness and management planning
activities such as those associated with the development, review, and revision of the THIRA, SPR,
continuity of operations plans, and other planning activities that support the Goal and placing an emphasis
on updating and maintaining a current Emergency Operations Plan (EOP) that conforms to the guidelines
outlined in Comprehensive Preparedness Guide (CPG) 101 v2.
Organization (SHSP and UASI)
States and high-risk urban areas must justify proposed expenditures of SHSP or UASI funds to support
organization activities within their Investment Justification (IJ) submission. Organizational activities
include:
•
Program management
•
Development of whole community partnerships, through groups such as Citizen Corp Councils
•
Structures and mechanisms for information sharing between the public and private sector
•
Implementing models, programs, and workforce enhancement initiatives to address
ideologically inspired radicalization to violence in the homeland
•
Tools, resources, and activities that facilitate shared situational awareness between the public
and private sectors
•
Operational Support
•
Utilization of standardized resource management concepts such as typing, inventorying,
organizing, and tracking to facilitate the dispatch, deployment, and recovery of resources before,
during, and after an incident
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•
Responding to an increase in the threat level under the National Terrorism Advisory System
(NTAS) or needs resulting from a National Special Security Event
•
Paying salaries and benefits for personnel to serve as qualified Intelligence Analysts. Per the
Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security
Act (PRICE Act), Pub. L. No. 110-412, § 2, codified in relevant part, as amended, at 6 U.S.C. §
609(a), SHSP and UASI funds may be used to hire new staff and/or contractor positions to serve
as intelligence analysts to enable information/intelligence sharing capabilities, as well as support
existing intelligence analysts previously covered by SHSP or UASI funding. See 6 U.S.C. §
609(a). To be hired as an intelligence analyst, staff and/or contractor personnel must meet at least
one of the following criteria:
o Complete training to ensure baseline proficiency in intelligence analysis and production
within six months of being hired; and/or,
o Previously served as an intelligence analyst for a minimum of two years either in a
federal intelligence agency, the military, or state and/or local law enforcement
intelligence unit.
•
All fusion center analytical personnel must demonstrate qualifications that meet or exceed
competencies identified in the Common Competencies for state, local, and tribal intelligence
analysts, which outlines the minimum categories of training needed for intelligence analysts. A
certificate of completion of such training must be on file with the State Administrative Agency
(SAA) and must be made available to the recipient’s respective FEMA HQ Preparedness Officer
upon request.
•
Migrating online services to the “.gov” internet domain.
All SAAs are allowed to use up to 50% of their SHSP funding, and all high-risk urban areas are allowed to
use up to 50% of their UASI funding, for personnel costs per 6 U.S.C. § 609(b)(2)(A). Personnel hiring,
overtime, and backfill expenses are permitted under this grant only to the extent that such expenses are for
the allowable activities within the scope of the grant. Personnel expenses may include, but are not limited
to training and exercise coordinators, program managers and planners, intelligence analysts, and
Statewide Interoperability Coordinators (SWICs).
At the request of a recipient, the FEMA Administrator (or their designee) may grant a waiver of this 50%
limitation under 6 U.S.C. § 609(b)(2)(B). Requests for waivers to the personnel cap must be submitted by
the authorized representative of the SAA to FEMA in writing on official letterhead, with the following
information:
•
Documentation explaining why the cap should be waived
•
Conditions under which the request is being submitted
•
A budget and method of calculation of personnel costs both in percentages of the grant award
and in total dollar amount.
Please see IB 421b for additional information on the waiver request process.
Organizational activities under SHSP and UASI include:
Operational Overtime Costs. In support of efforts to enhance capabilities for detecting, deterring,
disrupting, and preventing acts of terrorism and other catastrophic events, operational overtime costs are
allowable for increased protective security measures at critical infrastructure sites or other high-risk
locations and to enhance public safety during mass gatherings and high-profile events. In that regard, HSGP
recipients are urged to consider using grant funding to support soft target preparedness activities. SHSP or
UASI funds may be used to support select operational expenses associated with increased security measures
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in the authorized categories cited in the table below, but this table is not exhaustive. FEMA retains the
discretion to approve other types of requests that do not fit within one of the categories of the table.
Table 2 - Authorized Operational Overtime Categories
Category
Description
1
National Terrorism
Advisory System
(NTAS)
Security measures in response to an increase in the threat level
under the NTAS to an “elevated” or “imminent” alert status. FEMA
Information Bulletin No. 367, Impact of National Terrorism
Advisory System on Homeland Security Grant Programs, remains
applicable; therefore, advance authorization from FEMA is not
required. Refer to https://www.dhs.gov/topic/ntas for additional
information on the NTAS.
2
National Security
Special Event (NSSE)
Security measures for a designated NSSE. NSSEs are events of
national or international significance deemed by DHS to be a
potential target for terrorism or other criminal activity.
3
Special Event
Assessment Rating
(SEAR) Level 1 through
Level 4 Events
Security measures required for SEAR Level 1 through Level 4
events as designated by DHS and included in the DHS National
Special Events List, as defined below:
•
SEAR 1: A significant event with national and/or
international importance that may require extensive federal
interagency support.
•
SEAR 2: A significant event with national and/or
international importance that may require some level of
federal interagency support.
•
SEAR 3: An event of national and/or international
importance that requires only limited federal support.
•
SEAR 4: An event with limited national importance that is
managed at state and local level.
NOTE: In cases where a threat of terrorism can be associated with a
SEAR Level 5 event, the event planners should coordinate with their
state or territory Homeland Security Advisor to seek re-adjudication
of the SEAR rating. Operational overtime for security measures
associated with such events will be considered for approval by
FEMA if re-adjudication results in a SEAR 1 through 4 rating.
4
States of Emergency
Declarations of states of emergency by the Governor associated with
a terrorism-related threat or incident. This excludes Presidentially
declared major disasters or emergencies where federal funding
support for the proposed grant-funded activity is made available
through the FEMA Public Assistance program or other federal
disaster grants.
5
National Critical
Infrastructure
Prioritization Program
(NCIPP)
Protection of Level 1 and Level 2 facilities identified through DHS’s
NCIPP based on a terrorism-related threat to critical infrastructure.
6
Directed Transit Patrols Targeted security patrols in airports and major transit hubs based on
a terrorism-related threat to transportation systems.
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Category
Description
7
Other Related Personnel
Overtime Costs
Overtime costs may be authorized for personnel assigned to directly
support any of the security activities relating to the categories above.
Examples include firefighters and emergency medical services
personnel; public works employees who may be responsible for
installing protective barriers and fencing; public safety personnel
assigned to assist with event access and crowd control; emergency
communications specialists; backfill and overtime for staffing state
or major urban area fusion centers; state Active Duty National
Guard deployments to protect critical infrastructure sites, including
all resources that are part of the standard National Guard
deployment package (note: consumable costs, such as fuel expenses,
are not allowed except as part of the standard National Guard
deployment package); contract security services for critical
infrastructure sites; participation in Regional Resiliency Assessment
Program activities, increased border security activities in
coordination with USBP, etc.
8
Operational Support to
a Federal Agency
Overtime costs are allowable for personnel to participate in
information, investigative, and intelligence sharing activities related
to homeland security/terrorism preparedness and specifically
requested by a federal agency. Allowable costs are limited to
overtime associated with federally requested participation in eligible
activities, including anti-terrorism task forces, Joint Terrorism Task
Forces (JTTFs), Area Maritime Security Committees (as required by
the Maritime Transportation Security Act of 2002), DHS Border
Enforcement Security Task Forces, and Integrated Border
Enforcement Teams. In addition, reimbursement for operational
overtime law enforcement activities related to combating
transnational crime organizations in support of efforts to enhance
capabilities for detecting, deterring, disrupting, and preventing acts
of terrorism is an allowable expense under SHSP and UASI on a
case-by-case basis. Grant funding can only be used in proportion to
the federal man-hour estimate and only after funding for these
activities from other federal sources (i.e., FBI JTTF payments to
state and local agencies) has been exhausted.
All allowable operational overtime costs are also subject to the administration requirements outlined in
the following subsection.
Administration of Operational Overtime Requests
•
Except for an elevated NTAS alert, SHSP or UASI funds may only be spent for operational
overtime costs upon prior written approval by FEMA. The SAA must submit operational
overtime requests in writing to its assigned FEMA Preparedness Officer. FEMA will consider
requests for special event activities up to one year in advance. However such requests must be
within the award’s current POP and must not result in the need for a request to extend the period
of performance. SAAs should contact the Centralized Scheduling and Information Desk (CSID)
for Preparedness Officer contact information. CSID can be reached by phone at (800) 368-6498
or by e-mail at askcsid@fema.dhs.gov, Monday through Friday, 9:00 a.m. – 5:00 p.m. ET.
HSGP Appendix | February 2021
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•
All operational overtime requests must clearly explain how the request meets the criteria of one
or more of the categories listed in the table above. Requests must address the threat environment
as it relates to the event or activity requiring operational overtime support and explain how the
overtime activity is responsive to the threat. Request letters sent to FEMA must be
UNCLASSIFIED but may be labeled “For Official Use Only.” If explaining the threat will
require the sharing of classified information, the letter should state that fact. FEMA will then plan
for the sharing of classified information through official channels.
•
Post-event operational overtime requests will only be considered on a case-by-case basis, where it
is demonstrated that exigent circumstances prevented submission of a request in advance of the
event or activity.
•
Under no circumstances may FEMA grant funding be used to pay for costs already supported by
funding from another federal source.
•
States with UASI jurisdictions can use funds retained at the state level to reimburse eligible
operational overtime expenses incurred by the state (per the above guidance limitations). Any
UASI funds retained by the state must be used in direct support of the high-risk urban area. States
must provide documentation to the Urban Area Working Group (UAWG) and FEMA upon
request demonstrating how any UASI funds retained by a state would directly support the high-
risk urban area.
•
FEMA will consult and coordinate with appropriate DHS components as necessary to verify
information used to support operational overtime requests. For example, the review of operational
overtime requests for the protection of critical infrastructure will be coordinated with DHS Office
of Cyber and Infrastructure Analysis to verify the Level I or Level II NCIPP designation. Also,
DHS Office of Intelligence and Analysis will be consulted to validate reported threat information
associated with the event or activity.
Personnel Costs. Personnel hiring, overtime, and backfill expenses are permitted under this grant to
perform allowable HSGP planning, training, exercise, and equipment activities. Personnel may include
but are not limited to training and exercise coordinators, program managers for activities directly
associated with SHSP and UASI funded activities, intelligence analysts, and SWICs.
For further details, SAAs should refer to Information Bulletin (IB) #421b, Clarification on the Personnel
Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of 2008 (Public
L. No. 110–412 – the PRICE Act), October 30, 2019, or contact their FEMA Preparedness Officer. HSGP
funds may not be used to support the hiring of any personnel to fulfill traditional public health and safety
duties nor to supplant traditional public health and safety positions and responsibilities. The following
definitions apply to personnel costs:
•
Hiring. State and local entities may use grant funding to cover the salary of newly hired personnel
who are exclusively undertaking allowable FEMA grant activities as specified in this guidance.
This may not include new personnel who are hired to fulfill any non-FEMA program activities
under any circumstances. Hiring will always result in a net increase of Full Time Equivalent
(FTE) employees.
•
Overtime. These expenses are limited to the additional costs that result from personnel working
over and above 40 hours of weekly work time as the direct result of their performance of FEMA-
approved activities specified in this guidance. Overtime associated with any other activity is not
eligible.
•
Backfill-Related Overtime. Also called “Overtime as Backfill,” these expenses are limited to
overtime costs that result from personnel who are working overtime (as identified above) to
perform the duties of other personnel who are temporarily assigned to FEMA-approved activities
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outside their core responsibilities. Neither overtime nor backfill expenses are the result of an
increase of FTE employees.
•
Supplanting. Grant funds will be used to supplement existing funds and will not replace
(supplant) funds that have been appropriated for the same purpose. Applicants or recipients may
be required to supply documentation certifying that a reduction in non-federal resources occurred
for reasons other than the receipt or expected receipt of federal funds.
Organization (OPSG)
Personnel Costs
OPSG funds may be used for domestic travel and per diem, including costs associated with the
deployment/redeployment of personnel to border areas and for travel associated with law enforcement
entities assisting other local jurisdictions in law enforcement activities. In addition, allowable costs
include supporting up to six-month deployment of law enforcement personnel to critical Southwest
Border locations for operational activities (travel costs must be in accordance with applicable travel
regulations).
Operational Overtime Costs
OPSG funds should be used for operational overtime costs associated with law enforcement activities in
support of border law enforcement agencies for increased border security enhancement. Overtime pay is
for enhanced patrol for certified public safety officers, along with limited support for other law
enforcement direct support personnel (e.g., Communication Officers/Dispatchers, non-sworn patrol pilots,
etc.). Overtime shall be reimbursed consistent with the non-federal entity’s overtime policy and the
requirements as stated below:
•
Overtime is time worked that exceeds the required number of hours during an employee’s
designated shift.
•
Overtime must be worked to increase patrol capacity and be in support of identified and approved
United States Border Patrol (USBP) border security operations.
•
The OPSG overtime hourly rate of pay will be no more than the approved overtime rate per local
law and policy and must be in accordance with applicable state and federal regulations.
•
All overtime expenses under OPSG must be reasonable for the services rendered and conform to
the non-federal entity’s established written policy, which must apply to both federally funded and
non-federally funded activities and comply with the other applicable requirements under 2 C.F.R.
§§ 200.430-200.431.
•
The non-federal entity may not utilize OPSG funding to pay for an employee’s overtime hours or
pay that exceeds 16 hours worked in any 24-hour period.
Personnel Costs
Up to 50% of an OPSG award may be used to pay for all personnel costs (only to the extent that such
expenses are for the allowable activities within the scope of the grant). At the request of a recipient or
subrecipient, the FEMA Administrator (or designee) may waive the 50% personnel cap. Waiver decisions
are at the discretion of the FEMA Administrator and will be considered on a case-by-case basis in
accordance with IB 421b. 6 U.S.C. § 609(b)(2). A formal OPSG personnel waiver request should:
•
Be on official letterhead, include a written justification, and be signed by the local jurisdiction.
•
Include a budget and method of calculation of personnel costs both in the percentage of the grant
award and in total dollar amount, reflecting the change in scope or objective to the project.
•
Include an approved Operations Order from the USBP Sector office that supports the local
jurisdiction’s written justification.
HSGP Appendix | February 2021
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•
Be coordinated with the USBP Sector, SAA, and the DHS/Customs and Border Protection (CBP)
Office of the Border Patrol (OBP).
Further, changes in scope or objective also require FEMA’s prior written approval pursuant to 2 C.F.R. §
200.308(c)(1). If the cost changes are allowable under the grant, a Fragmentary Order (FRAGO) must be
submitted to HSIN to obtain FEMA’s prior written approval of such changes in accordance with 2 C.F.R.
§ 200.308(c)(1). These modifications will be annotated in the annex section of the FRAGO.
OPSG funds may be used to pay additional current part-time law enforcement personnel salaries to bring
them to temporary full-time status. OPSG funds may support a Governor’s request to activate, deploy, or
redeploy specialized National Guard Units/Package and/or elements of state law enforcement serving as
friendly forces to increase or augment specialized/technical law enforcement elements’ operational
activities. Costs associated with backfill for personnel supporting operational activities are allowable.
As with all OPSG personnel costs, OPSG grant funds will be used to supplement existing funds and will
not replace (supplant) funds that have been appropriated for the same purpose. Applicants or recipients
may be required to supply documentation certifying that a reduction in non-federal resources occurred for
reasons other than the receipt or expected receipt of federal funds.
Intelligence Support
OPSG funds may as applicable and operationally beneficial be used to pay salaries and benefits for
personnel to serve as qualified Intelligence Analysts. Per 6 U.S.C. § 609(a), OPSG funds may be used to
hire new staff and/or contractor positions to serve as intelligence analysts to enable and enhance
information/intelligence sharing capabilities, as well as support existing intelligence analysts previously
covered by OPSG funding. Qualified OPSG-funded intelligence analysts can be assigned to an applicable
law enforcement facility/intelligence function as long as information/intelligence sharing is maintained.
To serve as an OPSG-funded intelligence analyst, staff and/or contractor personnel must meet at least one
of the following criteria:
•
Complete training to ensure baseline proficiency in intelligence analysis and production within
six months of being hired; and/or,
•
Previously served as an intelligence analyst for a minimum of two years either in a federal
intelligence agency, the military, or state and/or local law enforcement intelligence unit.
OPSG-funded intelligence analysts must demonstrate qualifications that meet or exceed competencies
identified in the Common Competencies for state, local, and tribal intelligence analysts, which outlines
the minimum categories of training needed for intelligence analysts. A certificate of completion of such
training must be on file with the SAA and must be made available to the recipient’s respective FEMA HQ
Preparedness Officer upon request.
As with all allowable expenditures under HSGP, the SAA or its OPSG subrecipient jurisdictions must
agree to and approve the use of funds for this purpose and request to amend applicable grant awards
accordingly. Under OPSG, SAAs and subrecipients requesting to use grant funds in this manner must also
collaborate regarding prioritization of funds for the provision of allowable associated costs for
intelligence analysts with the applicable USBP sector and memorializing the collaboration through an
Operations, Fragmentary or Supplemental Operations Order approved by the USBP sector, USBP
Headquarters, and the FEMA Grant Programs Directorate.
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Temporary or Term Appointments
•
Subrecipients may utilize temporary or term appointments to augment the law enforcement
presence on the borders. However, applying funds toward hiring full-time or permanent sworn
public safety officers is unallowable.
•
OPSG-funded temporary or term appointments may not exceed the approved period of
performance.
o For OPSG purposes, temporary appointments are non-status appointments for less than
one year.
o For OPSG purposes, term appointments are non-status appointments for one year,
extendable for one year as necessary.
•
OPSG funding for temporary or term appointments may pay for salary only. Benefits are not
allowable expenses for term or temporary employees.
•
OPSG remains a non-hiring program. Appropriate uses of temporary or term appointments
include:
o To carry out specific enforcement operations work for ongoing OPSG-funded patrols
throughout the Sector Area of Operation;
o To staff operations of limited duration; such as OPSG-enhanced enforcement patrols
targeting specific locations or criminal activity; and,
o To fill OPSG positions in activities undergoing transition or personnel shortages and
local backfill policies (medical/military deployments)
•
OPSG term and temporary appointments must have all necessary certifications and training to
enforce state and local laws. OPSG funds will not be used to train or certify term or temporary
appointments except as otherwise stated in this Manual and the HSGP NOFO.
•
FEMA provides no guarantee of funding for temporary or term appointments. In addition to the
terms of this Manual and the HSGP NOFO, subrecipients must follow their own applicable
policies and procedures regarding temporary or term appointments.
Management and Administration
Management and administration (M&A) activities are those directly relating to the management and
administration of HSGP funds, such as financial management and monitoring. A maximum of up to five
percent of HSGP funds awarded may be retained by the state, and any funds retained are to be used solely
for M&A purposes associated with the HSGP award. Subrecipients may also retain a maximum of up to
five percent of the funding passed through by the state solely for M&A purposes associated with the
HSGP award.
Recipients or subrecipients may apply or credit M&A funding toward the recipient’s requirement to
allocate funding toward the four National Priority Areas. For example, if a recipient spends $5,000 to
manage or administer its funding dedicated toward its enhancing cybersecurity investment, the recipient
may credit that funding toward its requirement to allocate at least 7.5 percent of its award to the
enhancing cybersecurity National Priority Area.
A state’s HSGP funds for M&A calculation purposes includes the total of its SHSP, UASI, and OPSG
awards. While the SAA may retain up to five percent of this total for M&A, the state must still ensure that
all subrecipient award amounts meet the mandatory minimum pass-through requirements that are
applicable to each HSGP program. To meet this requirement, the percentage of SHSP and UASI funds
passed through to local or tribal jurisdictions must be based on the state’s total HSGP award prior to
withholding any M&A.
In retaining these funds, states may retain a maximum of 2.5 percent of the OPSG allocation, which must
be withheld from the pass-through to each subrecipient county or tribe in an equal percentage. The SAA
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may also retain additional funding from its SHSP award to manage and administer the OPSG award, but
that additional amount is also capped at an amount equal to 2.5 percent of the OPSG award. Examples
applying this principle:
SAA 1:
SHSP: $1,000,000 OPSG: $2,500,000 UASI: $2,500,000
M&A Maximum: $300,000 (5 percent of $6,000,000)
Maximum M&A for SHSP = $50,000
Maximum M&A for OPSG = $125,000. Of that amount, $62,500 (2.5 percent) may be retained
from the OPSG allocation, and the other $62,500 would come from the SHSP allocation. Any
amount used to manage and administer OPSG that is charged to SHSP may be above and
beyond the $50,000 available to manage the SHSP allocation.
Maximum M&A for UASI = $125,000
SAA 2:
SHSP: $3,500,000 OPSG: $1,000,000
M&A Maximum: $225,000 (5 percent of $4,500,000)
Maximum M&A for SHSP = $175,000
Maximum M&A for OPSG = $50,000. Of that amount, $25,000 (2.5 percent) may be retained
from the OPSG allocation, and the other $25,000 would come from the SHSP allocation. Any
amount used to manage and administer OPSG that is charged to SHSP may be above and
beyond the $175,000 available to manage the SHSP allocation.
HSGP recipients are also reminded that any M&A charged to a recipient’s or subrecipient’s UASI
funding must be directly allocable to administration of the UASI grant program and cannot be used to
cover M&A costs that are directly allocable to SHSP or OPSG funding. Similarly, any M&A charged to a
recipient’s or subrecipient’s SHSP or OPSG funding cannot be used to cover M&A costs directly
allocable to UASI funding
Additionally, if a state/territory receives Nonprofit Security Grant Program (NSGP) funding, it may use
SHSP M&A funding to cover M&A costs related to the management of NSGP-State awards, and UASI
M&A funding to cover M&A costs related to the management of NSGP-Urban Area awards..
Specific for OPSG, subrecipients and friendly forces may retain funding for M&A purposes; however, the
total amount retained cannot exceed 5% of the subrecipient’s subaward. Friendly forces are local law
enforcement entities that are subordinate subrecipients under OPSG. In other words, friendly forces are
entities that receive a subaward from a subrecipient under the OPSG program. Friendly forces must
comply with all requirements of subrecipients under 2 C.F.R. Part 200.
Equipment (SHSP and UASI)
The 21 allowable prevention, protection, mitigation, response, and recovery equipment categories for
HSGP are listed on the Authorized Equipment List (AEL). Some equipment items require prior approval
from FEMA before obligation or purchase of the items. Please reference the grant notes for each
equipment item to ensure prior approval is not required or to ensure prior approval is obtained if
necessary. Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they
first seek and obtain prior approval from FEMA.
Unless otherwise stated, all equipment must meet all mandatory regulatory and/or FEMA-adopted
standards to be eligible for purchase using these funds. In addition, recipients will be responsible for
obtaining and maintaining all necessary certifications and licenses for the requested equipment.
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Investments in emergency communications systems and equipment must meet applicable SAFECOM
Guidance. Such investments must be coordinated with the SWIC and the State Interoperability Governing
Body (SIGB) to ensure interoperability and long-term compatibility.
Grant funds may be used for the procurement of medical countermeasures. Procurement of medical
countermeasures must be conducted in collaboration with state, city, or local health departments that
administer federal funds from the Department of Health and Human Services for this purpose and with
existing Metropolitan Medical Response System committees where available, to sustain their long-term
planning for appropriate, rapid, and local medical countermeasures, including antibiotics and antidotes for
nerve agents, cyanide, and other toxins. Procurement must have a sound threat-based justification with an
aim to reduce the consequences of mass casualty incidents during the first crucial hours of a response.
Prior to procuring pharmaceuticals, recipients must have in place an inventory management plan to avoid
large periodic variations in supplies due to coinciding purchase and expiration dates. Recipients are
encouraged to enter into rotational procurement agreements with vendors and distributors. Purchases of
pharmaceuticals must include a budget for the disposal of expired drugs within each fiscal year’s POP for
HSGP. The cost of disposal cannot be carried over to another FEMA grant or grant period.
EMS electronic patient care data systems should comply with the most current data standard of the
National Emergency Medical Services Information System (www.NEMSIS.org).
SHSP and UASI funds can also be used for school hardening measures, including:
•
Bullet resistant doors and glass;
•
Hinge-locking mechanisms;
•
Immediate notification to emergency 911 systems;
•
Mechanisms that provide real time actionable intelligence directly to law enforcement and first
responders;
•
Installation of distraction devices or other countermeasures administered by law enforcement; and
•
Other measures determined to provide significant improvements to schools’ physical security.
Equipment (OPSG)
OPSG equipment is intended to be incidental to the enhanced border security operations being performed.
The grant is not intended to be used to outfit or supply general equipment to SLTT law enforcement
agencies. Equipment must be relatable to and justified by the operational benefit it will provide. Each
appropriate OPSG sector coordinator is required to keep an inventory of OPSG purchased equipment that
includes at a minimum: 1) grant funding year; 2) purchase amount; 3) purchase date; 4) purchase
quantity; 5) equipment ID; 6) source of funding for the property, including the Federal Award
Identification Number; 7) who holds title to the property; 8) federal share percent of the property; 9)
location of the property; 10) use and condition of the property; 11) disposal date; and 12) brief disposal
justification information and sale price if sold. Each Operations Order/FRAGO will require that each
friendly force submit the equipment inventory for each Operations Order/FRAGO submission.
•
Equipment Marking. Because equipment purchased with OPSG funding is intended to be used
to support OPSG activities, it may be appropriately marked to ensure its ready identification and
primary use for that purpose. When practicable, any equipment purchased with OPSG funding
should be prominently marked as follows: "Purchased with DHS funds for Operation
Stonegarden Use."
•
Fuel Cost and Mileage Reimbursement. There is no cap for reimbursement of fuel or mileage
costs in support of operational activities. Subrecipients and friendly forces may not claim
reimbursements for both mileage and fuel/maintenance for the same equipment at the same time.
•
Vehicle and Equipment Acquisition, Including Leasing and Rentals. Allowable purchases
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under OPSG include patrol vehicles and other mission-specific equipment whose primary purpose
is to increase operational capabilities on or near a border nexus in support of approved border
security operations. A detailed justification must be submitted to the respective FEMA HQ
Preparedness Officer prior to purchase.
•
Medical Emergency Countermeasures: Allowable purchases under OPSG include narcotic
antagonist pharmaceuticals, detection and identification equipment, safe storage and
transportation, personnel protective equipment, and initial equipment training, as reflected in the
AEL and explained in IB 438.
Requirements for Small Unmanned Aircraft System (SHSP, UASI, and OPSG)
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and IB 438 and also include a description of the policies and procedures in place to safeguard
individuals’ privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or
otherwise use the sUAS equipment.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Training (SHSP and UASI)
Allowable training-related costs under HSGP include the establishment, support, conduct, and attendance of
training specifically identified under the SHSP and UASI program and/or in conjunction with emergency
preparedness training by other federal agencies (e.g., HHS and Department of Transportation [DOT]).
Training conducted using HSGP funds should address a performance gap identified through an Integrated
Preparedness Plan (IPP) or other assessments (e.g., National Emergency Communications Plan [NECP]
Goal Assessments) and contribute to building a capability that will be evaluated through a formal exercise.
Any training or training gaps, including training related to under-represented diverse populations that may
be more impacted by disasters, including children, seniors, individuals with disabilities or access and
functional needs, individuals with diverse culture and language use, individuals with lower economic
capacity and other underserved populations, should be identified in an IPP and addressed in the state or
high-risk urban area training cycle. Recipients are encouraged to use existing training rather than developing
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new courses. When developing new courses, recipients are encouraged to apply the Analyze, Design,
Develop, Implement, and Evaluate (ADDIE) model of instructional design.
Recipients are also encouraged to utilize the National Training and Education Division’s National
Preparedness Course Catalog. Trainings include programs or courses developed for and delivered by
institutions and organizations funded by FEMA. This includes the Center for Domestic Preparedness (CDP),
the Emergency Management Institute (EMI), and FEMA’s Training Partner Programs, including the
Continuing Training Grants (CTG), the National Domestic Preparedness Consortium (NDPC), the Rural
Domestic Preparedness Consortium (RDPC), and other partners.
The catalog features a wide range of course topics in multiple delivery modes to meet FEMA’s mission
scope as well as the increasing training needs of federal, state, local, territorial, and tribal audiences. The
catalog can be accessed at http://www.firstrespondertraining.gov.
Some training activities require Environmental and Historic Preservation (EHP) Review, including
exercises, drills or trainings that require any type of land, water, or vegetation disturbance or building of
temporary structures or that are not located at facilities designed to conduct training and exercises.
Additional information on training requirements and EHP review can be found online at:
https://www.fema.gov/media-library/assets/documents/90195.
Exercises (SHSP and UASI)
Exercises conducted with grant funding should be managed and conducted consistent with Homeland
Security Exercise and Evaluation Program (HSEEP). HSEEP guidance for exercise design, development,
conduct, evaluation, and improvement planning is located at https://www.fema.gov/emergency-
managers/national-preparedness/exercises/hseep.
Some exercise activities require EHP review, including exercises, drills or trainings that require any type of
land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP
review can be found online at https://www.fema.gov/media-library/assets/documents/90195.
Maintenance and Sustainment (SHSP, UASI, and OPSG)
Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty, and it may only cover equipment purchased with HSGP funds or for equipment dedicated for
HSGP-related purposes. As with warranties and maintenance agreements, this extends to licenses and
user fees as well.
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Except for maintenance plans or extended warranties purchased incidental to the original purchase
of the equipment, the period covered by maintenance or warranty plan must not exceed the POP of the
specific grant funds used to purchase the plan or warranty.
Grant funds are intended to support the Goal by funding projects that build and sustain the core
capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from
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those threats that pose the greatest risk to the security of the Nation. In order to provide recipients the
ability to meet this objective, the policy set forth in FEMA’s IB 379, Guidance to State Administrative
Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding, initially for FY 2007-2011,
allows for the expansion of eligible maintenance and sustainment costs which must be in (1) direct
support of existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant
program; (3) be tied to one of the core capabilities in the five mission areas contained within the Goal,
and (4) shareable through the EMAC. Additionally, eligible costs may also be in support of equipment,
training, and critical resources that have previously been purchased with either federal grant or any other
source of funding other than FEMA preparedness grant program dollars.
Law Enforcement Terrorism Prevention Activities Allowable Costs (SHSP and UASI)
Activities eligible for the use of Law Enforcement Terrorism Prevention Activities (LETPA) focused
funds include but are not limited to:
•
Maturation, enhancement, and sustainment of designated state and major urban area fusion
centers, including information sharing and analysis, threat recognition, terrorist interdiction, and
training/ hiring of intelligence analysts;
•
Coordination between fusion centers and other intelligence, operational, analytic, or
investigative efforts including, but not limited to JTTFs, Field Intelligence Groups (FIGs), High-
Intensity Drug Trafficking Areas (HIDTA), Regional Information Sharing Systems (RISS)
Centers, criminal intelligence units, real-time crime analysis centers and DHS intelligence,
operational, analytic, and investigative entities;
•
Implementation and maintenance of the nationwide Suspicious Activity Reporting (SAR)
Initiative (NSI), including training for front-line personnel on identifying and reporting
suspicious activities, tips/leads, and online/social media-based threats, as well as the execution
and management of threat assessment programs to identify, evaluate, and analyze indicators and
behaviors indicative of terrorism, targeted violence, threats to life, and other criminal activity;
•
Management and operation of activities that support the execution of the intelligence process
and fusion centers, including but not limited to: Fusion Liaison Officer (FLO) programs,
security programs to protect the facility, personnel, and information, and the protection of
privacy, civil rights, and civil liberties.
•
Implementation of the “If You See Something, Say Something®” campaign to raise public
awareness of indicators of terrorism and terrorism-related crime and associated efforts to
increase the sharing of information with public and private sector partners, including nonprofit
organizations. Note: DHS requires that all public and private sector partners wanting to
implement and/or expand the DHS “If You See Something, Say Something®” campaign using
grant funds work directly with the DHS Office of Partnership and Engagement (OPE) to ensure
all public awareness materials (e.g., videos, posters, tri-folds, etc.) are consistent with DHS’s
messaging and strategy for the campaign and compliant with the initiative’s trademark, which is
licensed to DHS by the New York Metropolitan Transportation Authority. Coordination with
OPE, through the Campaign’s Office (seesay@hq.dhs.gov), must be facilitated by the FEMA
HQ Preparedness Officer;
•
Increase physical security, through law enforcement personnel and other protective measures,
by implementing preventive and protective measures at critical infrastructure sites or at-risk
nonprofit organizations;
•
Building and sustaining preventive radiological and nuclear detection capabilities, including
those developed through the Securing the Cities initiative; and
•
Integration and interoperability of systems and data, such as computer aided dispatch (CAD)
and record management systems (RMS), to facilitate the collection, evaluation, and assessment
of suspicious activity reports, tips/leads, and online/social media-based threats.
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Law Enforcement Readiness (SHSP, UASI, and OPSG)
OPSG grant funds may be used to increase operational, material, and technological readiness of SLTT
law enforcement agencies. The Delegation of Immigration Authority, Section 287(g) of the Immigration
and Nationality Act (INA) program allows a state or local law enforcement entity to enter into a
partnership with Immigration and Customs Enforcement (ICE), under a joint Memorandum of Agreement
(MOA), to receive delegated authority for immigration enforcement within their jurisdictions.
SHSP, UASI, or OPSG grant funds may be requested and may be approved on a case-by-case basis for
immigration enforcement training in support of the border security mission. Requests for training will be
evaluated on a case-by-case basis and can only be used for certification in the section 287(g) program
provided by DHS/ICE. SHSP, UASI, or OPSG subrecipients with agreements under section 287(g) of the
INA (8 U.S.C. § 1357(g)) to receive delegated authority for immigration enforcement within their
jurisdictions may also be reimbursed for section 287(g) related operational activities with approval from
FEMA on a case-by-case basis. For OPSG, subrecipients must be authorized by USBP Headquarters and
Sectors, and operational activities must be coordinated through a USBP Sector.
Regional Border Projects (OPSG)
Recipients are encouraged to prioritize the acquisition and development of regional projects on the
borders to maximize interoperability and coordination capabilities among federal agencies and with state,
local, and tribal law enforcement partners. Such regional projects include:
•
Communications equipment
•
Radio systems and repeaters
•
Integration with regional intelligence and information sharing effort (i.e., fusion centers)
o Intelligence analysts
•
Situational Awareness equipment:
o License Plate Reader Networks
o Visual detection and surveillance systems
o Sensor Systems
o Radar Systems (for air and/or marine incursions)
o Aircraft systems (manned or unmanned)
Critical Emergency Supplies (SHSP and UASI)
Critical emergency supplies, such as shelf stable products, water, and medical equipment and supplies are
an allowable expense under SHSP and UASI. Prior to the allocation of grant funds for stockpiling
purposes, each state must have FEMA’s approval of a five-year viable inventory management plan, which
should include a distribution strategy and related sustainment costs if planned grant expenditure is over
$100,000.00.
If grant expenditures exceed the minimum threshold, the five-year inventory management plan will be
developed by the recipient and monitored by FEMA. FEMA will provide program oversight and technical
assistance as it relates to the purchase of critical emergency supplies under UASI. FEMA will establish
guidelines and requirements for the purchase of these supplies under UASI and monitor development and
status of the state’s inventory management plan.
SAAs (through their Emergency Management Office) are strongly encouraged to consult with their
respective FEMA Regional Logistics Chief regarding disaster logistics-related issues. States are further
encouraged to share their FEMA approved plan with local jurisdictions and tribes.
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Construction and Renovation (SHSP and UASI)
Project construction using SHSP and UASI funds may not exceed the greater of $1,000,000 or 15% of the
grant award. For the purposes of the limitations on funding levels, communications towers are not
considered construction. See guidance on communication towers below.
All construction and renovation projects require EHP review. Recipients and subrecipients are
encouraged to have completed as many steps as possible for a successful EHP review in support of their
proposal for funding (e.g., coordination with their State Historic Preservation Office to identify potential
historic preservation issues and to discuss the potential for project effects, compliance with all state and
local EHP laws and requirements). Projects for which the recipient believes an Environmental
Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01,
FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ
Preparedness Officer within six months of the award and completed EHP review materials must be
submitted no later than 12 months before the end of the period of performance. EHP policy guidance and
the EHP Screening Form, can be found online at: https://www.fema.gov/media-
library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.dhs.gov.
Written approval must be provided by FEMA prior to the use of any HSGP funds for construction or
renovation. When applying for construction funds, recipients must submit evidence of approved zoning
ordinances, architectural plans, and any other locally required planning permits. Additionally, recipients
are required to submit a SF-424C form with budget detail citing the project costs, and an SF-424D Form
for standard assurances for the construction project.
Recipients using funds for construction projects must comply with the Davis-Bacon Act (codified as
amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character like the contract work in the civil subdivision of the state
in which the work is to be performed. Additional information regarding compliance with the Davis-Bacon
Act, including Department of Labor (DOL) wage determinations, is available online at
https://www.dol.gov/whd/govcontracts/dbra.htm.
Construction and Renovation (OPSG)
OPSG funds may not be used for any construction.
Communications Towers
All construction of communication towers requires EHP review. When applying for funds to construct
communication towers, recipients and subrecipients must submit evidence that the Federal
Communication Commission’s Section 106 of the National Historic Preservation Act, Pub. L. No. 89-
665, as amended, review process has been completed and submit all documentation resulting from that
review to FEMA with a GPD EHP Screening Form and supporting materials for EHP review. Recipients
and subrecipients are encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with their State Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects,
compliance with all state and local EHP laws and requirements). Projects for which the recipient believes
an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision 01, FEMA
Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness
Officer within six months of the award and completed EHP review materials must be submitted no later
than 12 months before the end of the period of performance. EHP policy guidance and the EHP Screening
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Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195. EHP review
materials should be sent to gpdehpinfo@fema.dhs.gov.
Western Hemispheric Travel Initiative (SHSP)
In addition to the expenditures outlined above, SHSP funds may be used to support the implementation
activities associated with the Western Hemisphere Travel Initiative (WHTI), including the issuance of
WHTI-compliant tribal identification cards.
Emergency Management Accreditation Program
States can encourage their local jurisdictions to pursue assessment and accreditation under the Emergency
Management Accreditation Program (EMAP). EMAP’s assessment and accreditation of emergency
management organizations against consensus-based, American National Standards Institute (ANSI)-
certified standards allows for standardized benchmarking of critical functions necessary for an emergency
management organization to meet the core capabilities identified in the Goal. Additional information on
the EMAP Standard is available at http://www.emap.org.
28 C.F.R. Part 23 Guidance
FEMA requires that any information technology system funded or supported by these funds comply with
28 C.F.R. Part 23, Criminal Intelligence Systems Operating Policies if this regulation is determined to be
applicable. Additionally, please see 28 C.F.R. Part 23 requirements that pertain to fusion centers at
http://www.dhs.gov/homeland-security-grant-programs-hsgp.
Unallowable Costs (OPSG)
OPSG unallowable costs include costs associated with evidence collection, arrest processing, prosecution,
and Traffic/DUI checkpoints, such as evidence documentation cameras, fingerprinting supplies, alcohol
breathalyzers, portable work lights, traffic barricades, and similar law enforcement expenses. OPSG
unallowable costs also include costs associated with staffing and general IT computing equipment and
hardware, such as personal computers, faxes, copy machines, modems, etc. OPSG is not intended as a
hiring program. Therefore, applying funds toward hiring full-time or permanent sworn public safety
officers is unallowable. OPSG funding shall not be used to supplant inherent routine patrols and law
enforcement operations or activities not directly related to providing enhanced coordination between local
and federal law enforcement agencies. Finally, construction and/or renovation costs are prohibited under
OPSG. Applicants should refer to IB 421b, or contact their FEMA HQ Preparedness Officer for guidance
and clarification. Due to the nature of OPSG, exercise expenses are not allowable costs under OPSG.
Unallowable Costs (SHSP, UASI, and OPSG)
•
Per FEMA policy, the purchase of weapons and weapons accessories, including ammunition, is
not allowed with HSGP funds.
•
Grant funds may not be used for the purchase of equipment not approved by FEMA. Grant funds
must comply with IB 426 and may not be used for the purchase of the following equipment:
firearms; ammunition; grenade launchers; bayonets; or weaponized aircraft, vessels, or vehicles of
any kind with weapons installed.
•
Unauthorized exercise-related costs include:
o Reimbursement for the maintenance or wear and tear costs of general use vehicles (e.g.,
construction vehicles), medical supplies, and emergency response apparatus (e.g., fire
trucks, ambulances).
o Equipment that is purchased for permanent installation and/or use, beyond the scope of
the conclusion of the exercise (e.g., electronic messaging sign).
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Indirect (Facilities and Administrative [F&A]) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Resources for Planning, Training, and Exercising (SHSP, UASI, and OPSG)
Planning Assistance
FEMA’s National Preparedness Directorate (NPD) offers technical assistance (TA) that is designed to
provide recipients and subrecipients with specialized expertise to improve and enhance the continuing
development of state and local emergency management across the five mission areas of the Goal and
across all core capabilities. TA provides the opportunity to engage emergency managers, emergency
planners, and appropriate decision-makers in open discussion of options to improve plans and planning
considering their jurisdiction’s needs. Although there is no direct cost to approved jurisdictions for FEMA
TA, jurisdictions are expected to invest staff resources and take ownership of the resulting products and
tools.
TA deliveries combine current emergency management best practices with practical consideration of
emerging trends, through discussion facilitated by FEMA contract specialists and with the support of
FEMA Region operational specialists. Additionally, peer-to-peer representation may also be included
from other jurisdictions that have recently addressed the same planning issue. The TA request form can be
accessed at https://www.fema.gov/emergency-managers/nims/implementation-training.
Training Information
Per IB 432, Review and Approval Requirements for Training Courses Funded Through Preparedness
Grants, issued on July 19, 2018, states, territories, tribal entities, and high-risk urban areas are no longer
required to request approval from FEMA for personnel to attend non-DHS FEMA training as long as the
training is coordinated with and approved by the state, territory, tribal, or high-risk urban area Training
Point of Contact (TPOC) and falls within the FEMA mission scope and the jurisdiction’s EOP. For
additional information on review and approval requirements for training courses funded with
preparedness grants, please refer to the following policy:
http://www.fema.gov/https://www.fema.gov/sites/default/files/2020-09/fema_gpd-review-approval-
requirements-training-policy_09-10-13.pdf.
FEMA will conduct periodic reviews of all state, local, territory, tribal entities, and high-risk urban area
training funded by FEMA. These reviews may include requests for all course materials and physical
observation of, or participation in, the funded training. If these reviews determine that courses are outside
the scope of this guidance, recipients will be asked to repay grant funds expended in support of those
efforts. For further information on developing courses using the instructional design methodology and
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tools that can facilitate the process, SAAs and TPOCs are encouraged to review the NTED Responder
Training Development Center (RTDC) website.
Some training and exercise activities require EHP Review, including exercises, drills or trainings that
require any type of land, water, or vegetation disturbance or building of temporary structures or that are not
located at facilities designed to conduct training and exercises. Additional information on training
requirements and EHP review can be found online at https://www.fema.gov/media-
library/assets/documents/90195.
DHS/FEMA Provided Training and Education
FEMA offers tuition-free training and education programs and courses through several providers including
the Center for Domestic Preparedness, the Emergency Management Institute, and the National Training
and Education Division’s Training Partners Program (TPP). TPP includes the Center for Homeland
Defense and Security, National Domestic Preparedness Consortium, Rural Domestic Preparedness
Consortium, and training partners through the Continuing Training Grants program.
FEMA’s National Preparedness Course Catalog
This online searchable catalog features a wide range of course topics in multiple delivery modes to meet
FEMA’s mission scope as well as the increasing training needs of federal, state, local, territorial, and tribal
audiences. The catalog can be accessed at http://www.firstrespondertraining.gov.
Training Not Provided by DHS/FEMA
These trainings include courses that are either state-sponsored or federal-sponsored (non-DHS/FEMA),
coordinated and approved by the SAA or their designated TPOC, and fall within the FEMA mission scope
to prepare SLTT personnel to prevent, protect against, mitigate, respond to, and recover from acts of
terrorism or catastrophic events.
•
State Sponsored Courses. These courses are developed for and/or delivered by institutions or
organizations other than federal entities or FEMA and are sponsored by the SAA or their
designated TPOC.
•
Joint Training and Exercises with the Public and Private Sectors. These courses are sponsored
and coordinated by private sector entities to enhance public-private partnerships for training
personnel to prevent, protect against, mitigate, respond to, and recover from acts of terrorism or
catastrophic events. In addition, states, territories, tribes, and high-risk urban areas are
encouraged to incorporate the private sector in government- sponsored training and exercises.
Additional information on both FEMA provided training and other federal and state training can be found
at http://www.firstrespondertraining.gov.
Training Information Reporting System (“Web-Forms”)
Web-Forms is an electronic data management system built to assist SAA TPOCs and federal agencies
with submitting non-NTED provided training courses for inclusion in the State/Federal-Sponsored Course
Catalog through electronic forms. The information collected is used in a two-step review process to
ensure the training programs adhere to the intent of the HSGP guidance and the course content is
structurally sound and current. As these programs may be delivered nationwide, it is vital to ensure each
training program’s viability and relevance to the Homeland Security mission. Reporting training activities
through Web-Forms is not required under present funding. However, the system remains available and
can be accessed through the FEMA Toolkit to support recipients in their own tracking of training
deliveries.
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Exercise Information
Recipients that use HSGP funds to conduct an exercise(s) are encouraged to complete a progressive
exercise series. Exercises conducted by states and high-risk urban areas may be used to fulfill similar
exercise requirements required by other grant programs. Recipients are encouraged to invite
representatives/planners involved with other federally mandated or private exercise activities. States and
high-risk urban areas are encouraged to share, at a minimum, the multi- year training and exercise
schedule with those departments, agencies, and organizations included in the plan.
•
Validating Capabilities. Exercises examine and validate capabilities-based planning across the
Prevention, Protection, Mitigation, Response, and Recovery mission areas. The extensive
engagement of the whole community, including but not limited to examining the needs and
requirements for individuals with disabilities, individuals with limited English proficiency, and
others with access and functional needs, is essential to the development of an effective and
comprehensive exercise program. Exercises are designed to be progressive – increasing in scope
and complexity and drawing upon results and outcomes from prior exercises and real-world
incidents – to challenge participating communities. Consistent with HSEEP guidance and tools,
the National Exercise Program (NEP) serves as the principal exercise mechanism for examining
national preparedness and measuring readiness. Exercises should align with priorities and
capabilities identified in a multi-year IPP.
•
Special Event Planning. If a state or high-risk urban area will be hosting a special event (e.g.,
Super Bowl, G-8 Summit), the special event planning should be considered as a training or
exercise activity for the multi-year IPP. States must include all confirmed or planned special
events in the multi-year IPP. The state or high-risk urban area may plan to use SHSP or UASI
funding to finance training and exercise activities in preparation for those events. States and
high-risk urban areas should also consider exercises at major venues (e.g., arenas, convention
centers) that focus on evacuations, communications, and command and control.
•
Regional Exercises. States should also anticipate participating in at least one regional exercise
annually.
•
Role of Non-Governmental Entities in Exercises. Non-governmental participation in all levels of
exercises is strongly encouraged. Leaders from non-governmental entities should be included in
the planning, design, and evaluation of an exercise. SLTT jurisdictions are encouraged to
develop exercises that test the integration and use of resources provided by non-governmental
entities, defined as the private sector and private non-profit, faith-based, and community
organizations. Participation in exercises should be coordinated with local Citizen Corps Whole
Community Council(s) or their equivalents and other partner agencies.
Reporting on the Implementation of the National Preparedness
System
Identifying and Assessing Risk and Estimating Capability Requirements
By December 31, 2021, states, territories, and high-risk urban areas are required to complete a
THIRA/SPR that addresses all 32 core capabilities and is compliant with CPG 201, Third Edition.
Specific guidance on the requirements for each core capability will be forthcoming in 2021, as some core
capabilities have fewer reporting requirements than others. Beginning in 2020, jurisdictions began the
requirement to respond to a series of planning-related questions as part of the THIRA/SPR.
Jurisdictions are required to submit a THIRA every three (3) years to establish a consistent baseline for
assessment. While the THIRA will be only required every three years, jurisdictions will continue to be
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required to submit an SPR annually. For additional guidance on the THIRA/SPR, please refer
to Comprehensive Preparedness Guide (CPG) 201, Third Edition.
Reporting
•
States and territories will submit their THIRA and SPR through the Unified Reporting Tool
(URT) on Prep Toolkit no later than December 31 of the applicable year (every three years for
THIRA and each year for SPR).
•
High-risk urban areas that receive UASI funding will submit their THIRA/SPR through the URT
on Prep Toolkit no later than December 31 for the years during which they have UASI funding.
•
States, territories and high-risk urban areas should work collaboratively to create the most
accurate THIRA and SPR possible. States, territories, and high-risk urban areas may share
scenarios, targets, and assessed capabilities when appropriate.
•
Please contact FEMA-SPR@fema.dhs.gov if you have questions.
Building and Sustaining Capabilities
States, territories, and high-risk urban areas must prioritize and align SHSP and UASI grant funding
investments in building and sustaining capabilities in areas that align with the national priorities in the
annual HSGP NOFO and capability gaps identified in their THIRA and SPR.
Reporting
In each HSGP recipient’s Biannual Strategy and Implementation Report (BSIR), as part of programmatic
monitoring, the recipient must describe how expenditures support closing capability gaps or sustaining
capabilities identified in the THIRA and SPR. HSGP recipients must, on a project-by-project basis, check
one of the following:
•
Building a capability with HSGP funding
•
Sustaining a capability with HSGP funding
National Incident Management System (NIMS) Implementation
Recipients receiving HSGP funding are required to implement NIMS. NIMS guides all levels of
government, nongovernmental organizations (NGO), and the private sector to work together to prevent,
protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the
whole community with the shared vocabulary, systems, and processes to successfully deliver the
capabilities described in the National Preparedness System. HSGP recipients must use standardized
resource management concepts for resource typing, credentialing, and an inventory to facilitate the
effective identification, dispatch, deployment, tracking, and recovery of resources.
The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarify the
NIMS implementation requirements in FEMA preparedness grant NOFOs. As recipients and
subrecipients of federal preparedness (non-disaster) grant awards, jurisdictions and organizations must
achieve, or be actively working to achieve, all of the NIMS Implementation Objectives. The objectives
can be found on the NIMS webpage at https://www.fema.gov/emergency-managers/nims/implementation-
training.
Reporting
•
Recipients report in the applicable secondary NIMS assessment portion of the URT as part of
their THIRA/SPR submission, as outlined in the HSGP NOFO.
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Planning to Deliver Capabilities
Recipients shall develop and maintain, jurisdiction-wide, all threats and hazards Emergency Operations
Plans (EOPs) consistent with Comprehensive Preparedness Guide 101, Version 2.0 (CPG 101 v2),
Developing and Maintaining Emergency Operations Plans (November 2010). Recipients must update
their EOPs at least once every two years.
Reporting
•
Recipients report EOP compliance with CPG 101 v2 by completing the secondary CPG-101
assessment in the URT.
Validating Capabilities
All recipients will develop and maintain a progressive exercise program consistent with HSEEP guidance
in support of the NEP. The NEP serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that
validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’
Strategic Priorities, established by the National Security Council and informed by preparedness data from
jurisdictions across the Nation.
To develop and maintain a progressive exercise program consistent with HSEEP and in support of the
NEP, recipients should engage senior leaders and other whole community stakeholders to identify
preparedness priorities. These priorities should be informed by various factors, including jurisdiction-
specific threats and hazards (i.e., the THIRA); areas for improvement identified by real-world events and
exercises; external requirements such as state or national preparedness reports, homeland security policy,
and industry reports; and accreditation standards, regulations, or legislative requirements. Recipients
should document these priorities and use them to deploy a schedule of preparedness events in a multi-year
IPP. Information related to Integrated Preparedness Planning Workshops (IPPWs) can be found on the
HSEEP website at https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep
and https://preptoolkit.fema.gov/.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance,
tools and resources, enhanced coordination, and the ability to directly influence and inform policy and
preparedness programs. If you have any questions, or would like to request assistance through the NEP,
please visit the NEP website at: https://www.fema.gov/national-exercise-program, or reach out to the
National Exercise Program directly at NEP@fema.dhs.gov.
•
Recipients must have a current multi-year IPP that identifies preparedness priorities and
activities. The current multi-year IPP must be submitted to hseep@fema.dhs.gov before January
31 of each year.
o Recipients are encouraged to enter their exercise information into the Preparedness
Toolkit at https://preptoolkit.fema.gov/.
•
Recipients must submit After-Action Report (AAR)/Improvement Plans (IPs) to
hseep@fema.dhs.gov and indicate which fiscal year’s funds were used (if applicable).
•
Submission of AAR/IPs must take place no later than December 31 of each year. For exercises
that occur within the final quarter of a calendar year, submission of AAR/IPs must occur within
90 days after completion of the single exercise. Regardless of conduct date, recipients are
encouraged to submit AAR/IPs within 90 days after completion of the single exercise or
progressive series.
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took
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place at the state, territorial, tribal, or UASI level. Recipients are discouraged from
submitting AAR/IPs specific to local jurisdictions that reflect drills.
o If a recipient endures a significant real-world incident during the calendar year that
delays or prevents conduct of a grant-funded exercise, they can submit the AAR from
that event in place of the exercise AARs. Jurisdictions submitting real world AARs
should include an explanation with the AAR submission to hseep@fema.dhs.gov.
o Recipients can access a sample AAR/IP template at:
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.
Fusion Centers
A critical component of the national response to the 9/11 terrorist attacks was the development of a
national-level, decentralized, and coordinated terrorism-related information sharing environment (ISE).
State and local governments, supported by federal investments from DHS, the Department of Justice
(DOJ), Department of Health and Human Services (HHS), and other federal agencies, established the
National Network of Fusion Centers (National Network), which became the backbone of the national ISE.
This National Network, comprised of 80 state and major urban area fusion centers, collaborates and
shares information with partners from all levels of government and the private sector, as well as other
field-based information sharing partners, including HIDTAs, RISS Centers, JTTFs, major city/county
intelligence units, and real-time crime analysis centers, among others.
National Network participation in the Nationwide SAR Initiative (NSI) enables fusion centers to identify,
receive and analyze suspicious activity reporting and other tips/leads from frontline public safety
personnel, the private sector, and the public, and ensure the sharing of SARs with DHS and the FBI’s
JTTFs for further investigation. In addition to those activities identified in the National Prevention
Framework, fusion centers are also required to collaborate with those intelligence, operational, analytic,
investigative, and information-sharing focused entities to combat a wide array of threats – noted below –
in support of efforts to enhance capabilities for detecting, deterring, disrupting, and preventing acts of
terrorism, targeted violence, and other threats. Such entities include, but are not limited to JTTFs, Area
Maritime Security Committees, Border Enforcement Security Task Forces, Integrated Border
Enforcement Teams, HIDTAs, and RISS Centers as well as other federal intelligence, operational,
analytic, and investigative entities. Applicants should describe their collaboration plan and proposed
efforts in their required Fusion Center project as part of the Intelligence and Information Sharing National
Priority.
Today’s threats—including international and domestic terrorism, drugs, gangs, active shooters, targeted
violence, transnational organized crime, and cyber—require federal, state, and local governments to
leverage this national capacity to effectively respond to the evolving nature of the various national and
homeland security threats confronting our Nation. Ultimately, timely identification and analysis of key
indicators from local, state, and federal partners will enable all stakeholders to address emerging threats
and develop and implement data-driven strategies to prevent, protect against, mitigate, and respond
effectively, while ensuring the protection of privacy, civil rights, and civil liberties.
To underscore the importance of the National Network as a critical component of our Nation’s distributed
homeland security and counterterrorism architecture, FEMA preparedness grants will continue to
prioritize support for designated fusion centers (http://www.dhs.gov/fusion-center-locations-and-contact-
information) and the maturation of the ISE. Fusion centers must prioritize the following capabilities to
further enable and mature this national asset and strengthen the collective capacity to identify, collect,
analyze, and share information, and to disseminate actionable and strategic intelligence to key
stakeholders:
HSGP Appendix | February 2021
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•
Addressing Emerging Threats: Fusion centers provide a national-level, decentralized, and
coordinated ISE across all levels of government and disciplines that can be leveraged and applied
to address emerging threats to homeland security, national security, public safety, and/or public
health, and especially those threats that may have little or no warning. Fusion centers should
leverage and build upon their terrorism-focused analytic and information-sharing capabilities so
they can be applied to address threats across the DHS mission space, including threats from both
international terrorism and domestic violent extremists, threats to life and targeted violence,
transnational organized criminal activity, cyber threats, and natural hazards, among others that
require close collaboration with DHS operational, investigative, and analytic entities such as
CBP, ICE, United States Secret Service (USSS), Cybersecurity and Infrastructure Security
Agency (CISA), the United States Coast Guard (USCG), and FEMA.
•
Analytic Capability: Fusion centers must maintain strong analytic capabilities at tactical,
operational, and strategic levels to address a wide array of threats or hazards that could have
implications for homeland security or national security. These capabilities directly support
operational, investigative, and information sharing efforts across all levels of government. These
capabilities include, but are not limited to:
o Building and sustaining a capable workforce of analysts who have the necessary
experience and training; access to open source, unclassified and classified information,
products, data, suspicious activity reporting; tips/leads and online/social media-based
threats; as well as necessary services and technology to facilitate analytic capabilities and
collaboration.
o Assessing, evaluating, and deconflicting acts of targeted violence, threats to life, and
other criminal or suspicious activity, to include potential indicators and behaviors, for
potential connection to or implications for international or domestic terrorism, or other
threats within the DHS mission space.
o Providing analytic support and responses to requests for information from federal, state,
and local partners during no notice emerging threats, attacks, or incidents, as well as
other planned events such as NSSEs.
o Conducting threat assessments within their respective jurisdictions, including the
identification of threats, intelligence gaps, and mitigation efforts.
o Establishing, formalizing, and maintaining bi-directional information sharing with federal
and other state agencies in accordance with jurisdictional authorities.
o Leveraging available resources and capabilities to conduct target and event deconfliction
in support of threat identification, officer safety, and information sharing.
o Maintaining an ability to routinely support federal government efforts to watchlist
terrorists and transnational organized crime actors.
o Appropriately planning for, and assessing/forecasting, prioritizing, and executing against
both known and emerging threat vectors, and ensuring the safety and security of all
operations, while protecting privacy, civil rights, and civil liberties.
Fusion centers should also consider their operational capacity when aligning manpower and
resources in support of this capability (e.g., the ability to maintain watch and analytic support
functions over a 24/7 operational tempo).
•
Technological Integration: Access to data, information, and products is essential for fusion
centers and the federal government to effectively identify, collect, analyze, and share information.
Just as threats do not stop at jurisdictional borders, fusion centers must be able to effectively
access and share appropriate information and data across jurisdictions, agencies, and disciplines.
Fusion centers must ensure and certify via the Fusion Center Assessment they have the
necessary technological capacity to access, analyze, and share information, including criminal
intelligence and online/social media threat information, both within their jurisdictions, as well as
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with other fusion centers across the country and with the Federal Government through a variety
of systems, databases, tools, and technologies that allow for federated searching and
data/information analysis that protects Personally Identifiable Information and includes
appropriate security, privacy, civil rights, and civil liberties protections. This includes
maintenance of the ability to collect, integrate, evaluate, and assess SAR, tips/leads, data resident
in CAD and RMS, and online/social media-based threats from agencies across the jurisdiction.
Such approaches should also address the evaluation and use of emerging capabilities, including
social network analysis, federated search technology across CAD, RMS, and other data systems,
complex data indexing, social media, open source, facial recognition, unmanned aircraft systems,
geographic information systems (GIS), license plate reader technologies, and other artificial
intelligence technologies.
•
Interagency Collaboration: Fusion centers must maintain strong partnerships to enable
intelligence, operational, investigative, and analytic collaboration and deconfliction of threat
information with other partners located within their jurisdiction and across their region, including
HIDTAs, RISS Centers, DHS intelligence, operational, investigative, and analytic entities, FBI
Field Offices, JTTFs, and major city/county intelligence units.
State and urban area fusion centers receiving SHSP or UASI grant funds will be evaluated based on
compliance with the guidance and requirements for the National Network as set forth by DHS
Intelligence and Analysis (I&A) through the annual Fusion Center Assessment.
•
Additional fusion center grant requirements are listed at http://www.dhs.gov/homeland-security-
grant-program-hsgp.
•
FEMA approved analyst courses that meet the grant requirement are listed at
http://www.dhs.gov/fema-approved-intelligence-analyst-training-courses.
Through the Program Performance Report (PPR), fusion centers will report on the compliance with
measurement requirements within the fusion centers through the annual Fusion Center Assessment
managed by DHS I&A and reported to FEMA. In addition to the activities identified in the National
Prevention Framework, fusion centers are also required to collaborate with those analytic, investigative,
and information-sharing entities focused on preventing, detecting, deterring, and disrupting acts of
terrorism and combating transnational criminal organizations. Such entities include, but are not limited to
JTTFs, Area Maritime Security Committees, Border Enforcement Security Task Forces, Integrated
Border Enforcement Teams, HIDTAs, and RISS Centers, as well as other federal intelligence,
operational, analytic, and investigative entities. Applicants will be required to provide information
regarding their information sharing partnerships, including how they will identify, address, and
overcome any existing laws, policies, and practices that prevent information sharing, via the
Information and Intelligence National Priority Investment and supporting data via the annual
Fusion Center Assessment.
Fusion Center Performance Measures
Reference
Number
Performance Measures
2021.1
Percentage of federal Information Intelligence Reports (IIRs) originating from fusion center
information that address a specific Intelligence Community need
2021.2
Percentage of federal IIRs originating from fusion center information that the Intelligence
Community otherwise used in performing its mission (e.g., contained first-time reporting;
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Reference
Number
Performance Measures
corroborated existing information; addressed a critical intelligence gaps; or helped to define an issue
or target).
2021.3
Number of SARs vetted and submitted by fusion centers that result in the initiation or enhancement
of an investigation by the FBI
2021.4
Number of SAR vetted and submitted by fusion centers that involve an individual on the Watchlist
2021.5
Percentage of Requests for Information (RFIs) from the Terrorist Screening Center (TSC) for which
fusion centers provided information for a TSC case file
2021.6
Percentage of I&A Watchlist nominations that were initiated or updated existing case files based on
information provided by fusion centers
2021.7
Number of distributable analytic products co-authored by one or more fusion centers and/or federal
agencies
2021.8
Percentage of fusion center distributable analytic products that address Homeland Security topics
2021.9
Percentage of fusion center distributable analytic products that address state/local customer
information needs
2021.10
Percentage of key customers reporting that fusion center products are relevant
2021.11
Percentage of key customers reporting that fusion center services are relevant
2021.12
Percentage of key customers reporting that fusion center products are timely for mission needs
2021.13
Percentage of key customers reporting that fusion center services are timely for mission needs
2021.14
Percentage of key customers reporting that fusion center products influenced their decision making
related to threat response activities within their AOR
2021.15
Percentage of key customers reporting that fusion center services influenced their decision making
related to threat response activities within their AOR
2021.16
Percentage of key customers reporting that fusion center products resulted in increased situational
awareness of threats within their AOR
2021.17
Percentage of key customers reporting that fusion center services resulted in increased situational
awareness of threats within their AOR
2021.18
Number of tips and leads vetted by the fusion center
2021.19
Number of tips and leads vetted by the fusion center that were provided to other F/SLTT agencies
for follow up action
2021.20
Number of responses to RFIs from all sources
2021.21
Number of situational awareness products developed and disseminated by fusion centers
2021.22
Number of case support and/or tactical products developed and disseminated by fusion centers
2021.23
Percentage of federally designated special events in which fusion centers played a direct role
2021.24
Percentage of federally declared disasters in which fusion centers played a direct role
2021.25
Number of public safety incidents in which fusion centers played a direct role
Continuity of Operations
Continuity planning and operations are an inherent element of each core capability and the coordinating
structures that provide them. Continuity operations increase resilience and the probability that
organizations can perform essential functions in the delivery of core capabilities that support the mission
areas. FEMA is responsible for coordinating the implementation and development, execution, and
HSGP Appendix | February 2021
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assessment of continuity capabilities among executive departments and agencies. To support this role,
FEMA develops and promulgates the Continuity Guidance Circular (CGC) for federal and SLTT
governments, non-governmental organizations, and private sector critical infrastructure owners and
operators. Federal Continuity Directives (FCDs) establish continuity program and planning requirements
for executive departments and agencies. This direction and guidance assist in developing capabilities for
continuing the essential functions of federal and SLTT governmental entities, as well as public/private
critical infrastructure owners, operators, and regulators enabling them.
Presidential Policy Directive 40, FCD 1, FCD 2, and CGC outline the overarching continuity
requirements and guidance for organizations and provides methodology and checklists. For additional
information on continuity programs, guidance, and directives, visit https://www.fema.gov/continuity-
guidance-circular-cgc and https://www.fema.gov/about/offices/continuity.
Governance
In keeping with the guiding principles of governance for all FEMA preparedness programs, recipients
must coordinate activities across preparedness disciplines and levels of government, including state,
territorial, local, and tribal governments. A cohesive planning framework should incorporate FEMA
resources as well as those from other federal and SLTT entities, the private sector, and faith-based
community organizations. Specific attention should be paid to how available preparedness funding
sources can effectively support a whole community approach to emergency preparedness and
management and the enhancement of core capabilities. To ensure this, the SAA must establish or
reestablish a unified Senior Advisory Committee. Additionally, urban areas are required to establish
UAWGs representative of the counties, cities, towns, and tribes within the high-risk urban area, including,
as appropriate, representatives of rural jurisdictions, high-population jurisdictions, and high-threat
jurisdictions.
Senior Advisory Committee (SAC)
The SAC builds upon previously established advisory bodies under the SHSP, UASI program, Nonprofit
Security Grant Program (NSGP), Transit Security Grant Program (TSGP), and Port Security Grant
Program (PSGP). Examples of advisory bodies that should be included on a SAC include UAWGs, SIGB,
Area Maritime Security Committees (AMSCs), Regional Transportation Security Working Groups
(RTSWGs), Citizen Corps Whole Community Councils, Disability Inclusion Working Groups, and
Children’s Working Groups. The membership of the SAC must reflect a state’s unique risk profile and the
interests of the five mission areas as outlined in the Goal. Further, the SAC must include representatives
that were involved in the production of the state’s THIRA and SPR.
SAC Composition and Scope
SAC membership shall include at least one representative from relevant stakeholders including:
•
Individuals from the counties, cities, towns, and Indian tribes within the state or high-risk urban
area, including, as appropriate, representatives of rural, high-population, and high-threat
jurisdictions of UASI-funded urban areas
•
Representatives that were involved in the production of the state’s THIRA and SPR
•
State and urban area Chief Information Officers (CIOs) and Chief Information Security Officers
(CISOs)
•
SWIC and SIGB members
•
Citizen Corps Whole Community Councils
•
Local or tribal government officials
HSGP Appendix | February 2021
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•
Tribal organizations
•
Emergency response providers, including representatives of the fire service, law enforcement,
emergency medical services, and emergency managers
•
Public health officials and other appropriate medical practitioners
•
Hospitals
•
Individuals representing educational institutions, including elementary schools, middle schools,
junior high schools, high schools, community colleges, and other institutions of higher education
•
State and regional interoperable communications coordinators, as appropriate
•
State and major urban area fusion centers, as appropriate
•
Nonprofit, faith-based, and other voluntary organizations, such as the American Red Cross
Additionally, program representatives from the following entities should be members of the SAC (as
applicable): State Primary Care Association, State Homeland Security Advisor (HSA) (if this role is not
also the SAA), State Emergency Management Agency (EMA) Director, State Public Health Officer, State
Awardee for HHS’ Hospital Preparedness Program, State Public Safety Officer (and SAA for Justice
Assistance Grants, if different), State Coordinator for the DoD 1033 Program (also known as the Law
Enforcement Support Office [LESO] Program), State Court Official, State Emergency Medical Services
(EMS) Director, State Trauma System Manager, Statewide Interoperability Coordinator, State Citizen
Corps Whole Community Council, the State Emergency Medical Services for Children (EMSC)
Coordinator, State Education Department, State Human Services Department, State Child Welfare
Services, State Juvenile Justice Services, Urban Area POC, Senior Members of AMSCs, Senior Members
of the RTSWG, Senior Security Officials from Major Transportation Systems, and the Adjutant General.
SACs are encouraged to develop subcommittee structures, as necessary, to address the issue or region-
specific considerations. The SAC must include whole community intrastate and interstate partners as
applicable and have balanced representation among entities with operational responsibilities for
terrorism/disaster prevention, protection, mitigation, response, and recovery activities within the state, and
include representation from the stakeholder groups and disciplines identified above.
The above membership requirement does not prohibit states, urban areas, regional transit and port entities,
or other recipients of FEMA preparedness funding from retaining their existing structure under separate
programs; however, at a minimum, those bodies must support and feed into the larger SAC. The
composition, structure, and charter of the SAC should reflect this focus on building core capabilities,
instead of simply joining previously existing advisory bodies under other grant programs. For designated
high-risk urban areas, the SAA Point of Contacts (POCs) are responsible for identifying and coordinating
with the POC for the UAWG, which should be a member of the SAC. The POC’s contact information
must be provided to FEMA with the grant application. SAAs must work with existing urban areas to
ensure that information for current POCs is on file with FEMA.
Finally, FEMA recommends that organizations advocating on behalf of youth, older adults, individuals
with disabilities, individuals with limited English proficiency and others with access and functional needs,
socio-economic factors and cultural diversity be invited to participate in the SAC. Applicants must submit
the list of SAC members and the SAC charter at the time of application as an attachment in ND Grants.
SAAs will use the URT to verify compliance with SAC charter requirements.
SAC Responsibilities
The responsibilities of a SAC include:
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•
Integrating preparedness activities across disciplines, the private sector, nonprofit, faith-based,
and community organizations, and SLTT governments, with the goal of maximizing coordination
and reducing duplication of effort;
•
Creating a cohesive planning network that builds and implements preparedness initiatives using
FEMA resources, as well as other federal, SLTT, private sector, and faith-based community
resources;
•
Management of all available preparedness funding sources to ensure their effective use and to
minimize duplication of effort;
•
Ensuring investments support closing capability gaps or sustaining capabilities identified in the
THIRA/SPR;
•
Assist in preparation and revision of the state, regional, or local homeland security plan or the
threat and hazard identification and risk assessment, as the case may be; and
•
Assist in determining effective funding priorities for SHSP grants.
SAC Charter
The governance of the SHSP and UASI programs through the SAC should be directed by a charter. All
members of the SAC should sign and date the charter showing their agreement with its content and their
representation on the Committee. Revisions to the governing charter must be sent to the recipient’s
assigned FEMA HQ Preparedness Officer. The SAC charter must at a minimum address the following:
•
A detailed description of the SAC’s composition and an explanation of key governance processes,
including how the SAC is informed by the state’s and urban area’s THIRA/SPR;
•
A description of the frequency at which the SAC will meet;
•
How the committee will leverage existing governance bodies;
•
A detailed description of how decisions on programmatic priorities funded by SHSP and UASI
are made and how those decisions will be documented and shared with its members and other
stakeholders, as appropriate; and
•
A description of defined roles and responsibilities for financial decision making and meeting
administrative requirements.
To ensure ongoing coordination efforts, SAAs are encouraged to share community preparedness
information submitted in a state’s BSIR with members of the SAC. SAAs are also encouraged to share
their THIRA/SPR data with members of the SAC who are applying for other FEMA preparedness grants
to enhance their understanding of statewide capability gaps. The charter should be made available upon
request to promote transparency in decision-making related to SHSP and UASI activities.
To manage this effort and to further reinforce collaboration and coordination across the stakeholder
community, a portion of the 20% holdback of a state or territory award may be utilized by the SAA to
support the SAC and to ensure representation and active participation of SAC members. Funding may be
used for hiring and training planners, establishing and maintaining a program management structure,
identifying and managing projects, conducting research necessary to inform the planning process, and
developing plans that bridge mechanisms, documents, protocols, and procedures.
Urban Area Working Group (UAWG)
UASI program implementation and governance must include regional partners and should have balanced
representation among entities with operational responsibilities for prevention, protection, mitigation,
response, and recovery activities within the region. In some instances, high-risk urban area boundaries
cross state borders. States must ensure that the identified urban areas take an inclusive regional approach
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to the development and implementation of the UASI program and involve the contiguous jurisdictions,
mutual aid partners, port authorities, rail and transit authorities, state agencies, Statewide Interoperability
Coordinators, Citizen Corps Whole Community Council(s), and campus law enforcement in their
program activities.
UAWG Composition and Scope
Pursuant to section 2003(b) of the Homeland Security Act of 2002 (codified as amended at 6 U.S.C. §
604(b)), eligible high-risk urban areas were determined based on an analysis of relative risk of the 100
most populous Metropolitan Statistical Areas (MSAs), as defined by the Office of Management and
Budget (OMB). MSAs are used by FEMA to determine eligibility for participation in the program.
Geographical areas queried do not equate to minimum mandated membership representation of an urban
area, nor does this guarantee funding for geographical areas queried. UAWGs are not required to expand
or contract existing urban area participation to conform to MSA composition. Detailed information on
MSAs is publicly available from the United States Census Bureau at https://www.census.gov/programs-
surveys/metro-micro.html.
An SAA must confirm a specific POC with the designated high-risk urban area. The SAA POC is
responsible for identifying and coordinating with the POC for the UAWG. This information must be
provided to FEMA with the grant application. SAAs must work with existing high-risk urban areas to
ensure that information for current POCs is on file with FEMA.
Membership in the UAWG must provide either direct or indirect representation for all relevant
jurisdictions and response disciplines (including law enforcement, fire service, EMS, hospitals, public
health, and emergency management) that comprise the defined high-risk urban area. It must also be
inclusive of local Whole Community Citizen Corps Council and tribal representatives. The UAWG
should also include at least one representative from each of the following significant stakeholders:
•
Local or tribal government officials
•
CIO and CISO
•
Emergency response providers, which shall include representatives of the fire service, law
enforcement, emergency medical services, and emergency managers
•
Public health officials and other appropriate medical practitioners, including Health Care
Coalitions (HCCs)
•
Individuals representing educational institutions, including elementary schools, middle schools,
junior high schools, high schools, community colleges, and other institutions of higher education
•
State and regional interoperable communications coordinators, as appropriate state and major
urban area fusion centers, as appropriate
In addition to representatives from the local jurisdictions and tribes within the state or high-risk urban
area, the UAWG should include officials responsible for the administration of Centers for Disease
Control and Prevention’s (CDC) and the HHS Assistant Secretary for Preparedness and Response’s
(ASPR) cooperative agreements. Finally, it must be inclusive of members advocating on behalf of youth,
older adults, individuals with disabilities, individuals with limited English proficiency and others with
access and functional needs, socio-economic factors, and cultural diversity.
High-risk urban areas will use the URT to verify UAWG structure and membership. The list of UAWG
members must also be submitted at the time of application as an attachment in ND Grants. High-risk
urban areas must notify the SAA and the FEMA Headquarters Preparedness Officer of any updates to the
UAWG structure or membership after the application is submitted.
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UAWG Responsibilities
UAWGs must ensure that applications for funding under the UASI program support closing capability
gaps or sustaining capabilities identified in the high-risk urban area’s THIRA/SPR. The UAWG should
support state efforts to develop the SPR, particularly as it relates to UASI-funded activities. The UAWG,
in coordination with the SAA POC, must develop a methodology for allocating funding available through
the UASI program. The UAWG must reach consensus on all UASI funding allocations. If consensus
cannot be reached within the 45-day period allotted for the state to obligate funds to subrecipients, the
SAA must make the allocation determination. The SAA must provide written documentation verifying
the consensus of the UAWG or the failure to achieve otherwise on the allocation of funds and submit it to
FEMA immediately after the 45-day period allotted for the state to obligate funds to subrecipients. Any
UASI funds retained by the state must be used in direct support of the high-risk urban area. States must
provide documentation to the UAWG, and FEMA upon request, demonstrating how any UASI funds
retained by a state are directly supporting the high-risk urban area.
UAWG Charter
In keeping with sound project management practices, the UAWG must ensure that its approach to critical
issues such as membership, governance structure, voting rights, grant management and administration
responsibilities, and funding allocation methodologies are formalized in a working group charter or
another form of standard operating procedure related to the UASI program governance. The charter must
also outline how decisions made in UAWG meetings will be documented and shared with UAWG
members. The UAWG charter must be submitted at the time of application as an attachment in ND Grants
and must be on file with FEMA prior to drawing down UASI funding. It also must be available to all
UAWG members to promote transparency in decision making related to the UASI program.
Supplemental SHSP and UASI Guidance
Collaboration
Collaboration with Other Federal Preparedness Programs
FEMA strongly encourages states, high-risk urban areas, tribes, and territories to understand other federal
preparedness programs in their jurisdictions and to work with them in a collaborative manner to leverage
all available resources and avoid duplicative activities. For example, HHS has two robust preparedness
programs—CDC’s Public Health Emergency Preparedness (PHEP) cooperative agreement and ASPR’s
Hospital Preparedness Program (HPP) cooperative agreement—that focus on preparedness capabilities.
CDC’s 15 public health preparedness capabilities and ASPR’s 4 healthcare preparedness capabilities
serve as operational components for many of the core capabilities, and collaboration with the PHEP
directors and HPP coordinators can build capacity around shared interests and investments that fall in the
scope of these HHS cooperative agreements and the HSGP.
States and urban areas should coordinate among the entire scope of federal partners, national initiatives,
and grant programs to identify opportunities to leverage resources when implementing their preparedness
programs. These may include but are not limited to: Medical Reserve Corps; Emergency Medical
Services for Children grants; ASPR HPP; CDC PHEP; CDC Cities Readiness Initiative; Strategic
National Stockpile Programs; EMS; DOJ grants; the Department of Defense 1033 Program (also known
as the LESO Program); and the Resilience Directorate/Office of Infrastructure Protection’s (OIP)
Regional Resilience Assessment Program (RRAP). However, coordination is not limited to grant funding.
It also includes leveraging assessments such a Transportation Security Agency’s (TSA) Baseline
Assessment for Security Enhancement (BASE), reporting from the Intelligence Community, risk
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information such as USCG’s Maritime Security Risk Analysis Model (MSRAM), and USBP Sector
Analysis.
Each SHSP- and UASI-funded investment that addresses biological risk, patient care, or health systems
preparedness should be implemented in a coordinated manner with other federal programs that support
biological and public health incident preparedness such as those administered by HHS ASPR, CDC, and
DOT’s National Highway Traffic Safety Administration (NHTSA).
Collaboration with Health Care Coalitions (HCCs)
HCCs are regional entities comprised of health care, public health, emergency management, and
emergency medical services organizations that plan and respond together, leverage resources, and address
challenges in health care delivery brought on by public health and medical incidents. Given that many of
the risks being mitigated include the potential for a range of mass casualties, including those across the
chemical, biological, radiological, nuclear, explosive (CBRNE) spectrum, planning efforts should include
the participation of HCCs and should take into account the elements and capabilities articulated in the
2017-2022 Health Care Preparedness and Response Capabilities
(https://www.phe.gov/Preparedness/planning/hpp/reports/Documents/2017-2022-healthcare-pr-
capablities.pdf ).
Collaboration with Nonprofit Organizations
SHSP and UASI recipients are encouraged to work with the nonprofit community to address terrorism
and all-hazards prevention concerns, seek input on the needs of the nonprofit sector, and support the goals
of their investments.
Collaboration with Tribes
FEMA strongly encourages states, high-risk urban areas, and territories to work with tribal nations in
overall initiatives such as whole community preparedness and emergency management planning.
Whole Community Preparedness
SHSP and UASI recipients should engage with the whole community to advance community and
individual preparedness and to work as a nation to build and sustain resilience. Recipients should consider
the three goals of the 2018-2022 FEMA Strategic Plan in their program design and delivery, specifically
Strategic Goal 1: Build a Culture of Preparedness, and Strategic Goal 2: Ready the Nation for
Catastrophic Disasters. Recipients should integrate program design and delivery practices that ensure
representation and services for under-represented diverse populations that may be more impacted by
disasters including children, seniors, individuals with disabilities or access and functional needs,
individuals with diverse culture and language use, individuals with lower economic capacity, and other
underserved populations. Individual preparedness must be coordinated by an integrated body of
government and nongovernmental representatives as well, including but not limited to, elected officials,
the private sector (especially privately owned critical infrastructure), private nonprofits, nongovernmental
organizations (including faith-based, community-based, and voluntary organizations), advocacy groups
for under-represented diverse populations that may be more impacted by disasters including children,
seniors, individuals with disabilities or access and functional needs, individuals with diverse culture and
language use, individuals with lower economic capacity, and other underserved populations.
In addition to Community Emergency Response Team (CERT) programs, the following preparedness
programs are allowable expenses:
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•
Financial Preparedness Activities that encourage and assist Americans in preparing for the true
cost of disasters. Allowable activities include encouraging emergency savings, promoting home
and renter’s insurance, and promoting flood insurance for individuals and families. Partnerships
with local financial wellness organizations such as credit unions, financial counselors, community
banks, and others that reach a variety of audiences are encouraged.
•
Preparedness of Community-Based Organizations that serve as a critical safety net for
Americans disproportionately impacted by disasters. Examples of community-based
organizations include but are not limited to food banks, food pantries, homeless shelters, school
readiness and after school centers, adult day care centers, job training centers, legal assistance
centers, and cultural centers. Allowable activities include Whole Community exercises, trainings,
and activities focused on staff preparedness, information sharing with clients and government,
and continuity of essential functions in the event of an emergency.
•
Youth Preparedness Resources are available on www.ready.gov/kids. Bolstering youth
preparedness across the nation is a priority for FEMA as the Agency works with state, local,
tribal, and territorial partners to create a culture of preparedness in the United States. Information
on youth-centric educational curricula, games, planning materials, and other relevant resources
can be found at www.ready.gov/kids. Furthermore, FEMA’s Individual and Community
Preparedness Division (ICPD) and regional-based Community Preparedness Officers (CPOs) are
available to provide grant recipients with guidance and assistance. Please email FEMA-
Prepare@fema.dhs.gov to contact one of the Agency’s subject matter experts.
The following are examples of youth preparedness activities that grantees are encouraged to
undertake as allowable costs:
o Reach out to a local school board or elementary school to encourage the adoption of the
Student Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based
emergency preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach
format. Students will learn about disasters, emergencies, and hazards, and how to create a
disaster supply kit and family emergency communication plan. An overview of the STEP
program along with the instructor guide and student activity book is available at
https://www.ready.gov/student-tools-emergency-planning-step.
o Sponsor the creation of a Teen Community Emergency Response Team (CERT) in your
jurisdiction. The CERT Program is a national program of volunteers trained in disaster
preparedness and emergency response. Volunteers come from all ages and all walks of
life, including teenagers. Additional information, including a step-by-step guide on how
to start a Teen CERT, is available at https://www.ready.gov/teen-cert.
The following tools are available to order from FEMA’s warehouse free of charge:
o “Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The
“Prepare with Pedro: Disaster Preparedness Activity Book” is designed to teach young
children and their families about how to stay safe during disasters and emergencies. The
book follows Pedro around the United States and offers safety advice through
crosswords, coloring pages, matching games, and more. Additional information,
including an ordering form, is available at https://www.ready.gov/prepare-pedro.
o The Ready 2 Help card game is a fun way for kids to learn how to respond to
emergencies by working with friends and using skills that will help in a real emergency.
Ready 2 Help teaches five simple steps to stay safe and make a difference until help
arrives:
•
Stay Safe
•
Stay Calm
•
Get Help
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•
Give Info
•
Give Care
Ready 2 Help is designed for children ages 8 and up. Additional information, including
an ordering form, is available at https://www.ready.gov/ready-2-help.
Supplemental OPSG Program Guidance
OPSG supports enhanced cooperation and coordination among CBP, USBP, and federal and SLTT law
enforcement agencies to improve overall border security. OPSG provides funding to support joint efforts
to secure the United States’ borders along routes of ingress/egress to and from international borders to
include travel corridors in states bordering Mexico and Canada, as well as states and territories with
international water borders. OPSG also further enhances the sharing of threat information and intelligence
between federal, state, local, tribal, and territorial law enforcement agencies through the development and
sustainment of a capable workforce of analysts that have the necessary experience and training, access to
open source, unclassified and classified information, products, data, suspicious activity reporting,
tips/leads, and online/social media-based threats, as well as necessary services and technology to facilitate
analytic capabilities and collaboration.
SLTT law enforcement agencies will utilize their own law enforcement authorities to support the CBP
and USBP border security mission and will not receive any additional authority as a result of participation
in the grant. An OPSG award does not provide any additional authority to SLTT law enforcement
agencies. More specifically, SLTT law enforcement agencies are not empowered through OPSG to
enforce immigration authorities under Title 8 of the U.S. Code (i.e., the Immigration and Nationality Act).
SLTT law enforcement agencies are expected utilize their own jurisdictional authority in support of
enhanced border security unless some other agreement applies. SLTT law enforcement agencies are
further expected to operate within the bounds of all applicable laws, to include federal laws, state statutes,
and local laws, policies, and procedures.
OPSG is intended to support border states and territories of the United States in accomplishing the
following objectives:
•
Increase intelligence and operational capabilities to prevent, protect against, and respond to
border security issues
•
Increase coordination and collaboration among federal and SLTT law enforcement agencies
•
Continue the distinct capability enhancements required for border security and border protection
•
Provide intelligence-based operations through USBP Sector Level experts to ensure safety and
operational oversight of federal and SLTT law enforcement agencies participating in OPSG
operational activities
•
Support a request to any Governor to activate, deploy, or redeploy specialized National Guard
Units/Packages and/or elements of state law enforcement to increase or augment
specialized/technical law enforcement elements operational activities
•
Continue to increase operational, material, and technological readiness of SLTT law enforcement
agencies
•
Enhance the sharing of threat information and intelligence between federal and SLTT law
enforcement agencies
•
Develop and sustain a capable workforce of analysts that have the necessary experience and
training, as well as access to open source, unclassified, and/or classified information, products,
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data, suspicious activity reporting, tips/leads, and online/social media-based threats, and the
necessary services and technology to facilitate these analytic activities
OPSG funds must be used to provide an enhanced law enforcement presence and to increase operational
and intelligence capabilities of federal and SLTT law enforcement, promoting a layered, coordinated
approach to law enforcement within border states and territories of the United States.
•
Federal and SLTT OPSG Integrated Planning Team (IPT). Federal and SLTT partners must
establish and maintain a formalized OPSG IPT with representation from all participating law
enforcement agencies, co-chaired by representatives from USBP, the SAA, and participating law
enforcement agencies’ OPSG program representatives.
•
No fewer than two IPT meetings must take place during every funding year:
o Prior to submitting the Concept of Operations (application)
o Prior to submitting the Campaign Plan
•
OPSG funds may be used for travel and per diem in support of the IPTs and OPSG strategic
planning events as long as the costs are otherwise compliant with other program and regulatory
requirements.
Coordination Requirements
All operational plans should be crafted in cooperation and coordination among federal and SLTT
partners. Consideration will be given to applications that are coordinated across multiple jurisdictions. All
applicants must coordinate with the USBP Sector Headquarters with geographic responsibility for the
applicant’s location in developing and submitting an Operations Order with an embedded budget to the
SAA. OPSG funds must be used to provide increased operational capabilities to SLTT partners in support
of enhanced border security through:
•
Enhanced Law Enforcement Presence
•
Enhanced Situational Awareness
•
Enhanced Intelligence Collection and Distribution
After awards are announced, prospective recipients will re-scope the draft Operations Order and resubmit
it as a final Operations Order with an embedded budget based on actual dollar amounts awarded. The
appropriate Sector Headquarters will approve final Operations Orders and forward those orders to
Headquarters, Office of Border Patrol, Washington, DC, before funding is released. Recipients may not
begin operations, obligate, or expend any funds until FEMA and USBP Headquarters have approved the
final Operations Order and the embedded budget and removed any existing special conditions and/or
restrictions.
Transportation Costs and Costs Related to the Provision of Acute Medical Care
Please see IB 438 for information on transportation costs and costs related to the provision of acute
medical care under an OPSG award.
OPSG Operations Order Template and Instructions
Operations Order Template Instructions
To access the OPSG Operations Order Template:
•
Find the Homeland Security Grant Program posting via the search function on Grants.gov
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•
Select the Related Documents tab on the posting
•
Click on the OPSG Operations Order Template and fill out all sections of the template
Executive Summary Overview
Operations Order Executive Summary
Operations Order Executive Summary must:
•
Identify the organization name, point of contact, committees, and other structures accountable for
implementing OPSG in the jurisdiction (typically this will be a program lead or manager
overseeing operations and individuals assigned to that agency).
•
Describe how federal and SLTT law enforcement agencies will work together to establish and
enhance coordination and collaboration on border security issues.
Budget Requirements Overview
Operations Order Detailed Annual Budget must:
•
Explain how costs and expenses were estimated.
•
Provide a narrative justification for costs and expenses. Supporting tables describing cost and
expense elements (e.g., equipment, fuel, vehicle maintenance costs) may be included.
Submission Requirements
Operations Orders must meet the following submission requirements:
•
Must be submitted as an Adobe PDF document.
•
All documents submitted must use the unique identifier created by the OPSG data management
system from the original associated operation order.
•
Applicable OPSG sector representatives must coordinate with the SAA and OPSG participants to
submit an accurate inventory of all specified OPSG purchased property with each Operations
Order/FRAGO.
Due to the competitive nature of this program, separate attachments will neither be accepted nor
reviewed.
OPSG Operational Guidance
This section provides operational guidance to OPSG applicants on the development of a concept of
operations and campaign planning, the tactical operation period, and reporting procedures. This guidance
also delineates specific roles and responsibilities, expectations for operations, and performance measures.
Successful execution of these objectives will promote situational awareness among participating agencies
and ensure a rapid, fluid response to emerging border-security conditions.
OPSG uses an integrated approach to address transnational criminal activity. Federal and SLTT partners
are required to establish and maintain an OPSG IPT with representation from all participating law
enforcement agencies, co-chaired by representatives from USBP, the SAA, and participating local law
enforcement agencies’ OPSG program representatives. Each operational order will address specific
threats, gaps, and vulnerabilities identified by the USBP. All requests in the operational plan will be
reviewed and approved by the corresponding sector's Chief Patrol Agent or his/her designee for border
security value. USBP will provide routine monitoring and technical expertise to each participating
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agency. The content of each operational plan, to include the requested items will be reviewed for border-
security value and approved by the corresponding sector’s Chief Patrol Agent or his/her designee.
All operational plans should be crafted in cooperation and coordination with federal and SLTT partners to
meet the needs of the USBP Sector. Consideration will be given to applications that are coordinated
across multiple jurisdictions. All applicants must coordinate with the CBP/USBP Sector Headquarters
with geographic responsibility for the applicant’s location in developing and submitting an Operations
Order with an embedded budget to the SAA. Operations are to be crafted so that resources are allocated to
one or more of the supportable categories:
1) Law Enforcement Presence
2) Situational Awareness
3) Intelligence Collection, Analysis, and Distribution
Law Enforcement Presence includes activities and costs associated to having an SLTT partner provide a
law enforcement patrol presence in an area designated by the USBP Sector in support of border security
efforts. Situational Awareness includes technology to provide current and immediately relevant
information about currently active border security threats. Intelligence Collection and Distribution
includes both technology and manpower related to the gathering and analysis of intelligence with a nexus
to border security.
The terms of an OPSG award do not extend to an SLTT partner any authority to enforce additional laws,
statues, or regulations beyond their own authorities; SLTT partners are not empowered through OPSG to
enforce immigration authorities under Title 8 of the U.S. Code (i.e., the INA). Participation in the grant
does not grant participants the power to operate outside of their own jurisdictional boundaries.
Concept of Operations and Campaign Planning
Post-Allocation Announcement/Pre-Award
The overarching operational cycle involves three stages: 1) application; and 2) concept of operations to
formulate a Campaign Plan, which are all developed by the IPT. All Operations Orders: Concept of
Operations (CONOPS), Operation Orders (OO) or Campaign Plans and FRAGOs shall be submitted
through the CBP Stonegarden Data Management System. All OPSG grant Application packages shall be
submitted to the SAA for entry into Grants.gov.
Application: Please refer to the current fiscal year’s HSGP NOFO and relevant information in this
Manual.
Campaign Plan: After awards are announced, participants will create and submit an operations order that
forms a campaign plan and captures the initial, generalized-budgetary intent to their IPT.
The campaign plan should articulate the participant agency’s long-term border security objectives and
goals designed to mitigate border-security risk.
Funds should be obligated as needed to target specific threats or vulnerabilities and ensure that OPSG
usage is commensurate to the unique risk of each border region. This may require several short-term
operations that combine to form an ongoing operational cycle, ensuring that USBP commanders and
SLTT agency partners reserve the flexibility to respond to the ever-changing elements of border security.
The operations plan also will articulate the budgetary intent of how funds are to be used throughout the
performance period. The operations plan will project planned expenditures in the following categories:
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overtime, equipment, travel, maintenance, fuel, and administrative funds. The subrecipient can initiate the
procurement of equipment as well as state how much the county intends to use for M&A while keeping
funds for overtime or residual equipment funds available for use as needed. If the subrecipient intends to
spend more than 50% of its award on overtime over the course of the performance period, a PRICE Act
waiver request must be submitted in accordance with the policy initially outlined in IB 379: Guidance to
State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding. The
operations plan will meet both the SAA expectations to obligate the funds within 45 days of the award
announcement and the demands of the grant’s operational intent. Sector approved campaign plans must
be submitted to USBP Headquarters no later than four months after the official awards
announcement has been made.
Investment Modifications - Changes in Scope or Objective: Changes in scope or objective of the
award – including those resulting from intended actions by the recipient or subrecipients – require
FEMA’s prior written approval, in accordance with 2 C.F.R. §§ 200.308(c)(1), 200.407.
In the event that changes must be made to the original operational plan, such as additional funding
requests or other changes to the original scope or objectives, a FRAGO must be submitted in HSIN to
obtain FEMA’s prior written approval of such changes in accordance with 2 C.F.R. § 200.308(c)(1).
These modifications will be annotated in the annex section of the FRAGO.
Operational Execution
In the event that changes or additional funding requests to the original operational order must be made, a
FRAGO will be created. These modifications will be annotated in the annex section of the FRAGO.
Operational discipline is necessary for the success of OPSG. Deliberate, adaptive, integrated, and
intelligence-driven planning is critical to conducting targeted enforcement operations consistent with the
objectives of the OPSG. By participating in the OPSG, the state, local, tribal, and territorial agencies
agree to conduct operations designed to reduce border-security risk.
Operations are composed of six critical elements: 1) a pre-planning meeting with the IPT; 2) specified
beginning and ending dates; 3) the integration of intelligence and border security; 4) use of targeted
enforcement techniques; 5) clearly stated objectives; and 6) an after-action meeting. These operations
require deliberate on-going planning to ensure command, staff, and unit activities synchronize to current
and future operations. The cyclical nature of the process will ensure OPSG activities align with the
fluctuating border-security threats and vulnerabilities. The IPT should leverage information provided by
the fusion center, Border Intelligence Centers or other local intelligence center, when possible, and
establish a common operational vision.
The USBP Sector’s Chief Patrol Agent, or his/her designee, will ensure that the information or
intelligence has a clear nexus to border security. Intelligence will be shared and vetted for border security
value, driving the focus of operations. Once intelligence-driven targets are identified, the IPT will decide
on operational objectives that reflect the intended impact of operations. The objectives should outline how
the operation will deter, deny, degrade, or dismantle the operational capacity of the targeted transnational
criminal organizations.
Each operational period will begin on a predetermined date and end on a predetermined date, but the dates
may be subject to change commensurate with emerging security conditions. The starting date of the
operational period should be established to allow sufficient time for the order to be submitted and
approved by the corresponding USBP Sector and in concurrence with its SAA and USBP Headquarters.
The USBP Sectors will upload copies of operations order in the corresponding folder in the CBP
Stonegarden Data Management System.
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Reporting Procedures
Participation in OPSG requires accurate, consistent, and timely reporting of how funds are used, and how
the state, local and tribal agencies’ operations have impacted border security through the mitigation of
threat or vulnerability and the overall reduction of risk. Reporting will focus on monitoring program
performance; determining the level of integration and information sharing; and developing best practices
for future operations. To ensure consistent reporting each state, local, and tribal agency will identify a
single point of contact to represent their agency as a member of the IPT and to coordinate the submission
of reports or execute other aspects of the grant.
The Daily Activity Report (DAR), which can be found by selecting the link for the current fiscal year
HSGP NOFO on FEMA’s preparedness grants page (https://www.fema.gov/homeland-security-grant-
program) to be used to submit the ongoing results and outputs from OPSG operations conducted. The
information and statistics included in the DAR will be delineated by agency (friendly forces). The DAR
must be submitted to the USBP sector or the participating agency’s OPSG coordinator within 48 hours
of the conclusion of each OPSG shift. Subrecipients and Sectors are responsible to ensure that DARs are
submitted in the proper format and in a timely manner. DARs will be submitted using the CBP
Stonegarden Data Management System. Friendly Forces receiving funding through a subrecipient will
submit DARs within 48 hours. Border Patrol Sectors and OPSG subrecipients will implement internal
protocols to ensure operational data from subrecipients and friendly force DARs are properly collected
following the established guidelines.
In addition to the ongoing reporting of outputs, subrecipient participants will be required to submit AARs
to USBP sectors within 10 days of closing the operational POP for that funding year. The AAR should
carefully articulate outcomes and outputs as well as how the results of the operation compare with the
objectives identified during the pre-planning meeting. Failure to submit the AAR in a timely manner may
prevent the approval of future operations requests. All AARs and other OPSG reporting requirements will
be submitted through the CBP Stonegarden Data Management System. Sectors are responsible for
submitting AARs into Border Patrol Enforcement Tracking System (BPETS) as applicable.
Operational Roles and Responsibilities
To achieve unity of effort, it is essential that each participant know the roles and responsibilities within
the IPT. The USBP sector’s Chief Patrol Agent, or his/her designee, will:
•
Coordinate and chair the area IPT’s meetings
•
Coordinate with all interested and eligible SLTT agencies in the sector’s area of operation during
the open period of the OPSG application process by:
o Assisting applicants in completing the operations planning portion of the application,
which is like the Operations Order used by the USBP
o Forwarding the approved operation portion of the application to CBP/USBP
Headquarters as well as to the SAA to complete the application process set by FEMA
o Detailing what operational support the USBP Sector anticipates for specific periods and
matching the capabilities of partners to fill those gaps
•
Following the announcement of grant awards, coordinate and chair a meeting with SLTT
agencies that received OPSG awards to develop an individualized campaign plan. This includes:
o Working with SLTT agencies, along with other federal law enforcement agencies to
determine the dates, focus, and needs of each operational period, ensuring that each
operation has a nexus to border security
o Receiving the first periodic operations order from the SLTT agencies and ensuring that
the operation is conducted as outlined in the Campaign Planning section
o Monitoring and supporting the Operational Cycle throughout the performance period
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o Ensuring the DAR and the AAR are submitted by state, local, and tribal agencies in the
proper format and within the established timeframes
o Providing instruction, when possible, to state, local, and tribal agencies regarding
techniques, methods, and trends used by transnational criminal organizations in the area
o Providing a single point of contact to participants as a subject-matter expert in OPSG that
can coordinate, collect, and report operational activities within the established reporting
procedures
o Providing verification that operations are conducted
o Documenting and conducting random, on-site operational verification of OPSG patrols
by subrecipients and friendly forces
o Verifying that subrecipients are performing OPSG enforcement duties in accordance with
the applicable grant, statute, and regulatory guidance and instructions
o Ensuring that grant funds are appropriately expended to meet sector border enforcement
operational requirements and assist in enhancing subrecipient/friendly force capabilities
to provide for enhanced enforcement presence, operational integration, and intelligence
sharing in border communities.
The state, local or tribal agency lead, or their designee, will:
•
Coordinate with the SAA on all grant management matters including but not limited to the
development and review of operations orders, expenditure of funds, allowable costs, reporting
requirements;
•
Upon receiving a grant award, coordinate and meet as a member of the IPT to develop an
individualized campaign plan that covers the length of the grant performance period;
•
Work within the IPT to develop an initial Operational Cycle and determine the duration of the
first operational period based on the tactical needs specific to the area;
•
Submit all operations orders for review and submit the operations order to the Border Patrol and
ensure the operation meets the six criteria established in the Operations Section;
o Conduct operations on an as-needed basis throughout the length of the grant performance
period;
o Integrate law enforcement partners from contiguous counties and towns into their tactical
operations to expand the layer of security beyond existing areas;
o Ensure all required reports, including reports from friendly forces, are submitted to the
Border Patrol and the SAA, when applicable, in the proper format and within established
timeframes;
o Ensure applicable OPSG-derived data is shared with the designated fusion center in the
state or high-risk urban areas;
o Ensure applicable intelligence is shared with the designated fusion center in the state
and/or urban areas;
o Request instruction and information from the SAA, when applicable, and/or USBP and
other federal law enforcement agencies regarding techniques, methods, and trends used
by transnational criminal organizations in the area;
o Provide the SAA and USBP a single point of contact that maintains subject-matter
expertise in OPSG who can coordinate, collect, and report operational activities within
the established reporting procedures; and
o Assist as required with the coordination, management, and operational aspects of the
grant.
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The SAA will:
•
Actively engage in the IPT meetings;
•
Work in direct coordination and communication with the local or tribal agency lead on all grant
management matters;
•
Review all operations orders created by the local or tribal agency;
•
Acts as the fiduciary agent for the program and provide expertise in state policy and regulations;
•
Enter into a subaward agreement to disburse the allocated funding awarded through FEMA;
•
Generate biannual reports to FEMA capturing the subrecipients’ obligations and expenditures of
funds;
•
Determine if the grant’s performance period requires additional refinement over the federally
established 36-month period; and
•
Conduct audits of the program to ensure that the subrecipients are following program guidance.
•
Assist as required with the coordination, management, and operational aspects of the grant.
Definitions (OPSG only)
Area of Interest: A specific area, areas, or facilities known to be used by transnational criminal
organizations in furtherance of their criminal activity.
Border-security related crime: Any action or enterprise that constitutes an offense which is punishable by
law:
•
That results in a favorable environment for criminal enterprise network, transnational criminal, or
terrorist organizations; the smuggling/trafficking of humans, contraband, narcotics, or weapons of
mass destruction across or in proximity to the U.S. border or;
•
That has a direct nexus to illicit cross-border activity; and
•
For which prosecution would serve established border security goals as outlined by the CBP for a
whole of community approach.
Campaign Plan: The first Operational Order based on the CONOP aimed at accomplishing a strategic or
operational objective within a given time and space.
Concept of Operations (CONOP): A written statement that clearly and concisely expresses what the
State, local, or tribal commander intends to accomplish and how it will be done using available resources
(and funding). It is also the operational equivalent of the OPSG grant application.
Fragmentary Order (FRAGO): A fragmentary order is a modification of the approved campaign plan,
reflecting changes to the scope or objective pursuant to 2 C.F.R. § 200.308(c)(1). After an operation order
has been approved, any changes to a campaign plan will be submitted via HSIN as a FRAGO for FEMA’s
approval. Subsequent FRAGOs are permissible, subject to FEMA’s prior written approval, consistent
with the requirements of 2 C.F.R. §§ 200.308, 200.407.
Friendly Forces: Local law enforcement entities with whom OPSG subrecipients provide funding to
support border security operations.
Integrated Planning Team (IPT): Group that coordinates on all aspects of OPSG application, planning,
and de-briefings.
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Operational Cycle: A deliberate on-going cycle of command, staff, and unit activities intended to
synchronize current and future operations (driven by current intelligence and short-term goals that
support the campaign).
Operational Discipline: The organized manner in which an organization plans, coordinates, and executes
the OPSG mission with common objectives toward a particular outcome.
Operation/Operational Order (OO): A formal description of the action to be taken to accomplish or
satisfy a CONOP, Campaign Plan, or FRAGO. The OO includes a detailed description of actions to be
taken and required logistical needs to execute an operation.
Opioid Receptor Antagonists: Any medically approved drug or medical substance that can be utilized by
first responder personnel in an emergency situation that is designed to counteract the effects of an opioid
overdose.
Performance Measure: A numerical expression that quantitatively conveys how well the organization is
doing against an associated performance goal, objective, or standard.
Risk: Potential for an adverse outcome assessed as a function of threats, vulnerabilities, and consequences
associated with an incident, event, or occurrence.
Targeted Enforcement: The leveraging of all available assets against a specific action, area, individual, or
organization and using those deemed most appropriate to mitigate risk.
Target of Interest: A specific person, group of persons, or conveyance known to be part of, or used by
transnational criminal organizations to advance their criminal activity.
Threat: Information expressing intent to conduct illegal activity often derived from intelligence sources,
the overall context, a specific event or series of events, or observation of suspicious activity.
Tier: Tier refers to the geographical location of a municipality, county, or tribe with respect to the United
States national border, i.e., Tier 1 is a county located on the border; a Tier 2 county is a county contiguous
to a Tier 1 county; and a. Tier 3 is a county not located on the physical border but is a contiguous to a Tier
2 county.
Unity of Effort: Coordination and cooperation among all organizational elements, even though they may
not be part of the same command structure, to achieve success.
Vulnerability: The protective measures in place are less than the protective measures needed to mitigate
risk.
HSGP Supplemental Material
FEMA collaborates with various subject-matter experts and acknowledges the value and expertise these
Federal partner agencies provide to help shape the development and implementation of the HSGP. This
continued partnership and collaboration helps provide recipients with the greatest number of resources
required to effectively manage and implement funds as well as promotes transparency. Therefore, FEMA
is providing hyperlinks to information on various subjects and policies that are relevant to the mission and
intent of the FEMA and its preparedness grant programs.
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Chemical, Biological, Radiological, and Nuclear (CBRN) Detection
The Countering Weapons of Mass Destruction (CWMD) Office is a support component within DHS
established in December 2017 to counter attempts by terrorists or other threat actors to carry out an attack
against the United States or its interests using a weapon of mass destruction. The CWMD Office provides
guidance to improve national coordination on CBRN issues and works with federal and SLTT agencies to
ensure operators have better access to current data and subject matter expertise they need. CWMD offers
THIRA Technical Assistance for CBRN threats to provide guidance to SLTT partners seeking to build or
sustain CBRN detection and response capabilities. For more information or assistance, please contact
CWMD-THIRA@hq.dhs.gov.
National Information Exchange Model (NIEM)
NIEM is a common vocabulary that enables efficient information exchange across diverse public and
private organizations. NIEM can save time and money by providing consistent, reusable data terms and
definitions and repeatable processes. To support information sharing, all recipients of grants for projects
implementing information exchange capabilities are required to use NIEM and to adhere to the NIEM
conformance rules. Go to https://niem.gov/ for guidance on how to utilize FEMA award funding for
information sharing, exchange, and interoperability activities.
The NIEM Emergency Management domain supports emergency-related services (including preparing
first responders and responding to disasters), information sharing, and activities such as homeland
security and resource and communications management. The NIEM Emergency Management domain has
an inclusive governance structure that includes federal, state, local, industry, and, where necessary,
international partnerships. The NIEM Emergency Management domain is committed to community
support via technical assistance and NIEM training. For more information on the NIEM Emergency
Management domain, to request training or technical assistance or to just get involved, go to
https://niem.gov/EM.
Integrated Public Alert and Warning System (IPAWS)
The current IPAWS Supplemental Guidance on Public Alert and Warning provides guidance on eligible
public alert and warning activities and equipment standards for prospective SLTT recipients. The intent of
this document is to promote consistency in policy across federal grant programs and to ensure
compatibility among federally-funded projects. For more information on the IPAWS, go to
https://www.fema.gov/informational-materials.
Homeland Security Information Network (HSIN)
HSIN is a user-driven, web-based, information sharing platform that connects all homeland security
professionals including the DHS and its federal, state, local, tribal, territorial, international, and private
sector partners across all homeland security mission areas. HSIN is used to support daily operations,
events, exercises, natural disasters, and incidents. To support user mission needs, HSIN provides three
sets of services for secure information sharing. The first service provides a shared place for communities
to securely collaborate on homeland security issues and includes core functions such as a web
conferencing and instant messaging tools with white boarding, video, and chat services for real-time
communication and situational awareness. The second set provides secure dissemination and sharing
capabilities for homeland security alerts, reports, and products. The third set allows users to access and
query a variety of shared data and services from all homeland security mission areas and trusted federal
partners. Preparedness grant funds may be used to support planning, training and development costs
associated with developing and managing, mission critical, HSIN communities of interest and sites. Learn
more about HSIN at http://www.dhs.gov/hsin-hsgp-guidance.
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SLTT Cybersecurity Engagement Program
CISA is responsible for enhancing the security, resilience, and reliability of the Nation’s cyber and
communications infrastructure. CISA works to prevent or minimize disruptions to critical information
infrastructure to protect the public, the economy, and government services. CISA leads efforts to protect
the Federal “.gov” domain of civilian government networks and to collaborate with the private sector—
the “.com” domain—to increase the security of critical networks.
The DHS SLTT Cybersecurity Engagement Program within CISA was established to help non-federal
public stakeholders and associations manage cyber risk. The program provides appointed and elected
SLTT government officials with cybersecurity risk briefings, information on available resources, and
partnership opportunities to help protect their citizens online. Through these and related activities, the
program coordinates DHS’s cybersecurity efforts with its SLTT partners to enhance and protect their
cyber interests. More information on all of the CISA resources available to support SLTT governments is
available at https://us-cert.cisa.gov/resources.
Regional Resiliency Assessment Program (RRAP)
The Regional Resiliency Assessment Program (RRAP) is a cooperative assessment of specific critical
infrastructure within a designated geographic area and a regional analysis of the surrounding
infrastructure that address a range of infrastructure resilience issues that could have regionally and
nationally significant consequences. These voluntary, non-regulatory RRAP projects are led by the
Infrastructure Security Division and are selected each year by DHS with input and guidance from federal,
state, and local partners. For additional information on the RRAP, visit https://www.cisa.gov/regional-
resiliency- assessment-program.
Law Enforcement Support Office (LESO), or 1033 Program
The LESO facilitates a law enforcement support program, which originated from the National Defense
Authorization Act of Fiscal Year 1997. This law allows the transfer of excess Department of Defense
property that might otherwise be destroyed by law enforcement agencies across the United States and its
territories.
No equipment is purchased for distribution. All items were excess that had been turned in by military
units or had been held as part of reserve stocks until no longer needed. Requisitions cover the gamut of
items used by America’s military ― clothing and office supplies, tools, and rescue equipment, vehicles,
small arms, and more. There is no fee for the equipment itself, however, the law enforcement agencies are
responsible for the shipping costs.
For additional information on the LESO, please visit
http://www.dla.mil/DispositionServices/Offers/Reutilization/LawEnforcement.aspx.
Supplemental Emergency Communications Guidance
Lessons learned from recent major disasters, unplanned events, and full-scale exercises have identified a
need for greater coordination of emergency communications among senior elected officials, emergency
management agencies, and first responders at all levels of government. Federal responders arriving on the
scene of a domestic incident are not always able to communicate with SLTT response agencies, as well as
key government officials. State and local first responders sometimes experience similar problems,
particularly when the incident requires a multi-agency, regional response effort or when primary
communications capabilities fail. This lack of operability and interoperability between federal and SLTT
agencies―further complicated by problems with communications survivability and resilience―has
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hindered the ability to share critical information, which can compromise the unity-of-effort required for
an effective incident response.
Departments and agencies at all levels of government have identified a need for improvement in a number
of high-priority areas, including: Governance, Planning, Training and Exercises, Operational
Coordination, and Technology. In addition, communications resilience and continuity should be viewed
as a critical component within each of these areas. These priorities are explained in detail in Section 2 of
the SAFECOM Guidance. By addressing these priorities, which are reflective of proven best practices,
emergency communications can be significantly improved at all levels of government. The end goal is to
ensure operable, interoperable, and resilient communications that maintain a continuous flow of critical
information, under all conditions, among multi-jurisdictional and multi-disciplinary emergency
responders, command posts, agencies, critical infrastructure sectors, and government officials for the
duration of an emergency response operation, and in accordance with NIMS and the National Emergency
Communications Plan, which describes goals and objectives for improving emergency communications
nationwide.
To help meet this goal, the SAFECOM Guidance outlines requirements for grant applications, including
alignment to national, regional, and state communications plans (e.g., NECP, Statewide Communications
Interoperability Plan (SCIP), Tactical Interoperability Communications Plan (TICP), FEMA Regional
Emergency Communications Plan (RECP)), project coordination, and technical standards for emergency
communications technologies. SCIPs define the current and future direction for interoperable and
emergency communications within a state or territory, while TICPs are designed to allow urban areas,
counties, regions, states/territories, tribes, or federal departments/agencies to document interoperable
communications governance structures, technology assets, and usage policies and procedures. In addition,
FEMA’s formal planning process has produced 10 RECPs and their associated state and/or
tribal/territorial annexes that identify emergency communications capability shortfalls and potential
resource requirements. Grant recipients are encouraged to leverage these planning resources as a source
of input and reference for all emergency communications grant applications and investment justifications.
In addition, FEMA formally recognizes several statewide emergency communications governance bodies
(e.g., SWIC, SIGB, Statewide Interoperability Executive Committee (SIEC), FirstNet State Single Point
of Contact (SPOC)), and strongly encourages grant recipients to closely coordinate with these entities
when developing an emergency communications investment to ensure projects support the state or
territory’s strategy to improve their communications capabilities with the goal of achieving fully operable,
interoperable, and resilient communications. In addition, grant applicants should work with public and
private entities, and across jurisdictions and disciplines, to demonstrate engagement with the Whole
Community in accordance with Presidential Policy Directive-8 (PPD-8).
For regional, cross-border initiatives, FEMA requires applicants to coordinate projects with national level
emergency communications coordination bodies, such as the National Council of Statewide
Interoperability Coordinators (NCSWIC) and the Regional Emergency Communications Coordination
Working Groups (RECCWGs). The NCSWIC promotes and coordinates state-level activities designed to
ensure the highest level of public safety communications across the nation. RECCWGs are
congressionally-mandated planning and coordination bodies located in each FEMA Region and provide a
collaborative forum to assess and address the survivability, sustainability, operability, and interoperability
of emergency communications systems at all levels of government. Grant-funded investments that are
coordinated with these bodies will help ensure that federally-funded emergency communications
investments are interoperable and support national policies.
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Resilient Communications Guidance
Nothing better demonstrates a modern nation than its ability to effectively communicate. The risk
imposed by the reliance on communication systems by government and the private sector can be reduced
by understanding dependencies, analyzing effects, and taking action. Entities planning to use HSGP
funding for communications investments are encouraged to work with state emergency management
agencies, SWICs, SIGBs, and appropriate stakeholders at the regional, state, local, territorial, and tribal
levels to:
•
Establish robust, resilient, reliable and interoperable communications capabilities. Account for
the mission impact of communication system disruptions in your planning;
•
Ensure mission-related communications (voice, video, data and network security requirements)
are adequately planned for and understood. It is important to maintain current documentation of
your communication systems architecture and perform regular audits. Your ability to continue
operations is dependent on the availability of and access to communications systems with
sufficient resiliency, redundancy, and accessibility to perform essential functions and provide
critical services during a disruption;
•
Ensure critical communication systems connectivity among key government leadership, internal
elements, other supporting organizations, and the public under all conditions. As such,
organizations should ensure current copies of vital records, including electronic files and
software, are backed-up and maintained off-site;
•
Ensure all communications systems/networks are traced from end to end to identify all Single
Points of Failure (SPF). In doing so, grantees should work with communication service providers
to add redundancy at key critical infrastructure facilities as needed;
•
Ensure key communication systems resiliency through:
o Ensuring availability of backup systems
o Ensuring diversity of network element components and routing
o Ensuring geographic separation of primary and alternate transmission media
o Ensuring availability of back-up power sources
o Ensuring availability and access to systems that are not dependent on commercial
infrastructure
o Maintain spares for designated critical communication systems
o Work with commercial suppliers to remediate communication Single Points of Failure
•
All communications system owners are encouraged to address the following issues:
o Integrate communications needs into continuity planning efforts by incorporating
mitigation options to ensure uninterrupted communications support
o Establish a cybersecurity plan that includes continuity of a communications component
such as Radio Frequency (RF)-based communications that do not rely on public
infrastructure
o Maintain communications capabilities to ensure their readiness when needed
o Frequently train and exercise personnel required to operate communications capabilities
o Test and exercise communications capabilities
o Consider Electromagnetic Pulse (EMP) protective measures for communications systems
where practical.
DHS/FEMA Communications Support Services
CISA and FEMA offer a variety of technical assistance and other support services to assist state and local
entities in their efforts to comply with the above requirements, including the SAFECOM Guidance, with
the goal of ensuring interoperable and resilient emergency communications. A summary of DHS/FEMA
support services is provided below. Grant recipients are encouraged to refer to the respective websites for
additional information.
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CISA Support:
CISA assists agencies through a myriad of services, including direct TA and training provided at no cost
to the jurisdiction. The TA offerings include (but are not limited to):
•
Coordinated statewide governance (e.g., State Mapping Tool, Interoperable Communications
Reference Guides)
•
Comprehensive emergency communications planning (e.g., SCIPs, TICPs, and Field Operations
Guides)
•
Next Generation 911 planning and implementation
•
Data operability and interoperability
•
Alerts and warnings
•
Broadband deployment
•
Cybersecurity education and awareness
•
Communications Unit (COMU) planning and procedures
Information on these services is available at https://www.cisa.gov/safecom/ictapscip-resources and
https://www.cisa.gov/interoperable-communications-technical-assistance-program.
FEMA Disaster Emergency Communications Division (DEC) Support:
DEC has developed State Communications Annexes for all 56 states and territories. DEC provides
technical assistance, coordinated through the FEMA Region’s Regional Emergency Communications
Coordinator (RECC) in scheduling with the states and territories for major updates to the Annexes. Major
updates are scheduled on a 3 to 5-year cycle. FEMA DEC supports the major update with a team of
communications and emergency management specialists that facilitate a process of interaction with state
representatives. This process is coordinated through the SWIC or state designated representative. All
documentation is the responsibility of the FEMA support team and validated through state interaction.
Minor yearly updates to the State Annexes are accomplished through the RECCWG process. FEMA DEC
support staff, working in coordination with the region-specific RECC, incorporate pertinent update
information provided by state and local representatives. Additionally, operational information identified
through exercises and incident response activities is a source of update data. The FEMA RECC, with the
support of the DEC team, is responsible for maintaining the State Annexes ― changes and modifications
to the Annexes are validated with the state through RECC coordination with the SWIC or designated state
representative.
FEMA National Preparedness Directorate (NPD) Support:
NPD provides training, exercises, and technical assistance to SLTT stakeholders that support operational
and emergency communications. Descriptions and resources specific to operational communication are
available on FEMA’s website (https://www.fema.gov/core-capability-development-sheets) within the
Response Mission Area and include the following information to support jurisdictions:
•
Description of the operational communications core capability
•
Training for building and sustaining operational communication with specific course titles
o Trainings can also be found at https://www.firstrespondertraining.gov/frt/.
•
Example capability targets to complete a THIRA
o Help in developing targets can be found at www.preptoolkit.fema.gov/urt or requested at
FEMA-SPR@fema.dhs.gov
•
Resources types that support operational communications
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o Additional resource types and position qualifications can be found at
https://www.fema.gov/preparedness-checklists-toolkits.
•
Tools to validate capabilities through exercises
o Technical assistance and support from subject matter experts can be requested through
www.fema.gov/national-exercise-program.
FEMA National Continuity Programs (NCP) Support:
NCP’s support services focus on holistic continuity planning, of which communications continuity is an
important component. Currently, continuity communications training and technical assistance is limited to
the FEMA National Radio System (FNARS) and IPAWS and is delivered either on an ad hoc basis at the
request of the state entity, through a FEMA Region, or via a requirement for terms of use. Entities
interested in NCP support services should contact FEMA-CGC@fema.dhs.gov or consult NCP’s
Continuity Resources Toolkit webpage at https://www.fema.gov/continuity-resource-toolkit.
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Program Appendix B:
Tribal Homeland Security Grant Program (THSGP)
As a reminder, while this appendix contains THSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the THSGP. Please be sure to read the main content of this
Manual in addition to the program-specific appendices.
Alignment of THSGP to the National Preparedness System
The THSGP plays an important role in the implementation of the National Preparedness Goal by
supporting the building, sustainment, and delivery of the core capabilities. The core capabilities are
essential for the execution of critical tasks for each of the five mission areas outlined in the Goal.
Delivering core capabilities requires the combined effort of the whole community, rather than the
exclusive effort of any single organization or level of government. THSGP allowable costs support efforts
to build and sustain core capabilities across the prevention, protection, mitigation, response, and recovery
mission areas described in the Goal.
Particular emphasis in THSGP will be placed on capabilities that address the greatest risks to the security
and resilience of tribal communities and the United States and that provide a clear nexus to preventing
acts of terrorism. Funding will support deployable assets that can be utilized through automatic assistance
and mutual aid agreements. THSGP supports investments that improve the ability of jurisdictions
nationwide to:
•
Prevent a threatened or an actual act of terrorism;
•
Protect our citizens, residents, visitors, and assets against the greatest threats and hazards;
•
Mitigate the loss of life and property by lessening the impact of future disasters;
•
Respond quickly to save lives, protect property and the environment, and meet basic human needs
in the aftermath of a catastrophic incident; and/or
•
Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic,
and environmental fabric of communities affected by a catastrophic incident.
To support building, sustaining, and delivering these core capabilities, recipients will use the components
of the National Preparedness System, which include: Identifying and Assessing Risk, Estimating
Capability Requirements, Building and Sustaining Capabilities, Planning to Deliver Capabilities,
Validating Capabilities, and Reviewing and Updating. Additional information on the National
Preparedness System is available at: http://www.fema.gov/national-preparedness-system.
FEMA requires recipients to prioritize grant funding to demonstrate how investments support identified
national priorities and closing capability gaps or sustaining capabilities identified in the Threat and
Hazard Identification and Risk Assessment (THIRA)/Stakeholder Preparedness Review (SPR) process.
Recipients are also expected to consider national areas for improvement identified in the most recent
National Preparedness Report as they relate to terrorism preparedness. They include cybersecurity,
economic recovery, housing, infrastructure systems, natural and cultural resources, and supply chain
integrity and security. Addressing these areas for improvement will enhance preparedness nationwide.
Minimum funding amounts are not prescribed by the Department for these priorities; however, recipients
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are expected to support state, local, regional, and national efforts in achieving the desired outcomes of
these priorities.
Reporting on the Implementation of the National Preparedness System
By December 31, 2021, THSGP recipients are required to complete a THIRA/SPR that addresses all 32
core capabilities and is compliant with the Comprehensive Preparedness Guide (CPG) 201, Third Edition.
Specific guidance on the requirements for each core capability will be forthcoming in 2021, as some core
capabilities have fewer reporting requirements than others.
THSGP recipients must complete every step of the THIRA/SPR for the following eight core capabilities:
Cybersecurity; Infrastructure Systems; Mass Care Services; Mass Search and Rescue Operations; On-
scene Security, Protection, and Law Enforcement; Operational Communications; Operational
Coordination; and Public Information and Warning. For the remaining 24 core capabilities, THSGP
recipients are only required to indicate planning, organization, equipment, training, and exercise gaps in
functional areas related to those capabilities. THSGP recipients may optionally complete additional
portions of the THIRA/SPR for these 24 core capabilities.
Beginning in 2020 and continuing in 2021, THSGP recipients are required to respond to a series of
planning-related questions as part of the THIRA/SPR. THSGP recipients are required to submit a THIRA
every three (3) years to establish a consistent baseline for assessment. While the THIRA will be only
required every three years, THSGP recipients will continue to be required to submit an SPR annually. For
additional guidance on the THIRA/SPR, please refer to the Comprehensive Preparedness Guide (CPG)
201, Third Edition. Recipients must align THSGP grant investments in building and sustaining
capabilities with closing capability gaps and/or sustaining capabilities they identified in their THIRA and
SPR.
Reporting Requirements
•
THSGP recipients must submit their THIRA and SPR through the Unified Reporting Tool (URT)
on Prep Toolkit no later than December 31 of the applicable year (every three years for THIRA
and each year for SPR). FY 2021 THSGP Recipients must also update their SPR inputs in 2022
and 2023.
•
Please contact FEMA-SPR@fema.dhs.gov if you have questions.
•
In each THSGP recipient’s Biannual Strategy and Implementation Report (BSIR), as part of
programmatic monitoring, recipients will be required to describe how investments support closing
capability gaps or sustaining capabilities identified in the THIRA/SPR. THSGP recipients will, on
a project-by-project basis, check one of the following:
o Building a capability with THSGP funding; or
o Sustaining a capability with THSGP funding.
National Incident Management System (NIMS) Implementation
Recipients receiving THSGP funding are required to implement the National Incident Management
System (NIMS). NIMS guides all levels of government, nongovernmental organizations (NGO), and the
private sector to work together to prevent, protect against, mitigate, respond to, and recover from
incidents. NIMS provides stakeholders across the whole community with the shared vocabulary, systems,
and processes to successfully deliver the capabilities described in the National Preparedness Goal.
THSGP recipients must utilize standardized resource management concepts such as typing, credentialing,
and inventorying resources that facilitates the effective identification, dispatch, deployment, tracking and
recovery of their resources.
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The NIMS Implementation Objectives for Local, State, Tribal, and Territorial Jurisdictions clarifies the
NIMS implementation requirements in FEMA preparedness grant Notices of Funding Opportunities
(NOFOs). As recipients and subrecipients of federal preparedness (non-disaster) grant awards,
jurisdictions and organizations must achieve, or be actively working to achieve, all of the NIMS
Implementation Objectives. The objectives can be found on the NIMS webpage at
https://www.fema.gov/emergency-managers/nims/implementation-training.
Reporting Requirements
Recipients report in the applicable secondary NIMS assessment portion of the URT as part of their
THIRA/SPR submission, as outlined in the THSGP NOFO.
Planning to Deliver Capabilities
Recipients shall develop and maintain a jurisdiction wide, all threats and hazards EOPs consistent with
CPG 101 Version 2.0 (CPG 101 v2). Recipients must submit an EOP once during the period of
performance.
Reporting Requirements
Recipients report EOP compliance with Developing and Maintaining Emergency Operations Plans by
completing the secondary CPG 101 v2 assessment in the URT.
Validating Capabilities
All recipients will develop and maintain a progressive exercise program consistent with Homeland
Security Exercise and Evaluation Program (HSEEP) guidance in support of the National Exercise
Program (NEP). The NEP serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that
validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’
Strategic Priorities, established by the National Security Council and informed by preparedness data from
jurisdictions across the Nation.
To develop and maintain a progressive exercise program consistent with HSEEP and in support of the
NEP, recipients should engage senior leaders and other whole community stakeholders to identify
preparedness priorities. These priorities should be informed by various factors, including jurisdiction-
specific threats and hazards (i.e. the THIRA); areas for improvement identified by real-world events and
exercises; external requirements such as state or national preparedness reports, homeland security policy,
and industry reports; and accreditation standards, regulations, or legislative requirements. Recipients
should document these priorities and use them to deploy a schedule of preparedness events in a multi-year
Integrated Preparedness Plan (IPP). Information related to IPPs and Integrated Preparedness Planning
Workshops (IPPWs) can be found on the HSEEP website at https://www.fema.gov/emergency-
managers/national-preparedness/exercises/hseep and https://preptoolkit.fema.gov/.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance,
tools and resources, enhanced coordination, and the ability to directly influence and inform policy and
preparedness programs. If you have any questions or would like to request assistance through the NEP,
please visit the NEP website at: https://www.fema.gov/national-exercise-program or reach out to the NEP
directly at NEP@fema.dhs.gov.
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Reporting Requirements
•
Recipients must have a current multi-year IPP that identifies preparedness priorities and
activities. The current multi-year IPP must be submitted to hseep@fema.dhs.gov before January
31 of each year.
o Recipients are encouraged to enter their exercise information into the Preparedness
Toolkit at https://preptoolkit.fema.gov/.
•
Recipients must submit After-Action Report (AAR)/Improvement Plans (IPs) to
hseep@fema.dhs.gov and indicate which fiscal year’s funds were used (if applicable).
•
Submission of AAR/IPs must be no later than December 31 of each year. For exercises that occur
within the final quarter of a calendar year, submission of AAR/IPs must occur within 90 days
after completion of the single exercise. Regardless of conduct date, recipients are encouraged to
submit AAR/IPs within 90 days after completion of the single exercise or progressive series.
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took
place at the state, territorial, tribal, or UASI level. Recipients are discouraged from
submitting AAR/IPs specific to local jurisdictions that reflect drills.
o If a recipient endures a significant real-world incident during the calendar year that
delays or prevents conduct of a grant-funded exercise, they can submit the AAR from
that event in place of the exercise AAR. Jurisdictions submitting real world AARs should
include an explanation with the AAR submission to hseep@fema.dhs.gov.
o Recipients can access a sample AAR/IP template at
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.
THSGP Funding Guidelines
Recipients and subrecipients must comply with all applicable requirements of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards located at 2 C.F.R. Part 200.
In administering a THSGP grant award, recipients must comply with the following general requirements:
THSGP Priorities
See the annual THSGP NOFO.
Allowable Costs
Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of THSGP
funds, such as financial management and monitoring. Recipients may use up to 5% of the amount of the
award for M&A, and where applicable, subrecipients may use up to 5% for M&A of the amount they
receive. Reasonable costs of grant management training are also allowable.
Indirect (Facilities and Administrative [F&A]) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
THSGP Appendix | February 2021
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proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Allowable Direct Costs
The following pages outline global allowable costs guidance specifically applicable to THSGP.
Allowable activities made in support of the national priorities, as well as other capability-enhancing
projects must fall into the categories of planning, organization, equipment, training, or exercises
(POETE). Additional detail about each of these allowable expense categories, as well as sections on
additional activities including explicitly unallowable costs is provided. In general, recipients should
consult their FEMA Preparedness Officer prior to implementing any investment to ensure that it clearly
meets the allowable expense criteria established by the guidance.
Recipients are encouraged to use grant funds for evaluating grant-funded project effectiveness and return
on investment aligned to the relevant POETE element, and FEMA encourages grant recipients to provide
the results of that analysis to FEMA.
Planning
Planning efforts can include prioritizing needs, updating preparedness strategies, and allocating resources
across stakeholder groups (e.g., law enforcement, fire, emergency medical services, health care systems,
public health, behavioral health, public works, rural water associations, agriculture, information
technology, emergency communications, and the general public, including people with disabilities) and
levels of government. Planning provides a methodical way to engage the whole community in thinking
through the life cycle of potential crises, determining required capabilities, and establishing a framework
for roles and responsibilities. Planning must include participation from all stakeholders in the community
who are able to contribute critical perspectives and may have a role in executing the plan. Planning should
be flexible enough to address incidents of varying types and magnitudes.
Planning activities should focus on the prevention, protection, mitigation, response, and recovery mission
areas outlined in the Goal. All jurisdictions are encouraged to work with Citizen Corps Whole
Community Councils, nongovernmental entities, and the general public in planning activities. Whole
community planning should integrate program design and delivery practices that ensure representation
and services for under-represented diverse populations that may be more impacted by disasters including
children, seniors, individuals with disabilities or access and functional needs, individuals with diverse
culture and language use, individuals with lower economic capacity and other underserved populations.
Recipients must use the CPG 101 v2, Third Edition in order to develop robust and effective plans.
For additional planning and resource information, please see:
http://www.fema.gov/pdf/about/divisions/npd/CPG_101_V2.pdf
http://www.ready.gov/citizen-corps
http://www.fema.gov/community-emergency-response-teams
www.ready.gov/kids
http://www.fema.gov/media-library/assets/documents/94775.
https://www.fema.gov/sites/default/files/2020-06/national_disaster_recovery_framework_2nd.pdf
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Continuity of Operations
FEMA is designated as the Department of Homeland Security's lead agency for managing the nation's
Continuity Program. To support this role, FEMA provides direction and guidance to assist in developing
capabilities for continuing federal and state, local, tribal, and territorial (SLTT) government jurisdictions
and private sector organizations' essential functions across a broad spectrum of emergencies.
Presidential Policy Directive 40, the National Continuity Policy Implementation Plan (NCPIP), Federal
Continuity Directive (FCD) 1, FCD 2, and Continuity Guidance Circular (CGC) outline continuity
requirements for agencies and organizations and provide guidance, methodology, and checklists. For
additional information on continuity programs, guidance, and directives, visit
http://www.fema.gov/guidance-directives and https://www.fema.gov/national-continuity-programs or
contact a Regional Continuity Manager. Please note, the Continuity Guidance Circular (2018) supersedes
Continuity Guidance Circular-1, Continuity Guidance for Non-Federal Governments (July 2013), and
Continuity Guidance Circular-2, Continuity Guidance for Non-Federal Governments: Mission Essential
Function Identification Process (Oct. 2013). U.S. Department of Homeland Security, Continuity
Guidance Circular at 8 (Feb. 2018).
Organization
Recipients may use grant funds for organization activities:
•
Organizational activities may include, paying salaries and benefits for personnel, including
individuals employed to serve as qualified intelligence analysts. Personnel hiring, overtime, and
backfill expenses are permitted under this grant only to the extent that such expenses are for the
allowable activities within the scope of the grant.
•
Other organization activities may include implementing standardized resource management
concepts such as typing, inventorying, organizing, and tracking to facilitate the dispatch,
deployment, and recovery of resources before, during, and after an incident.
Additionally, Migrating online services to the “.gov” internet domain is an allowable expense.
Equipment
The 21 allowable prevention, protection, mitigation, response, and recovery equipment categories and
equipment standards for THSGP are listed on the web-based version of the Authorized Equipment List
(AEL). Unless otherwise stated, equipment must meet all mandatory regulatory and DHS-adopted
standards to be eligible for purchase using these funds. In addition, recipients and subrecipients, as
applicable, agencies will be responsible for obtaining and maintaining all necessary certifications and
licenses for the requested equipment. Recipients may purchase equipment not listed on the AEL, but only
if they first seek and obtain prior approval from FEMA.
Grant funds must comply with Information Bulletin (IB) 426 and may not be used for the purchase of the
following unallowable equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized
aircraft, vessels, or vehicles of any kind with weapons installed. Recipients should analyze the costs and
benefits of purchasing versus leasing equipment, especially high-cost items and those subject to rapid
technical advances. Large equipment purchases must be identified and explained. For more information
regarding property management standards for equipment, please reference 2 C.F.R. Part 200, including 2
C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy
#405-143-1 regarding prohibitions on covered telecommunications equipment or services.
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Requirements for Small Unmanned Aircraft System
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Training and Exercises
Tribes are strongly encouraged to use THSGP funds to develop or maintain a homeland security training
program. Allowable training-related costs under the THSGP include the establishment, support, conduct,
and attendance of training specifically identified under the THSGP or in conjunction with emergency
preparedness training by other federal agencies (e.g., the Department of Health and Human Services or
the Department of Transportation). Training conducted using THSGP funds should address a performance
gap identified through an assessment or contribute to building a capability that will be evaluated through a
formal exercise. Exercises should be used to provide the opportunity to demonstrate and validate skills
learned in training, as well as to identify training gaps. Any training or training gaps evaluated though a
formal exercise, including those for vulnerable populations including children, the elderly, pregnant
women, and individuals with disabilities or access and functional needs should be identified in an
AAR/IP.
All training and exercises conducted with THSGP funds should support the development and testing of
the jurisdiction’s Emergency Operations Plan (EOP), consistent with the priorities in the National
Preparedness System. Recipients are encouraged to use existing training rather than developing new
courses. When developing new courses, recipients are encouraged to apply the Analysis, Design,
Development, Implement, and Evaluate (ADDIE) model of instruction design, available with additional
training information at https://www.firstrespondertraining.gov.
FEMA supports and encourages the coordination of all emergency preparedness training towards the
achievement of the Goal. To this end, FEMA supports the establishment of a Tribal Training Point of
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Contact (TTPOC). The role of the TTPOC is to coordinate the tribes’ training needs and activities with
FEMA and FEMA’s federal training partners and holds the same authority and roles that state training
points of contact serve within SAAs nationwide. FEMA will coordinate with Tribal Training Officers
(TTOs) as it relates to FEMA training when notified by recipients.
Per FEMA Grant Programs Directorate IB 432, Review and Approval Requirements for Training
Courses Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal entities,
and high-risk urban areas are no longer required to request approval from FEMA for personnel to attend
non-DHS/FEMA training as long as the training is coordinated with and approved by the state, territory,
tribal, or high-risk urban area TPOC and falls within the FEMA mission scope and the jurisdiction’s EOP.
For additional information on review and approval requirements for training courses funded with
preparedness grants, please refer to the following policy: https://www.fema.gov/sites/default/files/2020-
09/fema_gpd-review-approval-requirements-training-policy_09-10-13.pdf.
DHS/FEMA Provided Training and Education
FEMA offers tuition-free training and education programs and courses through several providers
including the Center for Domestic Preparedness, the Emergency Management Institute, and the National
Training and Education Division’s Training Partner Program (TPP). TPP includes the Center for
Homeland Defense and Security, National Domestic Preparedness Consortium, Rural Domestic
Preparedness Consortium, and training partners through the Continuing Training Grants program.
FEMA’s National Preparedness Course Catalog
This online searchable catalog features a wide range of course topics in multiple delivery modes to meet
FEMA’s mission scope as well as the increasing training needs of federal, state, local, territorial, and
tribal audiences. The catalog can be accessed at http://www.firstrespondertraining.gov.
Training Not Provided by DHS/FEMA
These trainings include courses that are either state sponsored or federal sponsored (non-DHS/FEMA),
coordinated and approved by the SAA or their designated TPOC, and fall within the FEMA mission
scope to prepare SLTT personnel to prevent, protect against, mitigate, respond to, and recover from acts
of terrorism or catastrophic events.
•
State Sponsored Courses. These courses are developed for and/or delivered by institutions or
organizations other than federal entities or FEMA and are sponsored by the SAA or their
designated TPOC.
•
Joint Training and Exercises with the Public and Private Sectors. These courses are
sponsored and coordinated by private sector entities to enhance public-private partnerships for
training personnel to prevent, protect against, mitigate, respond to, and recover from acts of
terrorism or catastrophic events. In addition, states, territories, tribes, and urban areas are
encouraged to incorporate the private sector in government-sponsored training and exercises.
Additional information on both FEMA provided training and other federal and state training can be found
at http://www.firstrespondertraining.gov.
Training Information Reporting System (“Web-Forms”)
Web-Forms is an electronic data management system built to assist SAAs, designated TPOCs, and federal
agencies with submitting non-NTED provided training courses for inclusion in the State/Federal-
Sponsored Course Catalog through electronic forms. The information collected is used in a two-step
review process to ensure the training programs adhere to the intent of the HSGP guidance and the course
content is structurally sound and current. As these programs may be delivered nationwide, it is vital to
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ensure each training program's viability and relevance to the Homeland Security mission. Reporting
training activities through Web-Forms is not required under FY 2021 THSGP. However, the system
remains available and can be accessed through the FEMA Toolkit to support recipients in their own
tracking of training deliveries.
Exercises
For additional information on conducting exercises under THSGP, please refer to the earlier section in
this appendix titled “Validating Capabilities” on page B-3.
Personnel Activities
Personnel hiring, overtime, and backfill expenses are permitted under this grant in order to perform
allowable THSGP planning, training, exercise, and equipment activities.
Not more than 50% of total THSGP funds may be used for personnel activities as directed by the
Homeland Security Act of 2002, as amended by the Personnel Reimbursement for Intelligence
Cooperation and Enhancement (PRICE) of Homeland Security Act (Pub. L. No. 110-412) (6 U.S.C.
§609(b)(2)(A)). This 50% cap may be waived, however, per 6 U.S.C. § 609(b)(2)(B). For further details,
THSGP recipients should refer to IB 421b, or contact their FEMA HQ Preparedness Officer. THSGP
funds may not be used to support the hiring of any personnel for the purposes of fulfilling traditional
public safety duties or to supplant traditional public safety positions and responsibilities.
Construction and Renovation
Construction projects are only permitted where they will assist the recipient to achieve target capabilities
related to preventing, preparing for, protecting against, or responding to acts of terrorism, including
through the alteration or remodeling of existing buildings for the purpose of making them secure against
acts of terrorism. THSGP funding may not be used for construction and renovation projects without prior
written approval from FEMA. All recipients of THSGP funds must request and receive approval from
FEMA before any THSGP funds are used for any construction or renovation. Additionally, recipients are
required to submit an SF-424C Form containing budget detail citing the construction project costs and an
SF-424D Form for standard assurances for the construction project. The total cost of any construction or
renovation paid for using THSGP funds may not exceed the greater amount of $1,000,000 or 15% of the
THSGP award.
All construction and renovation projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients and subrecipients are encouraged to have completed as many steps as possible for a
successful EHP review in support of their proposal for funding (e.g., coordination with their State
Historic Preservation Office to identify potential historic preservation issues and to discuss the potential
for project effects, compliance with all state and local EHP laws and requirements). Projects for which the
recipient believes an EA may be needed, as defined in DHS Instruction Manual 023-01-001-01, Revision
01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ
Preparedness Officer within six months of the award and completed EHP review materials must be
submitted no later than 12 months before the end of the period of performance. EHP policy guidance and
the EHP Screening Form, can be found online at: https://www.fema.gov/media-
library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.dhs.gov.
THSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified
as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Grant recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character similar to the contract work in the civil subdivision of the
THSGP Appendix | February 2021
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state in which the work is to be performed. Additional information regarding compliance with the Davis-
Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following
website: http://www.dol.gov/whd/govcontracts/dbra.htm.
Communications Towers
For the purposes of the limitations on funding levels only, communications towers are not considered
construction. When applying for construction funds, including communications towers, at the time of
application, recipients must submit evidence of approved zoning ordinances, architectural plans, and any
other locally required planning permits.
When applying for funds to construct communication towers, recipients and subrecipients must submit
evidence that the Federal Communication Commission’s Section 106 review process has been completed
and submit all documentation resulting from that review, with a FEMA Grant Programs Directorate EHP
Screening Form, to FEMA as part of the project’s EHP Review submittal. Recipients and subrecipients
are encouraged to have completed as many steps as possible for a successful EHP review in support of
their proposal for funding (e.g., coordination with their Tribal Historic Preservation Office to identify
potential historic preservation issues and to discuss the potential for project effects; compliance with all
state and local EHP laws and requirements). Projects for which an EA may be needed, as defined in DHS
Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction 108-1-1,
must also be identified to the FEMA HQ Preparedness Officer within six months of the recipient’s receipt
of the award. Completed EHP review materials for communication tower projects must be submitted no
later than 12 months before the end of the period of performance. EHP policy guidance and the EHP
Screening Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195.
EHP review materials and an EHP Screening Form should be sent to gpdehpinfo@fema.dhs.gov.
Multiple Purpose or Dual-Use of Funds
Many activities that support the achievement of target capabilities related to terrorism preparedness may
simultaneously support enhanced preparedness for other hazards unrelated to acts of terrorism. See 6 U.S.C.
§ 609(c). However, all THSGP-funded projects must assist recipients and subrecipients in achieving target
capabilities related to preventing, preparing for, protecting against, or responding to acts of terrorism.
Whole Community Preparedness
In addition to the Citizen Corps Whole Community Councils and Community Emergency Response Team
(CERT) programs mentioned above, youth preparedness activities are another allowable cost. Bolstering
youth preparedness across the nation is a priority for FEMA as the Agency works with state, local, tribal,
and territorial partners to create a culture of preparedness in the United States. Information on youth-
centric educational curricula, games, planning materials, and other relevant resources can be found at
https://www.ready.gov/kids. Furthermore, FEMA’s Individual and Community Preparedness Division
(ICPD) and regional based Community Preparedness Officers (CPOs) are available to provide grant
recipients with guidance and assistance. Please email FEMA-Prepare@fema.dhs.gov to contact one of the
Agency’s subject matter experts.
The following are examples of youth preparedness activities that grantees are encouraged to undertake as
allowable costs:
•
Reach out to a local school board or elementary school to encourage the adoption of the Student
Tools for Emergency Planning (STEP) curriculum. STEP is a classroom-based emergency
preparedness curriculum for 4th- and 5th-graders in an easy, ready-to-teach format. Students will
learn about disasters, emergencies, and hazards, and how to create a disaster supply kit and family
emergency communication plan. An overview of the STEP program along with the instructor
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guide and student activity book is available at https://www.ready.gov/student-tools-emergency-
planning-step.
•
Sponsor the creation of a Teen CERT in your jurisdiction. The CERT Program is a national
program of volunteers trained in disaster preparedness and emergency response. Volunteers come
from all ages and all walks of life, including teenagers. Additional information, including a step-
by-step guide on how to start a Teen CERT, is available at https://www.ready.gov/teen-cert.
The following tools are available to order from FEMA’s warehouse free of charge:
•
“Prepare with Pedro” is a joint product of FEMA and the American Red Cross. The “Prepare with
Pedro: Disaster Preparedness Activity Book” is designed to teach young children and their
families about how to stay safe during disasters and emergencies. The book follows Pedro around
the United States and offers safety advice through crosswords, coloring pages, matching games,
and more. Additional information, including an ordering form, is available at
https://www.ready.gov/prepare-pedro.
•
The Ready 2 Help card game is a fun way for kids to learn how to respond to emergencies by
working with friends and using skills that will help in a real emergency. Ready 2 Help teaches
five simple steps to stay safe and make a difference until help arrives:
o Stay Safe
o Stay Calm
o Get Help
o Give Info
o Give Care
Ready 2 Help was designed for children ages 8 and up. Additional information, including an ordering
form, is available at https://www.ready.gov/ready-2-help.
Other Allowable Costs
Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs which must be in (1) direct support of
existing capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program,
and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally,
eligible costs must also be in support of equipment, training, and critical resources that have previously
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been purchased with either federal grant money or any other source of funding other than FEMA
preparedness grant program dollars.
Critical Emergency Supplies
In furtherance of DHS’s mission, critical emergency supplies, such as shelf-stable food products, water,
and basic medical supplies are an allowable expense under THSGP. Prior to allocating grant funds for
stockpiling purposes, each Tribe must have FEMA’s approval of a five-year viable inventory
management plan, an effective distribution strategy, and related sustainment costs if the planned grant
expenditure is over $100,000.
The inventory management plan and distribution strategy, to include sustainment costs, will be developed
and monitored by FEMA. FEMA will provide program oversight and technical assistance as it relates to
the purchase of critical emergency supplies under THSGP. FEMA will establish guidelines and
requirements for the purchase of these supplies under THSGP and monitor development and status of the
Tribe’s inventory management plan and distribution strategy. Linkages between specific projects
undertaken with THSGP funds and strategic goals and objectives will be highlighted through regular
required reporting mechanisms. If grant expenditures exceed the minimum threshold, the five-year
inventory management plan will be developed and monitored by FEMA.
Secure Identification
THSGP funds may be used to support the development and production of enhanced tribal documents
(e.g., Enhanced Tribal Cards) designed to meet the requirements of the Western Hemisphere Travel
Initiative (WHTI). More information on the WHTI may be found at
http://www.dhs.gov/files/programs/gc_1200693579776.shtm and https://www.cbp.gov/travel/us-
citizens/western-hemisphere-travel-initiative.
When completing the Investment Justification, refer to the National Preparedness Goal at for a list of the
core capabilities that best fit the proposed activities and costs. For additional assistance in determining the
core capabilities that fit the proposed WHTI project, please contact the CSID by phone at (800) 368-6498
or by e-mail at askcsid@fema.gov
Fidelity Bonds
Reasonable costs of fidelity bonds (or like insurance as provided for by applicable state or tribal laws)
covering the maximum amount of THSGP funds the officer, official, or employee handles at any given
time for all personnel who disburse or approve disbursement of THSGP funds may be allowable if
required by the terms and conditions of the award or if generally required by the tribe in its general
operations. If a fidelity bond is required by a tribe in its general operations, those costs must be charged as
indirect costs. See 2 C.F.R. § 200.427.
THSGP Investment Modifications – Changes in Scope or Objective
Changes in scope or objective of the award—including those resulting from intended actions by the
recipient or subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §§
200.308(c)(1), 200.407. THSGP is competitive, with applications recommended for funding based on
threat, vulnerability, and consequence, and their mitigation of potential terrorist attacks. However,
consistent with 2 C.F.R § 200.308(c)(1), Change in Scope Prior Approval, FEMA requires prior approval
of any change in scope or objective of the grant-funded activity after the award is issued. See 2 C.F.R. §
200.308(b), (c). Scope or objective changes will be considered on a case-by-case basis, provided the
change does not negatively impact the competitive process used to recommend THSGP awards.
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Requests to change the scope or objective of the grant-funded activity after the award is made must be
submitted via ND Grants as a Scope Change Amendment. The amendment request must include the
following:
•
A written request on the recipient’s letterhead, outlining the scope or objective change, including
the approved projects from the IJ, the funds and relative scope or objective significance allocated
to those projects, the proposed changes, and any resulting reallocations as a result of the change
of scope or objective;
•
An explanation why the change of scope or objective is necessary;
•
How the proposed scope or objective changes to the project support the vulnerabilities and
capability gaps identified in the approved IJ; and
•
The request must also address whether the proposed changes will impact the recipient’s ability to
complete the project within the award’s period of performance.
Recipients may not proceed with implementing any scope or objective changes until they receive prior
written approval from FEMA through ND Grants.
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Program Appendix C:
Nonprofit Security Grant Program (NSGP)
As a reminder, while this appendix contains NSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the NSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
NSGP grant recipients and subrecipients may only use NSGP grant funds for the purpose set forth in the
grant award and must use funding in a way that is consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal grants or cooperative agreements,
lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may
not be used to sue the Federal Government or any other government entity.
Pre-award costs are allowable only with the prior written approval of FEMA and if they are included in
the award agreement. To request pre-award costs a written request must be included with the application,
signed by the Authorized Organizational Representative (AOR) of the entity. The letter must outline what
the pre-award costs are for, including a detailed budget break-out of pre-award costs from the post-award
costs, and a justification for approval. The following information outlines general allowable and
unallowable NSGP costs guidance.
NSGP Funding Guidelines
Recipients and subrecipients must comply with all applicable requirements of the Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards located at 2 C.F.R. Part 200.
In administering a NSGP grant award, recipients must comply with the following general requirements:
NSGP Priorities
See the annual NSGP NOFO.
Allowable Costs
Management and Administration (M&A)
M&A costs are for activities directly related to the management and administration of the award. M&A
activities are those defined as directly relating to the management and administration of NSGP funds,
such as financial management and monitoring. M&A expenses must be based on actual expenses or
known contractual costs. Requests that are simple percentages of the award, without supporting
justification, will not be allowed or considered for reimbursement.
M&A costs are not operational costs, they are the necessary costs incurred in direct support of the grant or
as a consequence of the grant and should be allocated across the entire lifecycle of the grant. Examples
include preparing and submitting required programmatic and financial reports, establishing and/or
maintaining equipment inventory, documenting operational and equipment expenditures for financial
accounting purposes, and responding to official informational requests from state and federal oversight
authorities. M&A costs include the following categories of activities:
NSGP Appendix | February 2021
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•
Hiring of full-time or part-time staff or contractors/consultants responsible for activities relating
to the management and administration of NSGP funds. Hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.
•
Meeting-related expenses directly related to M&A of NSGP funds.
M&A costs are allowed under this program as described below:
Note: States must be able to separately account for M&A costs associated with the NSGP-Urban Area
(NSGP-UA) award from those associated with the NSGP-State (NSGP-S) award.
•
SAA (Recipient) for NSGP-UA M&A: The NSGP-UA is a sub-component of the Urban Area
Security Initiative (UASI) program, and states must ensure that 100 percent of each individual
NSGP-UA award is passed through to the nonprofit organizations awarded funding by FEMA.
The state may use its UASI funding for M&A purposes associated with administering the NSGP-
UA award. However, the state’s overall M&A withholding for the NSGP-UA and UASI
programs may not exceed the percent noted in the relevant fiscal year (FY) NOFO of the total of
the state’s combined UASI and NSGP-UA awards. Additionally, since all costs must be allocable
to the applicable grant program, the state must be able to trace the level of expenditures for its
UASI M&A costs separately from its NSGP-UA M&A costs, with each set of M&A costs limited
to the percent noted in the relevant FY NOFO.
•
SAA (Recipient) for NSGP-S M&A:
The NSGP-S is a sub-component of the State Homeland Security Program (SHSP), and states
must ensure that 100 percent of each individual NSGP-S award is passed through to the nonprofit
organizations awarded funding by FEMA. The state may use its SHSP funding for M&A
purposes associated with administering the NSGP-S award. However, the state’s overall M&A
withholding for the NSGP-S and SHSP programs may not exceed the percent noted in the
relevant FY NOFO of the total of the state’s combined SHSP and NSGP-S awards. Additionally,
since all costs must be allocable to the applicable grant program, the state must be able to trace
the level of expenditures for its SHSP M&A costs separately from its NSGP-S M&A costs, with
each set of M&A costs limited to the percent noted in the relevant fiscal year (FY) NOFO.
•
Nonprofit (Subrecipient) for NSGP-UA and NSGP-S M&A:
Nonprofit organizations that receive a subaward under this program may use and expend up to the
percent noted in the relevant fiscal year (FY) NOFO for M&A purposes associated with the
subaward.
Indirect (Facilities and Administrative [F&A]) Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
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National Incident Management System (NIMS) Implementation
Recipients receiving NSGP funding are strongly encouraged to implement NIMS. NIMS guides all levels
of government, nongovernmental organizations (NGO), and the private sector to work together to prevent,
protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the
whole community with the shared vocabulary, systems, and processes to successfully deliver the
capabilities described in the National Preparedness System.
Incident management activities require carefully managed resources (personnel, teams, facilities,
equipment, and supplies). NIMS defines a national, interoperable approach for sharing resources,
coordinating, and managing incidents, and communicating information. Incident management refers to
how incidents are managed across all homeland security activities, including prevention, protection,
mitigation, response, and recovery.
Utilization of the standardized resource management concepts such as typing, credentialing, and
inventorying promote a strong national mutual aid capability needed to support delivery of core
capabilities. Recipients should manage resources purchased or supported with FEMA grant funding
according to NIMS resource management guidance.
Additional information on resource management and NIMS resource typing definitions and job
titles/position qualifications is on FEMA’s website at https://www.fema.gov/emergency-
managers/nims/components. Additional information about NIMS in general is available at
https://www.fema.gov/emergency-managers/nims.
Allowable Direct Costs
Planning
Funding may be used for security or emergency planning expenses and the materials required to conduct
planning activities. Planning must be related to the protection of the facility and the people within the
facility and should include consideration of access and functional needs considerations as well as those
with limited English proficiency. Examples of planning activities allowable under this program include:
•
Development and enhancement of security plans and protocols
•
Development or further strengthening of security assessments
•
Emergency contingency plans
•
Evacuation/Shelter-in-place plans
•
Coordination and information sharing with fusion centers
•
Other project planning activities with prior approval from FEMA
Equipment
Allowable costs are focused on target hardening and physical security enhancements. Funding can be
used for the acquisition and installation of security equipment on real property (including buildings and
improvements) owned or leased by the nonprofit organization, specifically in prevention of and/or
protection against the risk of a terrorist attack. This equipment is limited to select items in the following
two sections of items on the Authorized Equipment List (AEL):
•
Physical Security Enhancement Equipment (Section 14)
•
Inspection and Screening Systems (Section 15)
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In addition to the select items in Sections 14 and 15 listed above, the following equipment is also
allowable:
•
Notification and Warning Systems
•
Radios and Public Address Systems
Unless otherwise stated, equipment must meet all mandatory statutory, regulatory, and FEMA-adopted
standards to be eligible for purchase using these funds, including the Americans with Disabilities Act. In
addition, recipients will be responsible for obtaining and maintaining all necessary certifications and
licenses for the requested equipment.
Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek
and obtain prior approval from FEMA.
Applicants should analyze the cost benefits of purchasing versus leasing equipment, especially high-cost
items and those subject to rapid technical advances. Large equipment purchases must be identified and
explained. For more information regarding property management standards for equipment, please
reference 2 C.F.R. Part 200, including but not limited to 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also
see 2 C.F.R. §§ 200.216, 200.471, and FEMA Policy #405-143-1 regarding prohibitions on covered
telecommunications equipment or services.
The installation of certain equipment may trigger EHP requirements. Please reference the EHP sections in
the NOFO and this Manual for more information. Additionally, some equipment installation may
constitute construction or renovation. Please see the Construction and Renovation section of this appendix
for additional information.
Exercises
Funding may be used to conduct security-related exercises. This includes costs related to planning,
meeting space and other meeting costs, facilitation costs, materials and supplies, and documentation.
Exercises afford organizations the opportunity to validate plans and procedures, evaluate capabilities, and
assess progress toward meeting capability targets in a controlled, low-risk setting. All shortcomings or
gaps—including those identified for children and individuals with access and functional needs—should
be identified in an improvement plan. Improvement plans should be dynamic documents with corrective
actions continually monitored and implemented as part of improving preparedness through the exercise
cycle.
The Homeland Security Exercise and Evaluation Program (HSEEP) provides a set of guiding principles
for exercise programs, as well as a common approach to exercise program management, design and
development, conduct, evaluation, and improvement planning. For additional information on HSEEP,
refer to https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep. In
accordance with HSEEP guidance, subrecipients are reminded of the importance of implementing
corrective actions iteratively throughout the progressive exercise cycle. This link provides access to a
sample After Action Report (AAR)/Improvement Plan (IP) template:
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning. Recipients are encouraged to
enter their exercise data and AAR/IP in the Preparedness Toolkit.
Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses and user fees. These contracts may exceed the period of performance if they are
NSGP Appendix | February 2021
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purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal (the Goal) and fund projects that
build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of,
respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order
to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing
capabilities, (2) must be an otherwise allowable expenditure under the applicable grant program, and (3)
be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also support equipment, training, and critical resources that have previously been purchased
with either federal grant or any other source of funding other than FEMA preparedness grant program
dollars.
Construction and Renovation
NSGP funding may not be used for construction and renovation projects without prior written approval
from FEMA. In some cases, the installation of equipment may constitute construction and/or renovation.
If you have any questions regarding whether an equipment installation project could be considered
construction or renovation, please contact your Preparedness Officer. All recipients of NSGP funds must
request and receive prior approval from FEMA before any NSGP funds are used for any construction or
renovation. Additionally, recipients are required to submit a SF-424C Budget and budget detail citing the
project costs and an SF-424D Form for standard assurances for the construction project. The total cost of
any construction or renovation paid for using NSGP funds may not exceed the greater amount of
$1,000,000.00 or 15% of the NSGP award.
All construction and renovation projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients and subrecipients are encouraged to have completed as many steps as possible for a
successful EHP review in support of their proposal for funding (e.g., coordination with their State
Historic Preservation Office to identify potential historic preservation issues and to discuss the potential
for project effects, compliance with all state and local EHP laws and requirements). Projects for which the
recipient believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction
Manual 023-01-001-01, Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also
be identified to the FEMA HQ Preparedness Officer within six months of the award and completed EHP
review materials must be submitted no later than 12 months before the end of the period of performance.
Additional information on EHP policy and EHP review can be found online at
https://www.fema.gov/media-library/assets/documents/90195. EHP review packets should be sent to
gpdehpinfo@fema.gov.
NSGP recipients using funds for construction projects must comply with the Davis-Bacon Act (codified
as amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 609(b)(4)(B) (cross-referencing 42 U.S.C. §
5196(j)(9), which cross-references Davis-Bacon). Grant recipients must ensure that their contractors or
subcontractors for construction projects pay workers no less than the prevailing wages for laborers and
mechanics employed on projects of a character similar to the contract work in the civil subdivision of the
state in which the work is to be performed. Additional information regarding compliance with the Davis-
Bacon Act, including Department of Labor (DOL) wage determinations, is available from the following
website: https://www.dol.gov/whd/govcontracts/dbra.htm.
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Training
Nonprofit organizations may use NSGP funds for the following training-related costs:
•
Employed or volunteer security staff to attend security-related training within the United States;
•
Employed or volunteer staff to attend security-related training within the United States with the
intent of training other employees or members/congregants upon completing the training (i.e.,
“train-the-trainer” type courses);
•
Nonprofit organization’s employees, or members/congregants to receive on-site security training.
Allowable training-related costs under the NSGP are limited to attendance fees for training and related
expenses, such as materials, supplies, and/or equipment. Overtime, backfill, and travel expenses are not
allowable costs.
Allowable training topics are limited to the protection of critical infrastructure key resources, including
physical and cybersecurity, target hardening, and terrorism awareness/employee preparedness such as
Community Emergency Response Team (CERT) training, indicators and behaviors indicative of terrorist
threats, Active Shooter training, and emergency first aid training. Training conducted using NSGP funds
must address a specific threat and/or vulnerability, as identified in the nonprofit organization’s
IJ. Training should provide the opportunity to demonstrate and validate skills learned as well as to
identify any gaps in these skills. Proposed attendance at training courses and all associated costs using
the NSGP must be included in the nonprofit organization’s Investment Justification (IJ).
Contracted Security Personnel
Contracted security personnel are allowed under this program only as described in the NOFO and Manual
and comply with guidance set forth in IB 421b and IB 441. NSGP funds may not be used to purchase
equipment for contracted security. The recipient must be able to sustain this capability in future years
without NSGP funding, and a sustainment plan will be required as part of the closeout package for any
award funding this capability.
Additionally, NSGP recipients and subrecipients may not use more than 50 percent of their awards to pay
for personnel activities unless a waiver is approved by FEMA. For more information on the 50 percent
personnel cap and applicable procedures for seeking a waiver, please see IB 421b, Clarification on the
Personnel Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act of
2008 (Public Law 110-412 – the PRICE Act).
Unallowable Costs
The following projects and costs are considered ineligible for award consideration:
•
Organization costs, and operational overtime costs
•
Hiring of public safety personnel
•
General-use expenditures
•
Overtime and backfill
•
Initiatives that do not address the implementation of programs/initiatives to build prevention and
protection-focused capabilities directed at identified facilities and/or the surrounding
communities
•
The development of risk/vulnerability assessment models
•
Initiatives that fund risk or vulnerability security assessments or the development of the IJ
•
Initiatives in which federal agencies are the beneficiary or that enhance federal property
•
Initiatives which study technology development
NSGP Appendix | February 2021
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•
Proof-of-concept initiatives
•
Initiatives that duplicate capabilities being provided by the Federal Government
•
Organizational operating expenses
•
Reimbursement of pre-award security expenses
•
Cameras for license plate readers/license plate reader software
•
Cameras for facial recognition software
•
Weapons or weapons-related training
•
Knox boxes
NSGP Investment Modifications – Changes in Scope or Objective
Changes in scope or objective of the award—whether as a result of intended actions by the recipient or
subrecipients—require FEMA’s prior written approval, in accordance with 2 C.F.R. §§ 200.308(c)(1),
200.407. NSGP is competitive, with applications recommended for funding based on threat, vulnerability,
consequence, and their mitigation to a specific facility/location. However, consistent with 2 C.F.R §
200.308(c)(1), Change in Scope Notification, FEMA requires prior written approval of any change in
scope/objective of the grant-funded activity after the award is issued. See 2 C.F.R. § 200.308(b), (c).
Scope/objective changes will be considered on a case-by-case basis, provided the change does not
negatively impact the competitive process used to recommend NSGP awards. Requests to change the
scope or objective of the grant-funded activity after the award is made must be submitted by the State
Administrative Agency (SAA) via ND Grants as a Scope Change Amendment. The amendment request
must include the following:
•
A written request from the NSGP subrecipient on its letterhead, outlining the scope or objective
change, including the approved projects from the subrecipient’s IJ, the funds and relative scope or
objective significance allocated to those projects, the proposed changes, and any resulting
reallocations as a result of the change of scope or objective;
•
An explanation why the change of scope or objective is necessary;
•
Validation from the SAA that any deviations from the approved IJ are addressed in the
vulnerability assessment submitted by the subrecipient at the time of application; and
•
The subrecipient request must also address whether the proposed changes will impact its ability to
complete the project within the award’s period of performance.
FEMA will generally not approve NSGP change-of-scope requests resulting from the following
situations:
•
Subrecipients that relocate their facilities after submitting their application who are requesting a
change of scope to allow them to use NSGP funds towards projects at the new facility; or
•
Subrecipients that renovate their facilities after submitting their application in cases where the
subsequent renovations would affect the vulnerability/risk assessment upon which the IJ is based.
NSGP project funding is based on the ability of the proposed project to mitigate the risk factors identified
in the IJ. For this reason, FEMA may reject requests to significantly change the physical security
enhancements that are purchased with NSGP funding where FEMA believes approval of the request
would change or exceed the scope of the originally approved project. FEMA will consider all requests to
deviate from the security project as originally proposed on a case-by-case basis, consistent with 2 C.F.R. §
200.308(c)(1).
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Subrecipients may not proceed with implementing any scope/objective changes until the SAA receives
written approval from FEMA through ND Grants and until the SAA has made any required subaward
modifications.
Pass-Through Requirements
Pass-through funding is required under this program. Awards made to the SAA for the NSGP carry
additional pass-through requirements. Pass-through is defined as an obligation on the part of the state to
make subawards to selected nonprofit organizations. The SAA must provide 100% of funds awarded
under NSGP to successful nonprofit applicants within 45 days of receipt of the funds. A letter of intent (or
equivalent) to distribute funds is not sufficient. Award subrecipients that are selected for funding under
this program must be provided with funding within 45 days from the date the funds are first made
available to the recipient so that they can initiate implementation of approved investments.
For the SAA to successfully meet the pass-through requirement and provide funding to the subrecipients,
the SAA must meet the following four requirements:
•
There must be some action by the SAA to establish a firm commitment to award the funds to the
selected nonprofit organization;
•
The action must be unconditional on the part of the SAA (i.e., no contingencies for availability of
SAA funds);
•
There must be documentary evidence of the commitment of the award of funding to the selected
nonprofit organization; and
•
The SAA must communicate the terms of the subaward to the selected nonprofit organization.
If a nonprofit organization is selected for an NSGP award and elects to decline the award, the SAA must
notify their FEMA Preparedness Officer. The SAA may not re-obligate to another subrecipient without
prior approval. “Receipt of the funds” occurs either when the SAA accepts the award or 15 calendar days
after the SAA receives notice of the award, whichever is earlier. SAAs are sent notification of NSGP
awards via the ND Grants system. If an SAA accepts its award within 15 calendar days of receiving
notice of the award in the ND Grants system, the 45-calendar day pass-through period will start on the
date the SAA accepted the award. Should an SAA not accept the NSGP award within 15 calendar days of
receiving notice of the award in the ND Grants system, the 45-calendar days pass-through period will
begin 15 calendar days after the award notification is sent to the SAA via the ND Grants system.
It is important to note that the period of performance (POP) start date does not directly affect the start of
the 45-calendar day pass-through period. For example, an SAA may receive notice of the NSGP award on
August 20, 2021 while the POP dates for that award are September 1, 2021, through August 31, 2024. In
this example, the 45-day pass-through period will begin on the date the SAA accepts the NSGP award or
September 4, 2021 (15 calendar days after the SAA was notified of the award), whichever date occurs
first. The POP start date of September 1, 2021 would not affect the timing of meeting the 45-calendar day
pass-through requirement.
DUNS/SAM Requirements for Recipients and Subrecipients
As the direct applicant and recipient of NSGP funding, the SAA is required to have a Data Universal
Numbering System (DUNS) number and be registered in the System for Award Management (SAM) and
must maintain the currency of the SAA's information in SAM until the SAA submits the final financial
report required under the award or receives final payment, whichever is later. Nonprofit organizations that
are first-tier subrecipients applying for NSGP funding through the SAA must have a DUNS number, but
are not required to be registered in SAM. See 2 C.F.R. § 25.300.
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Program Appendix D:
Transit Security Grant Program (TSGP)
As a reminder, while this appendix contains TSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the TSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
TSGP grant recipients may only use TSGP grant funds for the purpose set forth in the Notice of Funding
Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal awards, lobbying, or intervention in
federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to sue the
Federal Government or any other government entity.
TSGP Funding Guidelines
Costs charged to a TSGP award must be consistent with the Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more
information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400 regarding FEMA’s
implementation of these provisions prior to the recent 2020 revisions. For information on the recent
revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov and
www.performance.gov/CAP/grants/.
Pre-Award Costs
Pre-award costs are not allowable and will not be approved, with the exception of costs resulting from
pre-award grant writing services provided by an independent contractor that shall not exceed $1,500.00.
See below for more information on these costs.
TSGP Priorities
See the annual TSGP NOFO.
Security Plan Requirements
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):
Security plans should include the following, as appropriate:
•
A prioritized list of all items included in the public transportation agency’s security assessment
that have not yet been addressed;
•
A detailed list of any additional capital and operational improvements identified by DHS or the
public transportation agency and a certification of the public transportation agency’s technical
capacity for operating and maintaining any security equipment that may be identified in such list;
•
Specific procedures to be implemented or used by the public transportation agency in response to
a terrorist attack, including evacuation and passenger communication plans and appropriate
evacuation and communication measures for the elderly and individuals with disabilities;
TSGP Appendix | February 2021
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•
A coordinated response plan that establishes procedures for appropriate interaction with state and
local law enforcement agencies, emergency responders, and federal officials in order to
coordinate security measures and plans for response in the event of a terrorist attack or other
major incident;
•
A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part
1582;
•
Plans for providing redundant and other appropriate backup systems necessary to ensure the
continued operation of critical elements of the public transportation system in the event of a
terrorist attack or other major incident;
•
Plans for providing service capabilities throughout the system in the event of a terrorist attack or
other major incident in the city or region which the public transportation system serves;
•
Methods to mitigate damage within a public transportation system in case of an attack on the
system, including a plan for communication and coordination with emergency responders; and
•
Other actions or procedures as the Secretary of Homeland Security determines are appropriate to
address the security of the public transportation system.
Allowable Direct Costs
Specific investments made in support of the funding priorities in the annual TSGP NOFO generally fall
into one of the following six allowable expense categories:
•
Planning
•
Operational Activities
•
Equipment and Capital Projects
•
Training and Awareness Campaigns
•
Exercises
•
Management and Administration
The following provides guidance on allowable costs within each of these areas:
Planning
Planning activities address the Soft Targets/Crowded Places; Cybersecurity; Emergent Threats; and
Planning Priorities.
TSGP funds may be used for the following types of planning activities:
•
Development and enhancement of system-wide security risk management plans, to include cyber
•
Development or further strengthening of continuity of operations plans, response plans, station
action plans, risk assessments, and asset-specific remediation plans
•
Development or further strengthening of security assessments, including multi-agency and multi-
jurisdictional partnerships and conferences to facilitate planning activities
•
Hiring of full or part-time staff and contractors or consultants to assist with planning activities
only to the extent that such expenses are for the allowable activities within the scope of the grant
(not for the purpose of hiring public safety personnel); hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.
•
Materials required to conduct planning activities
•
Other project planning activities with prior approval from FEMA
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Operational Activities
Operational Activities address the Soft Targets/Crowded Places; and Emergent Threat Priorities.
FEMA encourages applicants to develop innovative operational approaches to enhance the security of
transit systems. Projects that use visible, unpredictable deterrence, to include operational packages
dealing with explosive detection canine teams, mobile screening teams, and anti-terrorism teams, directly
support enhancing the protection of soft targets and crowded places. Implementation of one of the three
Operational Package (OPack) models discussed below complements existing security systems and
provides an appropriate, practical, and cost-effective means of protecting assets.
Agencies may submit Investment Justifications (IJ) to fund transit security police forces/law enforcement
providers for patrols and activities on overtime, such as directed patrols, additional canine teams, mobile
screening teams, or anti-terrorism team patrols. These activities must be dedicated to the transit
environment and must be anti-terrorism in nature. Agencies must identify the type of activity, length of
operation (hours), number of personnel, and cost based on length of operation and personnel. Agencies
should also provide a risk-based justification for the request, to include linkage to a known event, such as
hosting a significant regional sporting or political event; or a period of heightened awareness, such as a
national holiday. Three OPack types have been developed to support operational activities and are
available for funding under the TSGP:
•
Explosives Detection Canine Teams (EDCTs). When combined with the existing capability of a
transit security/police force, the added value provided through the addition of an EDCT is
significant. EDCTs are a proven, reliable resource to detect explosives and are a key component
in a balanced counter-sabotage program. The TSGP will provide funds to establish dedicated
security/police force canine teams. Each canine team will be composed of one dog and one
handler.
•
Anti-Terrorism Teams (ATTs). The ATT capability provided through TSGP funding is for
uniformed, dedicated transit patrols on a normal operational basis, rather than using teams only
for a surge capacity as provided by FEMA in the past. ATTs do not supersede other local transit
security forces; rather, they augment current capabilities. Each ATT will consist of four
individuals, including two overt elements (e.g., uniformed transit sector law enforcement officer,
canine team, mobile explosive screeners), and two discreet observer elements.
•
Mobile Explosive Screening Teams (MESTs). The MEST OPack will allow recipients the
flexibility to deploy combinations of certified explosive ordinance technicians with mobile
explosive screening technologies, including during local National Special Security Events. This
screening technology will be coupled with mobile explosive screening technologies. Each MEST
should have a minimum of two members and one mobile explosive screening apparatus.
Note: Funds for canine teams may not be used to fund drug detection and apprehension technique
training. Only explosives detection training for the canine teams will be funded.
TSGP Appendix | February 2021
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Funding Availability for OPacks
OPacks have the potential to be funded for up to a 36-month period from the award date. The monetary
figures presented below are stated in terms of cost per period of performance (which indicates
actual/complete funding for the 36-month period). Additionally, any OPack costs after the 36-month
period of performance (including expenses related to the maintenance, personnel, equipment, etc.) are the
responsibility of the applicable transit system. If these positions are not sustained, the public
transportation agency may not be eligible for this personnel support in the future. The table below
identifies the maximum funding available for the different OPack types.
Available Funding for OPacks
Operational Package
Maximum Funding per Year
(12 months)
Maximum Funding per Period of
Performance (36 months)
EDCT
$150,000 per team
$450,000 per team
ATT
$500,000 per team
$1,500,000 per team
MEST
$600,000 per team
$1,800,000 per team
OPack Requirements
TSGP OPack funds may be used for new positions or to sustain existing capabilities/programs (e.g.,
canine teams) already supported by the recipient. Applicants submitting IJs for both new OPacks and
sustainment funding for existing OPacks must clearly indicate which is their highest priority if funding is
available for only one of the IJs. Additionally, applicants must provide the number of existing teams
(EDCT, ATT, and MEST) already in place with either in-house funding or TSGP funding. The table
below identifies specific OPack requirements.
OPack Requirements
Operational Package
Requirements
Explosives Detection Canine Teams
Please refer to the pages below for detailed information regarding
EDCTs under the TSGP
Five-Year Security Capital Plan and Operational Sustainment
Applicant requests for OPack funding must include the submission of a Five-Year Security Capital
and Operational Sustainment Plan in ND Grants. This plan must include how the agency proposes to
implement capital projects and demonstrate how the agency will sustain the operational investments
(including officers hired with federal funding) and capabilities after grant funding has been expended.
Requests for OPacks will not be funded if the applicant does not have a Security Capital and
Operational Sustainment Plan.
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Operational Package
Requirements
Anti-Terrorism Teams
Specific for the Canine Team within the ATT:
• Each canine team, composed of one dog and one handler,
must be certified by an appropriate, qualified organization
• Canines should receive an initial basic training course and
also weekly maintenance training sessions thereafter to
maintain the certification
• The basic training averages 10 weeks for the team, with
weekly training and daily exercising (comparable training and
certification standards, such as those promulgated by the
Transportation Security Administration (TSA) Explosive
Detection Canine Program), the National Police Canine
Association (NPCA), the United States Police Canine
Association (USPCA), or the International Explosive
Detection Dog Association (IEDDA) may be used to meet
this requirement
• The individuals hired for the covert and overt elements must
be properly trained law enforcement officers
• Certifications should be on file with the recipient and must be
made available to FEMA upon request
Mobile Explosives Screening Team
Certifications should be on file with the recipient and must be
made available to FEMA upon request
Allowable Expenses for OPacks
The below table identifies allowable expenses for the various OPacks. Please see the inserted notes for
clarification of certain allowable costs.
Allowable Expenses for OPacks
Operational Package
Salary and Fringe
Benefits
Training and
Certification
Equipment Costs
Purchase and Train
a Canine
Canine Costsb
1)
EDCT
✓
✓
✓
✓c
✓
2)
ATT
✓
✓
✓
✓
✓
3)
MEST
✓
✓d
a Travel costs associated with training for personnel, handlers, and canines are allowable
b Canine costs include but are not limited to veterinary, housing, and feeding costs
c One type of allowable training is training specific to the detection of common explosives odors.
d Equipment and other costs can include but are not limited to explosives detection; stainless steel search tables;
consumables such as gloves, swabs, and alcohol; and land mobile radios
Specific Guidance on EDCTs
EDCT Certification. Each EDCT, composed of one dog and one handler, must be certified by an
appropriate, qualified organization. TSA-certified EDCTs will meet or exceed certification standards set
by the TSA National Explosives Detection Canine Team Program (NEDCTP). Recipient EDCTs that do
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not participate in the NEDCTP will be required to certify annually under their respective agency, local
and state regulations. The recipient (i.e., TSGP-grant supported) will maintain certification, utilization,
and training data to show their compliance in meeting or exceeding those guidelines set forth by the
Scientific Working Group on Dog and Orthogonal Detection Guidelines (SWGDOG), as of September
14, 2007, in addition to requirements set forth in the NOFO.
EDCT Submission Requirements
1) The recipient will ensure that a written security procedure plan exists for the safekeeping of all
explosive training aids, including safe transportation. The recipient will document the removal,
use and return of explosive training aids used during training exercises or for any other reason.
The plan and all documentation must be made available to FEMA upon request.
2) The recipient will comply with requirements for the proper storage, handling and transportation
of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and
Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulation.
3) The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a
day, seven days per week on an on-duty or off-duty on call basis. If TSGP-funded EDCTs are not
available, other non-TSGP-funded EDCTs may be utilized for this response. The intent is to
provide maximum coverage during peak operating hours and to maintain the ability to promptly
respond to threats that affect public safety or mass transit operations.
4) EDCTs under this grant are single purpose and will be trained to detect “live” explosives only not
“simulated” explosives. EDCTs must not have received previous training to detect any other
substances.
5) Recipient EDCTs will ensure that each EDCT receives on-site proficiency training at a minimum
of four hours per week per duty cycle. This training shall include, but not be limited to mass
transit passenger cars, terminal/platform, luggage, freight/warehouse, and vehicles. Complete,
detailed, and accurate training records must be maintained for all proficiency training conducted
by each EDCT. These records must be made available to FEMA upon request.
6) The TSGP grant recipient will conduct appropriate training or other canine activities, within view
of the public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts
which affect public safety or mass transit operations. Recipient EDCTs will also ensure that such
activities include, over a period of time, a presence in operational areas of the mass transit system
during peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at
least 80% of their duty time, annually.
7) Recipient EDCTs will provide safe and sanitary kennel facilities for program canines, and these
costs may be allowable with prior approval by FEMA. This applies to kenneling canines at the
mass transit system, handlers’ residences or commercial boarding facilities. Canines must not be
left in makeshift accommodations or without proper supervision, protection and care. The
recipient will ensure that canines are transported on-duty and off-duty in vehicles configured with
adequate temperature control, padding and screening to ensure proper health, safety and security.
8) Recipient EDCTs will ensure that adequate routine and emergency veterinary care are provided
for all canines.
Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour notice
to ensure compliance with applicable federal regulations.
Equipment and Capital Projects
Equipment and Capital Projects address the Soft Targets/Crowded Places; Cybersecurity; Emergent
Threats; and Equipment/Capital Projects Priorities.
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Priority projects include Top Transit Asset List (TTAL) risk remediation and protection of other high-
risk, high-consequence areas or systems that have been identified through system-wide risk assessments.
•
Projects related to physical security enhancements at rail and bus stations in Urban Area Security
Initiative (UASI) jurisdictions including security cameras, security screening equipment for
people and baggage, and access control (e.g., fences, gates, barriers, etc.).
•
Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers,
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems,
process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment
support. Cybersecurity assessments are allowable.
Equipment Acquisition
TSGP funds must comply with IB 426. TSGP funds may be used for the following categories of
equipment. A comprehensive listing of allowable equipment categories and types is found in the DHS
Authorized Equipment List (AEL). These costs include:
•
Personal protection equipment
•
Explosive device mitigation and remediation equipment
•
Chemical, biological, radiological, nuclear, and explosive (CBRNE) operational search and
rescue equipment, logistical support equipment, reference materials, or incident response vehicles
•
Interoperable communications equipment
•
Components or systems needed to address flaws in the computerized systems that control
generators, switching stations, and electrical substations as well as other emerging threats to
infrastructure critical to the U.S. economy
•
Detection Equipment
•
Power equipment
•
Terrorism incident prevention equipment
•
Physical security enhancement equipment
Recipients and subrecipients may purchase equipment not listed on the AEL, but only if they first seek
and obtain prior approval from FEMA.
Unless otherwise noted, equipment must be certified as meeting required regulatory and FEMA-adopted
standards to be eligible for purchase using TSGP funds. Equipment must comply with the Occupational
Safety and Health Act requirement for certification of electrical equipment by a nationally recognized
testing laboratory and demonstrate compliance with relevant FEMA-adopted standards through a
supplier’s declaration of conformity with appropriate supporting data and documentation per International
Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One
and Two. Agencies must have all necessary certifications and licenses for the requested equipment, as
appropriate, prior its purchase. DHS adopted standards are found at https://www.dhs.gov/dhs-
implementation-statement-regarding-standard-terms-and-conditions-research-grants. In addition,
recipients that are using TSGP funds to support emergency communications equipment activities must
comply with the SAFECOM Guidance on Emergency Communications Grants, including provisions on
technical standards that ensure and enhance interoperable communications. This SAFECOM Guidance
can be found at https://www.cisa.gov/safecom.
Equipment: Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
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privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Cybersecurity Projects
TSGP funds may be used for projects that enhance the cybersecurity of:
•
Access controls, sensors, security cameras, badge/ID readers, ICS/SCADA systems, process
monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.)
•
Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable)
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help
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U.S.-based companies and SLTT governments defend their computer systems against unauthorized
access, exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat
indicators from sensitive and classified Government Furnished Information (GFI). DHS then shares those
indicators with accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to
block certain types of malicious traffic from entering a company’s networks. Groups interested in
subscribing to ECS must contract directly with a CSP in order to receive services. Please visit
http://www.cisa.gov/enhanced-cybersecurity-services for a current list of ECS CSP points of contact.
Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any TSGP funds for construction
or renovation projects. When applying for construction funds, including communications towers, at the
time of application, recipients must submit evidence of approved zoning ordinances, architectural plans,
and any other locally required planning permits. Additionally, recipients are required to submit a SF-424C
and budget detail citing the project costs and an SF-424D Form for standard assurances for the
construction project.
All construction and renovation projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients are also encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with their State Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects;
compliance with all state and local EHP laws and requirements).
Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in
DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction
108-1-1, instances must also be identified to the FEMA HQ Preparedness Officer within the first six
months of the award, regardless of the period of performance. Completed EHP review materials for
construction and communication tower projects must be submitted no later than 12 months before the end
of the period of performance. EHP policy guidance and the EHP Screening Form, can be found online at
https://www.fema.gov/media-library/assets/documents/90195. EHP review materials should be sent to
gpdehpinfo@fema.dhs.gov.
Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; Emergent
Threats; and Training and Awareness Campaign Priorities.
Training
TSGP funds may be used for the following training activities:
•
Training Topics. Priority topics include active shooter training, security training for employees,
and public awareness/preparedness campaigns.
•
Training Workshops. Grant funds may be used to plan and conduct training workshops to
include costs related to planning, meeting space and other meeting costs, facilitation costs,
materials and supplies, travel, and training plan development. Recipients are strongly encouraged
to use free public space/locations/facilities, whenever available, prior to the rental of
space/locations/facilities. Training should provide the opportunity to demonstrate and validate
skills learned, as well as to identify any gaps in these skills. Any training or training gaps,
including those for children and individuals with disabilities or access and functional needs,
should be identified in an After-Action Report/Improvement Plan (AAR/IP) and addressed in the
training cycle.
TSGP Appendix | February 2021
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•
Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or
contractors/consultants may be hired to support training-related activities. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R.
§§ 200.317-200.327. Reimbursement of these costs should conform with the policies of the state
or local unit(s) of government or the awarding agency, whichever is applicable. Such costs must
be included within the funding allowed for program management personnel expenses, which must
not exceed 10% of the total allocation. Dual compensation is unallowable. That is, an employee
of a unit of government may not receive compensation from their unit or agency of government
and from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such
work may benefit both activities. Personnel hiring, overtime, and backfill expenses are permitted
under this grant only to the extent that such expenses are for the allowable activities within the
scope of the grant.
•
Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, that are the direct result of attendance at FEMA and approved training
courses and programs are allowable. Reimbursement of these costs should follow the policies of
the state or local unit(s) of government or the awarding agency, whichever is applicable. In no
case is dual compensation allowable.
•
Travel. Domestic travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as
expenses by employees who are on travel status for official business related, approved training,
subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense.
•
Supplies. Supplies, items that are expended or consumed during the course of the planning and
conduct of the training project(s) (e.g., gloves and non-sterile masks), are allowable expenses.
•
Funds Used to Develop, Deliver, and Evaluate Training, including costs related to
administering the training, planning, scheduling, facilities, materials and supplies, reproduction of
materials, and equipment are allowable expenses. Training should provide the opportunity to
demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any
training or training gaps, including those for children and individuals with disabilities or access
and functional needs, should be identified in the AAR/IP and addressed in the training cycle.
Recipients are encouraged to use existing training rather than developing new courses. When developing
new courses, recipients are encouraged to apply the Analysis, Design, Development, Implementation, and
Evaluation (ADDIE) model of instruction design. Information on FEMA-approved training can found at
http://www.firstrespondertraining.gov/.
Awareness Campaigns
TSGP funds may be used for the development and implementation of awareness campaigns to raise
public awareness of indicators of terrorism and terrorism-related crime, and for associated efforts to
increase the sharing of information with public and private sector partners, including nonprofit
organizations. DHS currently sponsors or supports a number of awareness campaigns. Please review
materials, strategies and resources at https://www.dhs.gov/dhs-campaigns before embarking on the
development of an awareness campaign for local constituencies and stakeholders.
Note: DHS requires that all public and private sector partners wanting to implement and/or expand the
DHS “If You See Something, Say Something®” campaign using grant funds work directly with the DHS
Office of Partnership and Engagement (OPE). This will help ensure that the awareness materials (e.g.,
videos, posters, tri-folds, etc.) remain consistent with DHS’s messaging and strategy for the campaign and
compliant with the initiative’s trademark, which is licensed to DHS by the New York Metropolitan
Transportation Authority. Coordination with OPE, through the Campaign’s Office (seesay@hq.dhs.gov),
must be facilitated by the FEMA HQ Preparedness Officer.
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Exercises
Exercise activities address the Soft Targets/Crowded Places; Cybersecurity; Emergent Threats; and
Exercises Priorities.
TSGP funds may be used for the following exercise activities:
•
Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs
related to planning, meeting space, and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Exercises afford organizations the opportunity to validate
plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets
in a controlled, low-risk setting. Any shortcoming or gap identified, including those for children
and individuals with disabilities or access and functional needs, should be identified in an
effective corrective action program that includes development of improvement plans that are
dynamic documents, with corrective actions continually monitored and implemented as part of
improving preparedness through the exercise cycle.
•
Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support exercise-related activities. In order to be eligible for reimbursement, the costs for
hiring staff must conform to the policies of the non-federal entity and federal statutes, where
applicable. See, e.g., 2 C.F.R. § 200.430(a). The costs for hiring contractors or consultants must
comply with the applicable federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. The
costs for hiring staff, consultants, or contractors to support exercise-related activities costs must
be included within the funding allowed for program management personnel expenses, which must
not exceed 10% of the total allocation. Dual compensation is never allowable, meaning, in other
words, that an employee of a unit of government may not receive compensation from their unit or
agency of government and from an award for a single period of time (e.g., 1:00 p.m. to 5:00
p.m.), even though their work may benefit both entities. Personnel hiring, overtime, and backfill
expenses are permitted under this grant only to the extent that such expenses are for the allowable
activities within the scope of the grant.
•
Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, which are the direct result of time spent on the design, development and
conduct of exercises are allowable expenses. These costs are allowed only to the extent the
payment for such services is in accordance with the policies of the state or unit(s) of local
government and has the approval of the state or the awarding agency, whichever is applicable.
Dual compensation is never allowable.
•
Travel. Domestic travel costs are allowable as expenses by employees who are on travel status
for official business related to the planning and conduct of exercise project(s), subject to the
restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense.
•
Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective
equipment).
•
Other Items. These costs include the rental of space/locations for exercise planning and
executing, rental of equipment, etc. Recipients are encouraged to use free public
space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.
These also include costs that may be associated with inclusive practices and the provision of
reasonable accommodations and modifications to provide full access for children and adults with
disabilities.
Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly
related to managing and administering the award. Recipients may use up to 5% of the amount of the
award for their M&A.
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Current fiscal year TSGP funds may be used for the following M&A costs:
•
Hiring of full-time or part-time staff, including contractors and consultants, to execute the
following:
o Management of the current fiscal year TSGP Award
o Design and implementation of the current fiscal year TSGP submission meeting
compliance with reporting/data collection requirements, including data calls
o Information collection and processing necessary to respond to FEMA data calls
o Domestic-only travel expenses related to TSGP grant administration, in compliance with
2 C.F.R. Part 200
•
Acquisition of authorized office equipment, including personal computers or laptops for
TSGP M&A purposes
Allowable Indirect Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Unallowable Costs
Specific unallowable costs include:
•
Grant funds must comply with IB 426 and may not be used for the purchase of the following
equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft,
vessels, or vehicles of any kind with weapons installed. Additional prohibited equipment
expenditures include items unrelated to grant allowable activities, such as general-use software,
general-use computers and related equipment (other than for allowable M&A activities or
otherwise associated preparedness or response functions), general-use vehicles, and licensing
fees.
•
Personnel costs (except as detailed above).
•
Activities unrelated to the completion and implementation of the TSGP.
•
Other items not in accordance with the AEL or not previously listed as allowable costs.
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
TSGP Appendix | February 2021
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coverage, licenses and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing
capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program, and (3)
be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also be in support of equipment, training, and critical resources that have previously been
purchased with either federal grant or any other source of funding other than FEMA preparedness grant
program dollars.
Encouraged Use of Certain Products Produced in the United States
Pursuant to Executive Order 13858 “Strengthening Buy-American Preferences for Infrastructure
Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent
practicable and consistent with the law, iron and aluminum as well as steel, cement, and other
manufactured products produced in the United States, in projects funded by an award under this grant
program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation;
ports, including navigational channels; water resources projects; energy production, generation, and
storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity
transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane
distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water
infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care
that all procurements and contract actions are consistent with law, the Preparedness Grants Manual and
applicable appendices, the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§
200.317-200.326.
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Program Appendix E:
Intercity Bus Security Grant Program (IBSGP)
As a reminder, while this appendix contains IBSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the IBSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
IBSGP grant recipients may only use IBSGP grant funds for the purpose set forth in the Notice of
Funding Opportunity (NOFO), and all investments must be consistent with the statutory authority for the
award. Grant funds may not be used for matching funds for other federal awards, lobbying, or
intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used
to sue the Federal Government or any other government entity.
IBSGP Funding Guidelines
Costs charged to an IBSGP award must be consistent with the Uniform Administrative Requirements,
Cost Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more
information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400 regarding FEMA’s
implementation of these provisions prior to the recent 2020 revisions. For information on the recent
revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov and
www.performance.gov/CAP/grants/.
IBSGP Priorities
See the annual IBSGP NOFO.
Pre-Award Costs
Pre-award costs are not allowable and will not be approved, with the exception of costs resulting from
pre-award grant writing services provided by an independent contractor that shall not exceed $1,500. See
the IBSGP NOFO for more information.
Allowable Direct Costs
Specific investments made in support of the funding priorities discussed in the annual IBSGP NOFO
generally fall into one of the following six allowable expense categories:
1. Planning
2. Operational Activities
3. Equipment and Capital Projects
4. Training and Awareness Campaigns
5. Exercises
6. Management and Administration
The following provides guidance on allowable costs within each of these areas.
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Planning
Planning activities should address the Soft Targets/Crowded Places; Cybersecurity; Emergent Threats;
and Planning Priorities.
IBSGP funds may be used for the following types of planning activities:
•
Development and enhancement of system-wide security risk management plans, to include cyber
•
Development or further strengthening of continuity of operations plans, response plans, station
action plans, risk assessments, and asset-specific remediation plans
•
Development or further strengthening of security assessments, including multi-agency and multi-
jurisdictional partnerships and conferences to facilitate planning activities
•
Hiring of full- or part-time staff and contractors or consultants to assist with planning activities
only to the extent that such expenses are for the allowable activities within the scope of the grant
(not for the purpose of hiring public safety personnel); hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.
•
Materials required to conduct planning activities
•
Other project planning activities with prior approval from FEMA
Operational Activities
Operational Activities should address the Soft Targets/Crowded Places; and Emergent Threat Priorities.
FEMA encourages applicants to develop innovative operational approaches to enhance the security of
transportation systems. Examples include:
•
Establishing or improving emergency communication systems linking drivers and over-the-road
buses to company operation centers, law enforcement agencies or emergency response personnel
•
Acquiring and installing equipment or systems that collect, store or exchange passenger and/or
driver information with established government databases for security purposes
•
Implementing and operating established methodologies for screening passengers, their carry-on
baggage, and/or their checked baggage, for weapons and/or explosives
Equipment and Capital Projects
Equipment and Capital Projects should address the Soft Targets/Crowded Places; Cybersecurity;
Emergent Threats; and Equipment/Capital Projects Priorities.
Equipment – Vehicle/Driver Security Enhancements
Vehicle Security Enhancements focus on vehicle disabling and anti-theft devices, real-time bus inventory
and inventory control, tracking, monitoring, and locating technologies. Driver security enhancements
focus on protection for the bus driver to prevent would-be terrorists from immobilizing the driver and/or
hijacking the bus. Applicants are discouraged from submitting projects that propose the use of closed-
circuit television (CCTV) alone as an on-board deterrent to terrorism. Rather, any cameras should have
the capability and protocols in place for incident-based real-time monitoring. CCTV Systems that are
primarily archival, and do not clearly specify the ability for live monitoring in the Investment Justification
(IJ) will not be funded.
Capital Projects – Facility Security Enhancements
•
Projects related to physical security enhancements at bus stations, or operator-owned facilities
including but not limited to lighting, security cameras, security screening equipment for people
and baggage, and access control (e.g., fences, gates, barriers).
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•
Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers,
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems,
process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment
support. Cybersecurity assessments are allowable.
•
Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or
contractors/consultants may be hired to support security enhancement-related activities. Personnel
hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such
expenses are for the allowable activities within the scope of the grant. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R.
§§ 200.317-200.327.
Note: All Capital and Vehicle/Driver security enhancement projects that include cameras, video
surveillance, or alarm systems MUST either be live monitored 24/7 or have the capability for real-time
incident-based monitoring. CCTV Systems that are primarily archival and do not clearly specify the
ability for live monitoring in the IJ will not be funded.
Equipment Acquisition
IBSGP funds must comply with IB 426 and may be used for the following categories of equipment. A
comprehensive listing of allowable equipment categories and types is found in the DHS Authorized
Equipment List (AEL). These costs include:
•
Personal protection equipment
•
Explosive device mitigation and remediation equipment
•
Chemical, biological, radiological, nuclear, and explosive (CBRNE) operational search and
rescue equipment, or logistical support equipment
•
Interoperable emergency communications equipment
•
Detection equipment
•
Terrorism incident prevention equipment
•
Physical security enhancement equipment
Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior
approval from FEMA.
Unless otherwise noted, equipment must be certified as meeting required regulatory and DHS- adopted
standards to be eligible for purchase using these funds. Equipment must comply with the Occupational
Safety and Health Act requirement for certification of electrical equipment by a nationally recognized
testing laboratory and demonstrate compliance with relevant DHS-adopted standards through a supplier’s
declaration of conformity with appropriate supporting data and documentation per International
Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One
and Two. Agencies must have all necessary certifications and licenses for the requested equipment, as
appropriate, prior to the request. In addition, recipients that are using IBSGP funds to support emergency
communications equipment activities must comply with the SAFECOM Guidance on Emergency
Communications Grants, including provisions on technical standards that ensure and enhance
interoperable communications. SAFECOM Guidance can be found at: https://www.cisa.gov/safecom.
Cybersecurity Projects
IBSGP funds may be used for projects that enhance the cybersecurity of:
•
Access controls; sensors; security cameras; badge/ID readers; ICS/SCADA systems; process
monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.).
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CCTV Systems that are primarily archival, and do not clearly specify the ability for live
monitoring in the IJ will not be funded.
•
Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (“The
Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at http://www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Cybersecurity Framework. Specifically, ECS offers intrusion prevention and analysis services that help
U.S.-based companies and state, local, tribal, and territorial (SLTT) governments defend their computer
systems against unauthorized access, exploitation, and data exfiltration. ECS works by sourcing timely,
actionable cyber threat indicators from sensitive and classified Government Furnished Information (GFI).
DHS then shares those indicators with accredited Commercial Service Providers (CSPs). Those CSPs in
turn use the indicators to block certain types of malicious traffic from entering a company’s networks.
Groups interested in subscribing to ECS must contract directly with a CSP in order to receive services.
Please visit http://www.cisa.gov/enhanced-cybersecurity-services for a current list of ECS CSP points of
contact.
Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any IBSGP funds for construction
or renovation projects. When applying for construction funds, including communications towers, at the
time of application, recipients must submit evidence of approved zoning ordinances, architectural plans,
any other locally required planning permits. Additionally, recipients are required to submit a SF-424C and
budget detail citing the project costs and an SF-424D Form for standard assurances for the construction
project.
All Capital (Construction) projects require Environmental Planning and Historic Preservation (EHP)
review. Recipients are also encouraged to have completed as many steps as possible for a successful EHP
review in support of their proposal for funding (e.g., coordination with their State Historic Preservation
Office to identify potential historic preservation issues and to discuss the potential for project effects;
compliance with all state and EHP laws and requirements).
Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in
DHS Instruction Manual 023-01-001-01, Revision 01, FEMA Directive 108-1 and FEMA Instruction
108-1-1, instances must also be identified to the FEMA HQ Preparedness Officer within the first six
months of the award. Completed EHP review materials for construction and communication tower
projects must be submitted no later than 12 months before the end of the period of performance. EHP
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policy guidance and the EHP Screening Form, can be found online at: https://www.fema.gov/media-
library/assets/documents/90195. EHP review materials should be sent to gpdehpinfo@fema.gov.
Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; Emergent
Threats; and Training and Awareness Campaign Priorities.
Training
IBSGP funds may be used for the following training activities:
•
Training Topics. Priority topics include active shooter training, security training for employees,
and public awareness/preparedness campaigns. The IJ narrative for Training should include:
o A course syllabus, curriculum, or topic plan identifying the proposed course material and
contents; and
o Provide the total cost of the training course, the number of participants, and the cost per
participant breakdown.
•
Training Workshops. Grant funds may be used to plan and conduct training workshops or
conferences including costs related to planning, meeting space and other meeting costs,
facilitation costs, materials and supplies, travel, and training plan development.
•
Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support training-related activities. Hiring of contractors/consultants must follow the
applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. The services of
contractors/consultants may also be procured in the design, development, conduct, and evaluation
of CBRNE training. Personnel hiring, overtime, and backfill expenses are permitted under this
grant only to the extent that such expenses are for the allowable activities within the scope of the
grant.
•
Overtime and Backfill Costs. Overtime and backfill costs associated with the design,
development, and conduct of training are allowable expenses. Payment of overtime expenses will
be for work performed by recipient or subrecipient employees in excess of the established work
week related to the planning and conduct of the training project(s). Furthermore, overtime
payments and backfill costs associated with sending personnel to training are allowable. Grant
funds cannot be used for personnel or direct salary costs for employees to attend training sessions.
Recipients seeking to claim overtime or backfill costs will be required to submit verification.
Straight time costs are not eligible expenses.
•
Travel. Domestic travel costs (e.g., airfare, mileage, per diem, hotel, etc.) are allowable as
expenses by employees who are on travel status for official business related to the planning and
conduct of the training project(s) or for attending courses. These costs must be in accordance with
applicable state law and regulations as well as the principles at 2 C.F.R. Part 200. International
travel is not an allowable cost under IBSGP.
•
Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the training project(s) (e.g., copying paper, gloves, tape, and non-sterile masks).
•
Funds Used to Develop, Deliver, and Evaluate Training, including costs related to
administering the training, planning, scheduling, facilities, materials and supplies, reproduction of
materials, and equipment are allowable expenses. Training should provide the opportunity to
demonstrate and validate skills learned, as well as to identify any gaps in these skills. Any
training or training gaps, including those for individuals with disabilities or access and functional
needs, should be identified in the AAR/IP and addressed in the training cycle.
•
Developing New Courses. Recipients are encouraged to use existing training rather than
developing new courses. When developing new courses, recipients are encouraged to apply the
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Analysis, Design, Development, Implementation, and Evaluation (ADDIE) model of instructional
design. Information on FEMA-approved training can found at the following website
•
Other Items. These costs include the rental of space/locations for planning and conducting
training, badges, etc. Recipients are encouraged to use free public space/locations, whenever
available, prior to the rental of space/locations.
Awareness Campaigns
IBSGP funds may be used for the development and implementation of awareness campaigns to raise
public awareness of indicators of terrorism and terrorism-related crime, and associated efforts to increase
the sharing of information with public and private sector partners, including nonprofit organizations. DHS
currently sponsors or supports a number of awareness campaigns. Please review materials, strategies and
resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness
campaign for your local constituencies and stakeholders.
Note: DHS requires that all public and private sector partners wanting to implement and/or expand the
DHS “If You See Something, Say Something®” campaign using grant funds work directly with the DHS
Office of Partnership and Engagement (OPE). This will help ensure that the awareness materials (e.g.,
videos, posters, tri-folds, etc.) remain consistent with the Department’s messaging and strategy for the
campaign and compliant with the initiative's trademark, which is licensed to DHS by the New York
Metropolitan Transportation Authority. Coordination with OPE, through the Campaign’s Office
(seesay@hq.dhs.gov), must be facilitated by the FEMA HQ Preparedness Officer.
Exercises
Exercise activities should address the Soft Targets/Crowded Places; Cybersecurity; Emergent Threats;
and Exercises Priorities.
IBSGP funds may be used for the following exercise activities:
•
Funds Used to Design, Develop, Conduct, and Evaluate an Exercise. This includes costs
related to planning, meeting space, and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Exercises afford organizations the opportunity to validate
plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets
in a controlled, low-risk setting. Any shortcoming or gap identified, including those for children
and individuals with disabilities or access and functional needs, should be identified in an
effective corrective action program that includes development of improvement plans that are
dynamic documents, with corrective actions continually monitored and implemented as part of
improving preparedness through the exercise cycle.
•
Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support exercise-related activities. The services of contractor/consultant staff may be
procured to support exercise-related activities. The services of contractors/consultants may also
be procured to support the design, development, conduct, and evaluation of terrorism exercises.
Hiring of contractors/consultants must follow the applicable federal procurement requirements at
2 C.F.R. §§ 200.317-200.327.
•
Overtime and Backfill Costs. Overtime and backfill costs associated with the design,
development, and conduct of terrorism exercises are allowable expenses. Payment of overtime
expenses will be for work performed in excess of the established work week related to the
planning and conduct of the exercise project(s). Further, overtime payments and backfill costs
associated with sending personnel to exercises are allowable, provided that the event being
attended is a DHS sponsored exercise. For positions not funded by the grant award, grant funds
cannot be used for personnel or straight salary costs for employees to attend exercises, meaning
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straight time costs for non-grant funded employees to attend exercise are not allowable. Instead,
for positions not funded by the grant award, only overtime and backfill costs will be allowable for
those employees to attend exercises. Recipients seeking to claim overtime or backfill costs will be
required to submit verification.
•
Travel. Domestic travel costs (e.g., airfare, mileage, per diem, hotel, etc.) are allowable as
expenses by employees who are on travel status for official business related to the planning and
conduct of the exercise project(s). International travel is not allowable under this program.
•
Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective
equipment).
•
Other Items. These costs include the rental of space/locations for exercise planning and
executing, rental of equipment, etc. Recipients are encouraged to use free public
space/locations/facilities, whenever available, prior to the rental of space/locations/facilities.
These also include costs that may be associated with inclusive practices and the provision of
reasonable accommodations and modifications to provide full access for children and adults with
disabilities.
Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly
related to managing and administering the award. Recipients may use up to 5% of the amount of the
award for their M&A.
Current fiscal year IBSGP funds may be used for the following M&A costs:
•
Hiring of full-time or part-time staff including contractors and consultants, to execute the
following:
o Management of the current fiscal year IBSGP award
o Design and implementation of the current fiscal year IBSGP submission meeting
compliance with reporting/data collection requirements, including data calls
•
Information collection and processing necessary to respond to FEMA data calls
•
Domestic travel expenses related to IBSGP grant administration
Indirect Costs (Facilities and Administration [F&A])
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
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Unallowable Costs
Specific unallowable costs include:
•
Grant funds must comply with IB 426 and may not be used for the purchase of the following
equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels,
or vehicles of any kind with weapons installed.
•
General-use facility expenditures, to include, but not limited to ordinary facility maintenance,
contracts for maintenance, and specifically backup or emergency generators.
•
General vehicle maintenance, service contracts, or warranties. This is different from maintenance
and sustainment costs that are allowable, but only for projects funded under a grant award. For
projects or equipment not funded by the grant award, general maintenance, service contracts, and
warranties are not allowable.
•
Expenditures for items such as general-use software (word processing, spreadsheet, graphics,
etc.), general-use computers and related equipment (other than for allowable M&A activities, or
otherwise associated preparedness or response functions), general-use vehicles, licensing fees,
recurring operating costs (e.g., cell phone services, maintenance contracts).
•
Organizational operating expenses.
•
Personnel costs, to include, but not limited to, overtime and backfill (except as detailed above).
•
Activities unrelated to the completion and implementation of the IBSGP.
•
Other indirect costs (meaning property purchase, depreciation, or amortization expenses).
•
Initiatives in which federal agencies are the beneficiary or that enhance federal property.
•
Initiatives which study technology development.
•
Proof-of-concept initiatives.
•
Initiatives that duplicate capabilities being provided by the Federal Government.
•
Other items not in accordance with the AEL, in accordance with IB 426, or not previously listed
as allowable costs.
•
Pre-award costs are not allowable and will not be approved, with the exception of costs resulting
from pre-award grant writing services provided by an independent contractor that shall not
exceed $1,500, as detailed in “Pre-Award Costs” above and in the IBSGP NOFO.
Other Allowable Costs
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal (the Goal) and fund projects that
build and sustain the core capabilities necessary to prevent, protect against, mitigate the effects of,
respond to, and recover from those threats that pose the greatest risk to the security of the Nation. In order
to provide recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
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the expansion of eligible maintenance and sustainment costs which must be in (1) direct support of
existing capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program,
and (3) be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally,
eligible costs may also be in support of equipment, training, and critical resources that have previously
been purchased with either federal grant or any other source of funding other than FEMA preparedness
grant program dollars.
Bonds
Financial markets are not always predictable, and commercial suppliers are not always reliable; but there
are options to provide resource contingencies to support an IBSGP award.
•
Prepayment Bond: Prepayment Bonds provide a measure of economic security for an
organization that is going to advance funds to a vendor(s). The prepayment bond generally may
be obtained through the vendor or bank. The prepayment bond protects funds in the event a
vendor fails to perform (e.g., not finishing/delivering contracted service/equipment, or going out
of business). Prepayment bonds are chargeable to an award.
o Encouraged Prepayment Bond: Recipients are strongly recommended, but not
required, to obtain a prepayment bond for awarded acquisition activities that exceed the
Simplified Acquisition Threshold (SAT) (currently $250,000, but the applicable dollar
threshold will be the SAT amount in place at the time of procurement) when recipients
are contractually required to advance a down payment and when such advances contain
no federal funds (only local funds).
o Required Prepayment Bond: Per 2 C.F.R. § 200.304(b), recipients are required to
obtain a prepayment bond for awarded acquisition activities that exceed the SAT; a
prepayment bond is required when recipients are contractually required to advance a
down payment and when such advances contain only federal funds or a combination of
federal and local funds.
•
Fidelity Bond: Reasonable costs of fidelity bonds (or like insurance as provided for by applicable
state or tribal laws) covering the maximum amount of IBSGP funds the officer, official, or
employee handles at any given time for all personnel who disburse or approve disbursement of
IBSGP funds may be allowable if required by the terms and conditions of the award or if
generally required by the tribe in its generally operations. If a fidelity bond is required by a
recipient in its general operations, those costs must be charged as indirect costs. See 2 C.F.R. §
200.427.
Encouraged Use of Certain Products Produced in the United States
Pursuant to Executive Order 13858 “Strengthening Buy-American Preferences for Infrastructure
Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent
practicable and consistent with the law, iron and aluminum as well as steel, cement, and other
manufactured products produced in the United States, in projects funded by an award under this grant
program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation;
ports, including navigational channels; water resources projects; energy production, generation, and
storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity
transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane
distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water
infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care
that all procurements and contract actions are consistent with law, this Manual and applicable appendices,
the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§ 200.317-200.326.
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Program Appendix F:
Intercity Passenger Rail (IPR) Program
As a reminder, while this appendix contains IPR-specific information and requirements, the main content
of this Manual (non-appendix information) contains important information relevant to all preparedness
grant programs, including the IPR. Please be sure to read the main content of this Manual in addition to
the program-specific appendices.
The IPR grant recipient may only use IPR grant funds for the purposes set forth in the Notice of Funding
Opportunity (NOFO), and all investments must be consistent with the statutory authority for the award.
Grant funds may not be used for matching funds for other federal awards, lobbying, or intervention in
federal regulatory or adjudicatory proceedings. In addition, federal funds may not be used to sue the
Federal Government or any other government entity.
IPR Funding Guidelines
Costs charged to a an IPR award must be consistent with the uniform administrative requirements and
audit requirements for federal awards, located at 2 C.F.R. Part 200, Subparts A-D and F. For more
information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400 regarding FEMA’s
implementation of these provisions prior to the recent 2020 revisions. For information on the recent
revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov and
www.performance.gov/CAP/grants/. Costs charged to an IPR award must also be consistent with the cost
principles in the Federal Acquisition Regulation (FAR) Part 31.2 in lieu of 2 C.F.R. Part 200, Subpart E.
Any conflicts between FAR 31.2 and 2 C.F.R. Part 200, Subpart E shall be resolved in favor of the
applicable provision in FAR 31.2.
IPR Priorities
See the annual IPR NOFO.
Security Plan Requirements
The following information regarding security plan requirements is provided in 6 U.S.C. § 1134(c)(2):
Security plans should include the following, as appropriate:
•
A prioritized list of all items included in the public transportation agency’s security assessment
that have not yet been addressed;
•
A detailed list of any additional capital and operational improvements identified by DHS or the
public transportation agency and a certification of the public transportation agency’s technical
capacity for operating and maintaining any security equipment that may be identified in such list;
•
Specific procedures to be implemented or used by the public transportation agency in response to
a terrorist attack, including evacuation and passenger communication plans and appropriate
evacuation and communication measures for the elderly and individuals with disabilities;
•
A coordinated response plan that establishes procedures for appropriate interaction with state and
local law enforcement agencies, emergency responders, and federal officials in order to
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coordinate security measures and plans for response in the event of a terrorist attack or other
major incident;
•
A strategy and timeline for conducting training under 49 C.F.R. § 1570.109(b) and 49 C.F.R. Part
1580;
•
Plans for providing redundant and other appropriate backup systems necessary to ensure the
continued operation of critical elements of the public transportation system in the event of a
terrorist attack or other major incident;
•
Plans for providing service capabilities throughout the system in the event of a terrorist attack or
other major incident in the city or region which the public transportation system serves;
•
Methods to mitigate damage within a public transportation system in case of an attack on the
system, including a plan for communication and coordination with emergency responders; and
•
Other actions or procedures as the Secretary of Homeland Security determines are appropriate to
address the security of the system.
Allowable Costs
Specific investments made in support of the funding priorities discussed in the annual IPR NOFO
generally fall into one of the following six allowable expense categories:
1) Planning
2) Operational Activities
3) Equipment and Capital Projects
4) Training and Awareness Campaigns
5) Exercises
6) Management and Administration
The following provides guidance on allowable costs within each of these areas.
Planning
Planning activities that address the Soft Targets/Crowded Places; Cybersecurity; and Emergent Threats
Priorities.
IPR funds may be used for the following types of planning activities:
•
Development and enhancement of system-wide security risk management plans, to include cyber;
•
Development or further strengthening of continuity of operations plans, response plans, station
action plans, risk assessments, and asset-specific remediation plans;
•
Development or further strengthening of security assessments, including multi-agency and multi-
jurisdictional partnerships and conferences to facilitate planning activities;
•
Hiring of full or part-time staff and contractors or consultants to assist with planning activities
only to the extent that such expenses are for the allowable activities within the scope of this grant
(not for the purpose of hiring public safety personnel); hiring of contractors/consultants must
follow the applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327.
•
Materials required to conduct planning activities; and
•
Other project planning activities, with prior approval from FEMA.
Operational Activities
Operational Activities that address the Soft Targets/Crowded Places; and Emergent Threat Priorities.
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FEMA encourages applicants to develop innovative operational approaches to enhance the security of
transit systems. Projects that use visible, unpredictable deterrence, including operational packages dealing
with explosive detection canine teams, mobile screening teams, and anti-terrorism teams, directly support
enhancing the protection of soft targets and crowded places. Implementation of one of the three
Operational Package (OPack) models discussed below complements existing security systems and
provides an appropriate, practical, and cost-effective means of protecting assets.
Agencies may submit IJs to fund transit security police forces/law enforcement providers for patrols and
activities on overtime, such as directed patrols, additional canine teams, mobile screening teams, or anti-
terrorism team patrols. These activities must be dedicated to the transit environment and must be anti-
terrorism in nature. Agencies must identify the type of activity, length of operation (hours), number of
personnel, and cost based on length of operation and personnel. Agencies should also provide a risk-based
justification for the request, including linkage to a known event, such as hosting a significant regional
sporting or political event; or a period of heightened awareness, such as a national holiday. Three OPack
types have been developed to support operational activities and are available for funding under the IPR:
•
Explosives Detection Canine Teams (EDCTs). When combined with the existing capability of a
transit security/police force, the added value provided through the addition of an EDCT is
significant. EDCTs are a proven, reliable resource to detect explosives and are a key component
in a balanced counter-sabotage program. The TSGP will provide funds to establish dedicated
security/police force canine teams. Each canine team will be composed of one dog and one
handler.
•
Anti-Terrorism Teams (ATTs). The ATT capability provided through TSGP funding is for
uniformed, dedicated transit patrols on a normal operational basis, rather than using teams only
for a surge capacity as provided by FEMA in the past. ATTs do not supersede other local transit
security forces; rather, they augment current capabilities. Each ATT will consist of four
individuals, including two overt elements (e.g., uniformed transit sector law enforcement officer,
canine team, mobile explosive screeners), and two discreet observer elements.
•
Mobile Explosive Screening Teams (MESTs). The MEST OPack will allow recipients the
flexibility to deploy combinations of certified explosive ordinance technicians with mobile
explosive screening technologies, including during local National Special Security Events. This
screening technology will be coupled with mobile explosive screening technologies. Each MEST
should have a minimum of two members and one mobile explosive screening apparatus.
Note: Funds for canine teams may not be used to fund drug detection and apprehension technique
training. Only explosives detection training for the canine teams will be funded.
Five-Year Security Capital Plan and Operational Sustainment
Applicant requests for OPack funding must include the submission of a Five-Year Security Capital
and Operational Sustainment Plan in ND Grants. This plan must include how the agency proposes to
implement capital projects and demonstrate how the agency will sustain the operational investments
(including officers hired with federal funding) and capabilities after grant funding has been expended.
Requests for OPacks will not be funded if the applicant does not have and submit a Security Capital
and Operational Sustainment Plan.
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Funding Availability for OPacks
OPacks have the potential to be funded for up to a 36-month period from the award date. The monetary
figures presented below are stated in terms of cost per period of performance (which indicates
actual/complete funding for a 36-month period). Additionally, any OPack costs after the period of
performance (including expenses related to the maintenance, personnel, equipment, etc.) are the
responsibility of the applicable transit system. Additional funding may be applied for in future grant
cycles to maintain this operational capability, but future funding is not guaranteed and requires approval.
If these positions are not sustained, the public transportation agency may not be eligible for this personnel
support in the future. The table below identifies the maximum funding available for the different OPack
types.
Available Funding for OPacks
Operational Package
Maximum Funding per Year
(12 months)
Maximum Funding per Period of
Performance (36 months)
EDCT
$150,000 per team
$450,000 per team
ATT
$500,000 per team
$1,500,000 per team
MEST
$600,000 per team
$1,800,000 per team
OPack Requirements
IPR OPack funds may be used for new positions or to sustain existing capabilities/programs (e.g., canine
teams) already supported by the recipient. Applicants pursuing both new OPacks and sustainment funding
for existing OPacks must indicate in their IJs which funding the higher priority for their agency is.
Additionally, applicants must provide the number of existing teams (EDCT, ATT, and MEST) already in
place, regardless of how they are funded. The below table identifies specific OPack requirements.
OPack Requirements
Operational
Requirements
EDCT
Please refer to the pages below for detailed information regarding EDCTs
under the IPR
ATT
Specific for the Canine Team within the ATT:
• Each canine team, composed of one dog and one handler, must be certified
by an appropriate, qualified organization
• Canines should receive an initial basic training course and also weekly
maintenance training sessions thereafter to maintain the certification
• The basic training averages 10 weeks for the team, with weekly training and
daily exercising (comparable training and certification standards, such as
those promulgated by the Transportation Security Administration (TSA)
Explosive Detection Canine Program), the National Police Canine
Association (NPCA), the United States Police Canine Association
(USPCA), or the International Explosive Detection Dog Association
(IEDDA) may be used to meet this requirement
• The individuals hired for the covert and overt elements must be properly
trained law enforcement officers
• Certifications should be on file with the recipient and must be made
available to FEMA upon request
MEST
Certifications should be on file with the recipient and must be made available
to FEMA upon request
IPR Appendix | February 2021
Page F-5
Allowable Expenses for OPacks
The table below identifies allowable expenses for the various OPacks. Please see the accompanying notes
for clarification of certain allowable costs.
Allowable Expenses for OPacks
Operational Package
Salary and Fringe
Benefits
Training and
Certification
Equipment Costs
Purchase and Train
a Canine
Canine Costs
1)
EDCT
✓
✓
✓
✓c
✓
2)
ATT
✓
✓
✓
✓
✓
3)
MEST
✓
✓d
a Travel costs associated with training for personnel, handlers, and canines are allowable
b Canine costs include but are not limited to a canine’s veterinary, housing, and feeding costs
c One type of allowable training is training specific to the detection of common explosives odors
d Equipment and other costs can include but are not limited to explosives detection; stainless steel search tables;
consumables such as gloves, swabs, and alcohol; and land mobile radios
Specific Guidance on EDCT
EDCT Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified
organization. TSA-certified EDCTs will meet or exceed certification standards set by the TSA National
Explosives Detection Canine Team Program (NEDCTP). Recipient EDCTs that do not participate in the
NEDCTP will be required to certify annually under their respective agency, local, and state regulations.
The recipient will maintain certification, utilization, and training data to show compliance in meeting or
exceeding those guidelines set forth by the Scientific Working Group on Dog and Orthogonal Detection
Guidelines (SWGDOG), as of September 14, 2007, in addition to the requirements set forth in the NOFO.
EDCT Submission Requirements
1) The recipient will ensure that a written security procedure plan exists for the safekeeping of all
explosive training aids, including safe transportation. The recipient will document the removal,
use, and return of explosive training aids used during training exercises or for any other reason.
The plan and all documentation must be made available to FEMA upon request.
2) The recipient will comply with requirements for the proper storage, handling, and transportation
of all explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and
Explosives’ Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulation.
3) The recipient will ensure that certified EDCTs are available to respond to situations 24 hours a
day, 7 days per week on an on-duty or off-duty on-call basis. If IPR-funded EDCTs are not
available, other, non-IPR funded EDCTs may be utilized for this response. The intent is to
provide maximum coverage during peak operating hours and to maintain the ability to promptly
respond to threats that affect public safety or mass transit operations.
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Page F-6
4) EDCTs under this grant are single purpose and will be trained to detect “live” explosives only,
not “simulated” explosives. EDCTs must not have received previous training to detect any other
substances.
5) The recipient will ensure that each EDCT receives on-site proficiency training at a minimum of 4
hours per week per duty cycle. This training shall include, but not be limited to, mass transit
passenger cars, terminals/platforms, luggage, freight/warehouses, and vehicles. Complete,
detailed, and accurate training records must be maintained for all proficiency training conducted
by each EDCT. These records must be made available to FEMA upon request.
6) The recipient will conduct appropriate training or other canine activities, within view of the
public, to increase public awareness of EDCTs and provide a noticeable deterrent to acts which
affect public safety or mass transit operations. The recipient will also ensure that such activities
include, over a period of time, a presence in operational areas of the mass transit system during
peak and off-peak hours. The recipient agrees that EDCTs will be utilized in the field at least 80%
of their duty time, annually.
7) The recipient will provide safe and sanitary kennel facilities for program canines, and these costs
may be allowable with prior approval by FEMA. This applies to kenneling canines at a mass
transit system, handlers’ residences, or commercial boarding facilities. Canines must not be left in
makeshift accommodations or without proper supervision, protection, and care. The recipient will
ensure that canines are transported on-duty and off-duty in vehicles configured with adequate
temperature control, padding, and screening to ensure proper health, safety, and security.
8) The recipient will ensure that adequate routine and emergency veterinary care are provided for all
canines.
Note: FEMA reserves the right to conduct an on-site operational and record review upon 48-hour notice
to ensure compliance with applicable federal regulations.
Equipment and Capital Projects
Equipment and Capital Projects that address the Soft Targets/Crowded Places; Cybersecurity; and
Emergent Threats Priorities.
Priority projects include Top Transit Asset List (TTAL) risk remediation and protection of other high-
risk, high-consequence areas or systems that have been identified through system-wide risk assessments:
•
Projects related to physical security enhancements at rail and bus stations in Urban Area Security
Initiative (UASI) jurisdictions, including security cameras, security screening equipment for
people and baggage, and access control (e.g., fences, gates, barriers, etc.).
•
Projects related to cybersecurity of access control, sensors, security cameras, badge/ID readers,
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems,
process monitors and controls, etc. or passenger/vehicle/cargo security screening equipment
support. Cybersecurity assessments are allowable.
Equipment Acquisition
IPR funds may be used for the following categories of equipment. A comprehensive listing of allowable
equipment categories and types is found in the DHS Authorized Equipment List (AEL). These costs
include:
•
Personal protection equipment
•
Explosive device mitigation and remediation equipment
•
Chemical, biological, radiological, nuclear, and high explosive (CBRNE) operational search and
rescue equipment, logistical support equipment, reference materials, or incident response vehicles
•
Interoperable communications equipment
IPR Appendix | February 2021
Page F-7
•
Components or systems needed to address flaws in the computerized systems that control
generators, switching stations, and electrical substations as well as other emerging threats to
infrastructure critical to the U.S. economy
•
Detection Equipment
•
Power equipment
•
Terrorism incident prevention equipment
•
Physical security enhancement equipment
Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior
approval from FEMA.
Unless otherwise noted, equipment must be certified as meeting required regulatory and FEMA- adopted
standards to be eligible for purchase using IPR funds. Equipment must comply with the Occupational
Safety and Health Act requirement for certification of electrical equipment by a nationally recognized
testing laboratory and demonstrate compliance with relevant FEMA-adopted standards through a
supplier’s declaration of conformity with appropriate supporting data and documentation per International
Organization for Standardization/International Electro-technical Commission (ISO/IEC) 17050, Parts One
and Two. The recipient must have all necessary certifications and licenses for the requested equipment, as
appropriate, prior its purchase. In addition, if the recipient is using IPR funds to support emergency
communications equipment activities must comply with the SAFECOM Guidance on Emergency
Communications Grants, including provisions on technical standards that ensure and enhance
interoperable communications. This SAFECOM Guidance can be found at:
https://www.cisa.gov/safecom.
Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted you of an advisory guidance document issued by DHS, the
Department of Justice, the Federal Aviation Administration, and the Federal Communications
Commission: https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-
technologies. The purpose of the advisory guidance document is to help non-federal public and private
entities better understand the federal laws and regulations that may apply to the use of capabilities to
detect and mitigate threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
IPR Appendix | February 2021
Page F-8
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Cybersecurity Projects
IPR funds may be used for projects that enhance the cybersecurity of:
•
Access controls, sensors; security cameras, badge/ID readers, ICS/SCADA systems, process
monitors and controls (such as firewalls, network segmentation, predictive security cloud, etc.)
•
Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable)
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”), developed by the National Institute of Standards and Technology (NIST). The Framework
gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers ways to improve their programs, such as through better communication
with their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at www.cisa.gov/ccubedvp.
DHS’s Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in
protecting U.S.-based public and private entities and combines key elements of capabilities under the
“Detect” and “Protect” functions to deliver an impactful solution relative to the outcomes of the
Framework. Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based
companies and SLTT governments defend their computer systems against unauthorized access,
exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from
sensitive and classified Government Furnished Information. DHS then shares those indicators with
accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain
types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS
must contract directly with a CSP in order to receive services. Please visit http://www.cisa.gov/enhanced-
cybersecurity-services for a current list of ECS CSP points of contact.
Capital (Construction) Projects Guidance
The recipient must obtain written approval from FEMA prior to the use of any IPR funds for construction
or renovation projects. When applying for construction funds, including communications towers, the
recipient must submit evidence of approved zoning ordinances, architectural plans, any other locally
required planning permits. Additionally, the recipient is required to submit a SF-424C and budget detail
citing the project costs and an SF-424D Form for standard assurances for the construction project.
All construction or renovation projects require Environmental Planning and Historic Preservation (EHP)
review. The recipient is also encouraged to have completed as many steps as possible for a successful
EHP review in support of their proposal for funding (e.g., coordination with the relevant Historic
Preservation Office to identify potential historic preservation issues and to discuss the potential for project
effects; compliance with all state and local EHP laws and requirements).
IPR Appendix | February 2021
Page F-9
Projects for which the recipient believes an Environmental Assessment (EA) may be needed, as defined in
DHS Instruction Manual 023-01-001-01, Revision 01, EHP Directive and Instruction, FEMA Directive
108-1, and FEMA Instruction 108-1-1, must also be identified to the FEMA HQ Preparedness Officer
within the first six months of the award, regardless of the length of the period of performance. Completed
EHP review materials for construction and communication tower projects must be submitted no later than
12 months before the end of the period of performance. EHP policy guidance and the EHP Screening
Form, can be found online at: https://www.fema.gov/media-library/assets/documents/90195. EHP review
materials should be sent to gpdehpinfo@fema.dhs.gov.
If the recipient uses funds for construction projects, it must comply with the Davis-Bacon Act (codified as
amended at 40 U.S.C. §§ 3141 et seq.). See 6 U.S.C. § 1163(h) (cross-referencing 49 U.S.C. § 24312,
which cross-references Davis-Bacon). It must ensure that its contractors or subcontractors for
construction projects pay workers no less than the prevailing wages for laborers and mechanics employed
on projects of a character similar to the contract work in the civil subdivision of the state in which the
work is to be performed. Additional information regarding compliance with the Davis-Bacon Act,
including the Department of Labor (DOL) wage determinations, is available at
https://www.dol.gov/whd/govcontracts/dbra.htm.
Training and Awareness Campaigns
Training and Awareness Campaigns that address the Soft Targets/Crowded Places; Cybersecurity; and
Emergent Threats Priorities.
Training
IPR funds may be used for the following training activities:
•
Training Topics. Priority topics include active shooter training, security training for employees,
and public awareness/preparedness campaigns.
•
Training Workshops. Grant funds may be used to plan and conduct training workshops,
including costs related to planning, meeting space and other meeting costs, facilitation costs,
materials and supplies, travel, and training plan development. The recipient is strongly
encouraged to use free public space, locations, or facilities, whenever available, prior to the rental
of space, locations, or facilities. Training should provide the opportunity to demonstrate and
validate skills learned as well as to identify any gaps in these skills. Any training or training gaps,
including those for children and individuals with disabilities or access and functional needs,
should be identified in an After-Action Report/Improvement Plan (AAR/IP) and addressed in the
training cycle.
•
Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff or
contractors/consultants may be hired to support training-related activities. Reimbursement of
these costs should conform with the policies of recipient, as well as any applicable federal and
FEMA policies, rules, and regulations. Hiring of contractors/consultants must follow the
applicable federal procurement requirements at 2 C.F.R. §§ 200.317-200.327. Dual compensation
is unallowable, in other words, an employee of a unit of government may not receive
compensation from their unit or agency of government and from an award for a single period of
time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities. Personnel
hiring, overtime, and backfill expenses are permitted under this grant only to the extent that such
expenses are for allowable activities within the scope of the grant.
•
Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, that are the direct result of attendance at FEMA and approved training
courses and programs are allowable. Reimbursement of these costs should follow the policies of
IPR Appendix | February 2021
Page F-10
the recipient, as well as any applicable federal and FEMA policies, rules, and regulations. state.
Dual compensation is never allowable.
•
Travel. Domestic travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as
expenses by employees who are on travel status for official business related, approved training,
subject to the restrictions at 2 C.F.R. Part 200. International travel is not an allowable expense.
•
Supplies. Supplies, items that are expended or consumed during the course of the planning and
conduct of the training project(s) (e.g., gloves and non-sterile masks), are allowable expenses.
•
Funds Used to Develop, Deliver, and Evaluate Training. Funds used to develop, deliver, and
evaluate training, including costs related to administering the training, planning, scheduling,
facilities, materials and supplies, reproduction of materials, and equipment are allowable
expenses. Training should provide the opportunity to demonstrate and validate skills learned as
well as to identify any gaps in these skills. Any training or training gaps, including those for
children and individuals with disabilities or access and functional needs, should be identified in
the AAR/IP and addressed in the training cycle.
Recipients are encouraged to use existing training rather than developing new courses. When developing
new courses, recipients are encouraged to apply the Analysis, Design, Development, Implementation, and
Evaluation (ADDIE) model of instructional design. Information on FEMA-approved training can found at
http://www.firstrespondertraining.gov/.
Awareness Campaigns
IPR funds may be used for the development and implementation of awareness campaigns to raise public
awareness of indicators of terrorism and terrorism-related crime and for associated efforts to increase the
sharing of information with public and private sector partners, including nonprofit organizations. DHS
currently sponsors or supports a number of awareness campaigns. Please review materials, strategies, and
resources at https://www.dhs.gov/dhs-campaigns before embarking on the development of an awareness
campaign for local constituencies and stakeholders.
Note: DHS requires that all public and private sector partners wanting to implement and/or expand the
DHS “If You See Something, Say Something®” campaign (“campaign”) using grant funds work directly
with the DHS Office of Partnership and Engagement (OPE). This will help ensure that the awareness
materials (e.g., videos, posters, tri-folds, etc.) remain consistent with DHS’s messaging and strategy for
the campaign and compliant with the initiative’s trademark, which is licensed to DHS by the New York
Metropolitan Transportation Authority. Coordination with OPE, through the campaign’s office
(seesay@hq.dhs.gov), must be facilitated by the FEMA Preparedness Officer.
Exercises
Exercise activities that address the Soft Targets/Crowded Places; Cybersecurity; and Emergent Threats
Priorities.
IPR funds may be used for the following exercise activities:
•
Funds Used to Design, Develop, Conduct and Evaluate an Exercise. This includes costs
related to planning, meeting space and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Exercises afford organizations the opportunity to validate
plans and procedures, evaluate capabilities, and assess progress toward meeting capability targets
in a controlled, low-risk setting. Any shortcomings or gaps identified, including those for children
and individuals with disabilities or access and functional needs, should be identified in an
effective corrective action program that includes development of improvement plans that are
IPR Appendix | February 2021
Page F-11
dynamic documents, with corrective actions continually monitored and implemented as part of
improving preparedness through the exercise cycle.
•
Hiring of Full or Part-Time Staff or Contractors/Consultants. Full or part-time staff may be
hired to support exercise-related activities. Reimbursement of these costs should conform with
the policies of the recipient, as well as any applicable federal and FEMA policies, rules, and
regulations. Dual compensation is not allowable, meaning, in other words, that an employee of a
unit of government may not receive compensation from their unit or agency of government and
from an award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work
may benefit both entities. Personnel hiring, overtime, and backfill expenses are permitted under
this grant only to the extent that such expenses are for the allowable activities within the scope of
the grant. The recipient must follow all applicable procurement regulations at 2 C.F.R. Part 200
when procuring contractor services.
•
Overtime and Backfill Costs. The entire amount of overtime costs, including payments related
to backfilling personnel, which are the direct result of time spent on designing, developing, and
conducting exercises are allowable expenses. These costs are allowed only to the extent the
payment for such services is in accordance with the policies of the recipient and has the approval
of the awarding agency, if applicable. Dual compensation is never allowable.
•
Travel. Domestic travel costs are allowable as expenses by employees who are on travel status
for official business related to the planning and conduct of exercise project(s), subject to the
restrictions at 2 C.F.R. Part 200. International travel costs are not allowable expenses.
•
Supplies. Supplies are items that are expended or consumed during the course of the planning
and conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective
equipment).
•
Other Items. These costs include the rental of space or locations for exercise planning and
executing, rental of equipment, etc. The recipient is encouraged to use free public space,
locations, or facilities, whenever available, prior to the rental of space, locations, or facilities.
These also include costs that may be associated with inclusive practices and the provision of
reasonable accommodations and modifications to provide full access for children and adults with
disabilities.
Management and Administration (M&A)
Management and administration costs are allowed under this program. M&A costs are activities directly
related to managing and administering the award. The recipient may use up to 5% of the amount of the
award for its M&A costs.
Current fiscal year IPR funds may be used for the following M&A costs:
•
Hiring of full-time or part-time staff, including contractors and consultants, to execute the
following:
o Management of the current fiscal year IPR Award
o Design and implementation of the current fiscal year IPR submission meeting compliance
with reporting/data collection requirements, including data calls
•
Information collection and processing necessary to respond to FEMA data calls
•
Domestic travel expenses related to IPR grant administration, in compliance with the Super
Circular, 2 C.F.R. Part 200.
•
Acquisition of authorized office equipment, including personal computers or laptops for IPR
M&A purposes.
IPR Appendix | February 2021
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Indirect Costs
Indirect costs are allowable under this program as described in the Federal Acquisition Regulations
(FAR).
Unallowable Costs
Specific unallowable costs include:
•
Grant funds must comply with IB 426 and may not be used for the purchase of the following
prohibited equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized
aircraft, vessels, or vehicles of any kind with weapons installed. Expenditures for items
unrelated to grant allowable activities, such as general-use software, general-use computers and
related equipment (other than for allowable M&A activities or for other associated preparedness
or response functions), general-use vehicles, licensing fees, weapons systems, and ammunition
are also prohibited.
•
Personnel costs (except as detailed above or otherwise allowed by statute).
•
Activities unrelated to the completion and implementation of the IPR program.
•
Other items not in accordance with the AEL or not previously listed as allowable costs.
•
Costs related to any matching or cost share requirement for any other federal award
•
Costs related to lobbying or intervention in federal regulatory proceedings
•
Costs related to suing the Federal Government or any other government entity
•
Pre-award costs, unless approved in writing by FEMA and included in the grant award
•
Costs that are not consistent with the Cost Principles located in FAR 31.2, as applicable
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and to fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients with the ability to meet this objective, the policy set forth originally in IB 379: Guidance to
State Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows
for the expansion of eligible maintenance and sustainment costs that must be (1) in direct support of
existing capabilities, (2) an otherwise allowable expenditure under the applicable grant program, and (3)
tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also be in support of equipment, training, and critical resources that have previously been
purchased with either federal grant or any other source of funding other than FEMA preparedness grant
program dollars.
IPR Appendix | February 2021
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Encouraged Use of Certain Products Produced in the United States
Pursuant to Executive Order 13858 “Strengthening Buy-American Preferences for Infrastructure
Projects,” FEMA encourages non-federal entities under this grant program to use, to the greatest extent
practicable and consistent with the law, iron and aluminum as well as steel, cement, and other
manufactured products produced in the United States, in projects funded by an award under this grant
program affecting surface transportation, including roadways, bridges, railroads, and transit; aviation;
ports, including navigational channels; water resources projects; energy production, generation, and
storage, including from fossil-fuels, renewable, nuclear, and hydroelectric sources; electricity
transmission; gas, oil, and propane storage and transmission; electric, oil, natural gas, and propane
distribution systems; broadband internet; pipelines; stormwater and sewer infrastructure; drinking water
infrastructure; and cybersecurity. Notwithstanding this encouragement, non-federal entities must take care
that all procurements and contract actions are consistent with law, this Manual and applicable appendices,
the grant program’s NOFO, and the federal procurement standards at 2 C.F.R. §§ 200.317-200.326.
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Program Appendix G:
Port Security Grant Program (PSGP)
As a reminder, while this appendix contains PSGP-specific information and requirements, the main
content of this Manual (non-appendix information) contains important information relevant to all
preparedness grant programs, including the PSGP. Please be sure to read the main content of this Manual
in addition to the program-specific appendices.
PSGP grant recipients and subrecipients may only use PSGP grant funds for the purposes set forth in the
Notice of Funding Opportunity (NOFO), and all investments must be consistent with the statutory
authority for the award. These grant funds may not be used for matching funds for other federal awards,
lobbying, or intervention in federal regulatory or adjudicatory proceedings. In addition, federal funds may
not be used to sue the Federal Government or any other government entity.
PSGP Funding Guidelines
Costs charged to a PSGP award must be consistent with the Uniform Administrative Requirements, Cost
Principles, and Audit Requirements for Federal Awards, located at 2 C.F.R. Part 200. For more
information on 2 C.F.R. Part 200, please visit Information Bulletin (IB) 400 regarding FEMA’s
implementation of these provisions prior to the recent 2020 revisions. For information on the recent
revisions to these regulations, see 2 CFR Grants Management Policy Updates | FEMA.gov and
www.performance.gov/CAP/grants/.
PSGP Priorities
See the annual PSGP NOFO.
Limitations on Funding
As part of the PSGP application process, applicants must complete the approved Investment Justification
(IJ) template provided addressing each initiative being proposed for funding. A separate IJ should be
submitted for each proposed project which should represent the complete scope of work and materials
required to achieve a single overall capability. For example, a project could be to procure a boat
specifically designed and equipped as chemical, biological, radiological, nuclear and explosives
(CBRNE) detection, prevention, response, and/or recovery platform. The IJ for this example project
should include the CBRNE equipment in the same IJ as the vessel.
In accordance with 46 U.S.C. § 70107(b)(2), PSGP funding for projects for the cost of acquisition,
operation, and maintenance of security equipment or facilities to be used for security monitoring and
recording, security gates and fencing, marine barriers for designated security zones, security-related
lighting systems, remote surveillance, concealed video systems, security vessels, and other security-
related infrastructure or equipment that contributes to the overall security of passengers, cargo, or
crewmembers cannot exceed $1 million federal share per project.
The $1 million per project limitation applies only to those projects funded under 46 U.S.C. § 70107(b)(2)
and does not apply to projects funded under other provisions of Section 70107.
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Allowable Direct Costs
Specific investments made in support of the funding priorities discussed in the annual PSGP NOFO
generally fall into one of the following six allowable expense categories:
•
Planning
•
Operational Activities
•
Equipment and Capital Projects
•
Training and Awareness Campaigns
•
Exercises
•
Management and Administration
The following provides guidance on allowable costs within each of these areas.
Planning
Planning activities address the Soft Targets/Crowded Places; Cybersecurity; Emergent Threats; and
Planning Priorities.
PSGP funds may be used for the following types of planning activities:
•
Development or updating of port wide risk mitigation plan (PRMP), including the conduct of port
security vulnerability assessments as necessary to support plan update/development
•
Development and enhancement of security plans and protocols within the Area Maritime Security
Plan (AMSP), PRMP, and the Business Continuity and Resumption of Trade Plans (BCRTP) in
support of maritime security and risk mitigation planning
•
Materials required to conduct planning activities noted in this section
•
Travel and per diem related to the professional planning activities noted in this section
•
Coordination and information sharing with fusion centers
•
Other port wide maritime security project planning activities, which emphasize the ability to
adapt to changing conditions and be prepared to withstand, and recover from, disruptions due to
emergencies with prior approval from FEMA
Backfill, overtime, hiring of part-time temporary personnel, and contractors or consultants to assist with
planning activities. Copies of PSGP-funded plans must be made available to FEMA and the U. S. Coast
Guard (USCG) upon request.
Operational Activities
Operational Activities address the Soft Targets/Crowded Places; and Emergent Threat Priorities.
Explosive Detection Canine Teams (EDCTs)
Use of canines (K-9) for explosive detection is one of the most effective solutions for the detection of
vehicle-borne IEDs. When combined with the existing capability of a port or ferry security/police force,
the added value provided through the addition of a canine team is significant. EDCTs are a proven,
reliable resource to detect explosives and are a key component in a balanced counter-sabotage program.
Eligibility for funding of EDCTs is restricted to:
•
U.S. Ferry Systems regulated under 33 C.F.R. Parts 101, 103, 104, and the passenger terminals
these specific ferries service under 33 C.F.R. Part 105
•
Maritime Transportation Security Act (MTSA) regulated facilities
PSGP Appendix | February 2021
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•
Port authorities, port police, and local law enforcement agencies that provide direct layered
security for these U. S. Ferry Systems and MTSA-regulated facilities, and are defined in an
AMSP, Facility Security Plan (FSP), or Vessel Security Plan (VSP)
Applicants may apply for up to $450,000 ($150,000/year for three years) per award to support this
endeavor. At the end of the grant period (36 months), recipients will still be responsible for continuing the
heightened level of capability provided by the EDCT. A sustainment plan must be submitted with the
applicant’s IJ to address the 12-month period beyond the period of performance of the award.
Eligible EDCT Costs
Funds for these EDCTs may not be used to fund drug detection and apprehension technique training.
Only explosives detection training for EDCTs will be funded. The PSGP EDCT funds may only be used
for new or expanded capabilities/programs and cannot be used to pay for existing K-9 teams, personnel,
or K-9 training costs already supported by the port area. Repair and replacement of existing EDCT
equipment is allowed. Eligible costs include:
•
Contracted K-9 and handler providing services in accordance with PSGP guidance
•
Salary and fringe benefits of new full- or part-time K-9 handler positions
•
Training and certifications (travel costs associated with training for new or expanded full or part
time agency handlers, and canines are allowable)
•
K-9 and handler equipment costs
•
Purchase and train a new K-9 and handler for CBRNE detection
•
K-9 maintenance costs including but not limited to veterinary, housing, and feeding costs
Ineligible EDCT costs include, but are not limited to:
•
Hiring costs, including costs associated with initial police academy training of new officers
•
Meals and incidentals associated with travel for initial certification
•
Vehicles modified to be used solely to transport canines
•
Repair or replacement of unallowable equipment
EDCT Certification
Each EDCT, composed of one dog and one handler, must be certified by an appropriate, qualified
organization. K-9 and handler should receive an initial basic training course and weekly maintenance
training sessions thereafter to maintain the certification. The basic training averages ten weeks for the
canine team (K-9 and handler together) with weekly training and daily exercising. Comparable training
and certification standards, such as those promulgated by the Transportation Security Administration
(TSA) Explosive detection canine program, the National Police Canine Association (NPCA), the U.S.
Police Canine Association (USPCA), or the International Explosive Detection Dog Association (IEDDA)
may be used to meet this requirement. Certifications and training records will be kept on file with the
recipient and made available to FEMA upon request.
EDCT Submission Requirements
Successful applicants will be required to submit an amendment to their approved VSP or FSP per 33
C.F.R. Parts 104 and/or 105 detailing the inclusion of a K-9 explosive detection program into their
security measures. The recipient will ensure that a written plan or standard operating procedures (SOPs)
exist that describe EDCT deployment policy to include visible and unpredictable deterrent efforts and on-
call EDCTs rapid response times as dictated by the agency’s FSP or VSP. The plan or SOPs must be
made available to FEMA and USCG upon request.
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The recipient will comply with requirements for the proper storage, handling and transportation of all
explosive training aids in accordance with the Bureau of Alcohol, Tobacco, Firearms and Explosives’
Publication 5400.7 (ATF P 5400.7) (09/00), Federal Explosive Law and Regulations.
Additional EDCT Resources Available for K-9 Costs
The PSGP, while providing the ability to defray some start-up costs, does not cover any recurring costs
associated with EDCT programs. FEMA strongly encourages applicants to investigate their eligibility
under other programs, and potential exclusions, when developing their K-9 programs.
Organization Costs
Allowable organization-related costs are limited to those activities associated with new and ongoing
maritime security operations essential to the national priorities. All such activities must be focused
exclusively on maritime security and coordinated with the local Captain of the Port (COTP). PSGP
funding used for organizational costs will only fund immediate needs for personnel that will be directly
engaged in maritime security activities. Allowable organization personnel costs include:
•
Backfill, Overtime, Hiring of Full or Part-Time Personnel or Contractors/Consultants. Full
or part-time staff or contractors/consultants may be hired to support training-related and/or
maritime-security-related activities conducted under this grant only to the extent that such
expenses are for the allowable activities within the scope of the grant. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R.
§§ 200.317-200.327. Salary and fringe benefit payments must be in accordance with the policies
of the state or unit(s) of local government and have the approval of the state or awarding agency.
Dual compensation is not allowable. That is, an employee of a unit of government may not
receive compensation from their unit or agency of government AND from an award for a single
period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both activities.
Limitations may apply for grant related activities. See specific guidance provided within this
Manual for additional details on allowable organization costs (i.e., Training – Personnel costs are
limited to backfill and overtime).
•
Hiring new, full-time personnel to:
o Operate maritime security patrol vessels (first response agencies only)
o Staff a new or expanded interagency maritime security operation center
o Support maritime security/counterterrorism efforts in the local Joint Terrorism Task
Force (JTTF) and/or fusion center
o Support credentialing access to a MTSA facility
•
Backfill and Overtime costs for existing personnel to:
o Operate patrol vessels in support of pre-planned, mission critical activities, as identified
by the local COTP (not including routine patrol)
o Attend approved maritime security training courses
•
Personnel or contracted costs to:
o Install, repair, and replace port security equipment acquired with FEMA preparedness
grant funds. Note this does not include routine maintenance, such as oil changes and
daily/weekly systems tests.
o Management and administration (M&A) of projects funded under this program
•
Contracted costs to:
o Provide approved training courses
o Provide warranty, maintenance, and service agreements for equipment purchased under
this grant
Organization costs will only be funded to address port (or facility) security needs as outlined in the NOFO
and this appendix. PSGP funding for new permanent or part-time personnel will not exceed the 36-month
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period of performance. Applicants must provide reasonable assurance that personnel costs can be
sustained beyond the 36-month award period. A sustainment plan must be submitted with the
applicant’s IJ to address the 12-month period beyond the period of performance of the award.
Equipment and Capital Projects
Equipment and Capital Projects address the Soft Targets/Crowded Places; Cybersecurity; Emergent
Threats; and Equipment/Capital Projects Priorities.
Equipment Acquisition
PSGP funds must comply with IB 426. PSGP funds may be used for the following categories of
equipment. A comprehensive listing of allowable equipment categories and types is found in the DHS
Authorized Equipment List (AEL). Requests for vehicles of any type are subject to secondary review and
approval by the National Review Panel. These costs include:
•
Personal Protective Equipment (PPE) for maritime security providers, such as ballistic protective
body armor (not including uniforms)
•
CBRNE response and remediation equipment for maritime security providers
•
CBRNE decontamination equipment for direct maritime security providers and MTSA-regulated
industry
•
CBRNE detection-equipped patrol vehicles (not including armored personnel carriers or tow
trucks), provided they will be used exclusively for port/facility CBRNE detection security
operations. A CBRNE detection equipped patrol vehicle must include specifically identified,
permanently mounted detection equipment.
•
Mobile Command Centers only when validated by the COTP as essential to address a
specifically required capability outlined in the approved AMSP.
•
CBRNE detection equipped and patrol watercraft vessel/small boat used to directly support
maritime security for a facility or within a Port Area on a routine basis (CBRNE detection
equipment requested with the watercraft/small boat in the IJ must be listed and also detailed in the
budget). However, a vessel is not required to be CBRNE equipped.
•
Marine firefighting vessels, provided they are outfitted with CBRNE detection equipment and are
designed and equipped to meet NFPA 1925: Standard on Marine Fire-Fighting Vessels
•
Firefighting foam and Purple-K Powder (PKP) may be purchased by public fire departments that
have jurisdictions in a port area and would respond to an incident at an MTSA regulated facility.
MTSA facilities may also receive funding for this purpose. Funding will be limited to a one-time
purchase based on a worst-case incident at the facility or facilities
•
Information-sharing technology; components or equipment designed to share maritime security
risk information and maritime all-hazards risk information with other agencies (equipment must
be compatible with generally used equipment)
•
Maritime security risk mitigation interoperable communications equipment
•
Terrorism incident prevention and response equipment for maritime security risk mitigation
•
Physical security enhancements, to include TWIC projects (e.g., card readers, fences, blast
resistant glass, turnstiles, hardened doors and vehicle gates) at maritime facilities
•
Portable fencing, closed-circuit televisions (CCTVs), passenger vans, mini-buses, etc. to support
secure passage of vessel crewmembers through a MTSA regulated facility
•
Equipment in support of resiliency, such as interoperable communications, intrusion
prevention/detection, physical security enhancements, and software and equipment needed to
support essential functions during a continuity situation
PSGP Appendix | February 2021
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•
Generators with appropriate capability (size) to provide back-up power to systems and equipment
that support Maritime Domain Awareness (not including routine operational capabilities):
o Access control equipment and systems
o Detection and security surveillance equipment
o Enhancement of Command and Control facilities
•
Equipment for new personnel, such as personal protective equipment, is an allowable expense.
Weapons and equipment associated with weapons maintenance/security (e.g., firearms,
ammunition, and gun lockers) are not allowable.
Recipients may purchase equipment not listed on the AEL, but only if they first seek and obtain prior
approval from FEMA.
Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA was alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this
topic for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-
technology-detect-and-mitigate-unmanned-aircraft.
Sonar Devices
The four types of allowable sonar devices are: imaging sonar, scanning sonar, side scan sonar, and three-
dimensional sonar. These types of sonar devices are intended to support the detection of underwater
improvised explosive devices and enhance maritime domain awareness. The eligible types of sonar, and
short descriptions of their capabilities, are provided below:
1) Imaging Sonar: A high-frequency sonar that produces “video-like” imagery using a narrow field
of view. The sonar system can be pole-mounted over the side of a craft or hand-carried by a diver.
2) Scanning Sonar: Consists of smaller sonar systems that can be mounted on tripods and lowered
to the bottom of the waterway. Scanning sonar produces a panoramic view of the surrounding
area and can cover up to 360 degrees.
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3) Side Scan Sonar: Placed inside a shell and towed behind a vessel. Side scan sonar produces
strip-like images from both sides of the device.
4) Three-Dimensional Sonar: Produces 3-dimensional imagery of objects using an array receiver.
Maritime Domain Awareness
Maritime domain is defined as “all areas and things of, on, under, relating to, adjacent to, or bordering on
a sea, ocean, or other navigable waterway, including all maritime-related activities, infrastructure, people,
cargo, and vessels and other conveyances.” Homeland Security Presidential Directive-13 (NSPD-
41/HSPD-13) (Maritime Security Policy, December 21, 2004). According to the National Plan to Achieve
Maritime Domain Awareness for the National Strategy for Maritime Security (Oct. 2005), “Maritime
Domain Awareness (MDA) is the effective understanding of anything associated with the global maritime
domain that could impact the security, safety, economy, or environment of the United States. MDA is a
key component of an active, layered maritime defense in depth. It will be achieved by improving our
ability to collect, fuse, analyze, display, and disseminate actionable information and intelligence to
operational commanders.” Id. at ii. Applicants are encouraged to familiarize themselves with this National
Strategy.
Improvised Explosive Device (IED) and CBRNE Prevention, Protection, Response,
Recovery Capabilities
Port areas should continue to enhance their capabilities to prevent, detect, respond to and recover from
terrorist attacks employing IEDs, CBRNE devices, and other non-conventional weapons. Please refer to
DHS Small Vessel Security Strategy (Apr. 2008).
Physical Security
Physical security is security measures that are designed to deny unauthorized access to facilities,
equipment, and resources and to protect personnel and property from damage or harm (such as espionage,
theft, or terrorist attacks). Physical security involves the use of multiple layers of interdependent systems
and techniques. Physical security has been a focus of PSGP since the program’s inception in 2002.
Primarily, physical security is intended to harden MTSA-regulated facilities against attacks. Law
enforcement may contribute to physical security through patrols; however, patrol vessels generally
enhance multiple core capabilities with a focus on CBRNE detection, deterrence, and response. Funding
through PSGP for physical security projects should be only directed toward those projects that address
identified MTSA required activities and identified in the entity FSP and/or the port area AMSP. Some
examples of funded projects include TWIC-related equipment, fencing, lighting, gates, and CCTV.
Cybersecurity Projects
PSGP funds may be used for projects that enhance the cybersecurity of:
•
Access controls;
•
Sensors;
•
Security cameras;
•
Badge/ID readers;
•
Industrial Control System (ICS)/Supervisory Control and Data Acquisition (SCADA) systems;
•
Process monitors and controls (such as firewalls, network segmentation, predictive security cloud,
etc.); and
•
Passenger/vehicle/cargo security screening equipment (cybersecurity assessments are allowable).
When requesting funds for cybersecurity, applicants are encouraged to propose projects that would aid in
implementation of all or part of the Framework for Improving Critical Infrastructure Cybersecurity (the
“Framework”) developed by the National Institute of Standards and Technology (NIST). The Framework
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gathers existing international standards and practices to help organizations understand, communicate, and
manage their cyber risks. For organizations that do not know where to start with developing a
cybersecurity program, the Framework provides initial guidance. For organizations with more advanced
practices, the Framework offers a way to improve their programs, such as better communication with
their leadership and suppliers about management of cyber risks.
The Cybersecurity and Infrastructure Security Agency’s (CISA) Critical Infrastructure Cyber Community
C³ Voluntary Program also provides resources to critical infrastructure owners and operators to assist in
adoption of the Framework and managing cyber risks. Additional information on the Critical
Infrastructure Cyber Community C³ Voluntary Program can be found at www.cisa.gov/ccubedvp. DHS’s
Enhanced Cybersecurity Services (ECS) program is an example of a resource that assists in protecting
U.S.-based public and private entities and combines key elements of capabilities under the “Detect” and
“Protect” functions to deliver an impactful solution relative to the outcomes of the Cybersecurity
Framework. Specifically, ECS offers intrusion prevention and analysis services that help U.S.-based
companies and SLTT governments defend their computer systems against unauthorized access,
exploitation, and data exfiltration. ECS works by sourcing timely, actionable cyber threat indicators from
sensitive and classified Government Furnished Information (GFI). DHS then shares those indicators with
accredited Commercial Service Providers (CSPs). Those CSPs in turn use the indicators to block certain
types of malicious traffic from entering a company’s networks. Groups interested in subscribing to ECS
must contract directly with a CSP in order to receive services. Please visit http://www.cisa.gov/enhanced-
cybersecurity-services for a current list of ECS CSP points of contact.
“Hub and spoke” cybersecurity projects are allowable under PSGP for cybersecurity projects that span
multiple port area facilities. Hub and spoke cybersecurity projects may affect a parent organization’s
multiple eligible entities in multiple port areas. Such projects may be submitted within a primary Port
Area for the project implementation. For example, an applicant in the Port of Houston may submit a hub
and spoke project within the Houston/Galveston port area which includes system hardening throughout
the organization’s facilities in Houston, Port Lavaca and Corpus Christi. Proportionally, costs associated
with entities or subcomponents that are not covered under an AMSP and are not instrumental to
enhancing maritime security must not be included in the detailed budget worksheet or investment
justification and thereby prorating the cost of the project only to those facilities that are covered by the
AMSP. Following the example noted above, the applicant may not include costs associated with
cybersecurity of their non-maritime facilities, such as a non-MTSA regulated facility located in San
Antonio. Hub and spoke projects are limited only to the enhancement of maritime security as outlined in
this section and may not include non-maritime systems or facilities. Please clearly identify hub and spoke
projects as such within your IJ and consult your COTP to verify project applicability to enhancing
maritime security.
Cybersecurity projects should address risks to the marine transportation system and/or Transportation
Security Incidents (TSIs) outlined in the applicable AMSP or priorities prescribed under applicable
FSP or VSP, as mandated under the MTSA or the PRMPs. At the port level, examples of cybersecurity
projects include but are not limited to projects that enhance the cybersecurity of access control,
sensors, security cameras, badge/ID readers, ICS/SCADA systems, process monitors and controls (such
as those that monitor flow rates, valve positions, tank levels, etc.), security/safety of the ship-to-port-to-
facility-to-intermodal interface, and systems that control vital cargo machinery at the ship/shore
interface (such as cranes, manifolds, loading arms, etc.), and passenger/vehicle/cargo security
screening equipment.
Vulnerability assessments are generally not funded under PSGP. However, considering the evolving
malicious cyber activity, the relative novelty of cybersecurity as a priority within the program, and the
need to adopt best practices included in the voluntary Cybersecurity Framework, vulnerability
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assessments may be funded as contracted costs. Personnel costs (other than M&A) are not an allowable
expense for conducting these assessments.
CISA offers free resources to assist with initial assessments, please see https://www.cisa.gov/cyber-
resource-hub for additional information. Applicants are encouraged to utilize free resources prior to
requesting funds under this program.
Copies of completed cybersecurity assessments funded under PSGP that impact the maritime
transportation system, lead to a “transportation security incident” (as that term is defined under 46
U.S.C. § 70101(6)), or are otherwise related to systems, personnel, and procedures addressed by the
facility and vessel plan shall be made available to FEMA and/or the local COTP upon request. The
results of these cybersecurity assessments may be designated as Sensitive Security Information (SSI)
and may be used to inform national maritime cybersecurity assessments.
Where a vulnerability assessment has been completed either through contracts or qualified personnel to
identify existing gaps and required mitigation efforts, mitigating projects may be funded that include
purchase of equipment, software, and infrastructure designed to harden cybersecurity. Specific questions
on conducting vulnerability assessments should be referred to the respective FEMA Preparedness Officer.
Capital (Construction) Projects Guidance
Recipients must obtain written approval from FEMA prior to the use of any PSGP funds for construction
or renovation projects. Additionally, PSGP funding may not be used to construct buildings or other
physical facilities that are not constructed under terms and conditions consistent with the requirements of
section 611(j)(9) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. §
5196(j)(9)) (the Stafford Act),3 which requires compliance with the Davis-Bacon Act (codified as
amended at 40 U.S.C. §§ 3141 et seq.) for PSGP funded projects. Grant recipients must ensure that their
contractors or subcontractors for construction projects pay workers no less than the prevailing wages for
laborers and mechanics employed on projects of a character similar to the contract work in the civil
subdivision of the state in which the work is to be performed. Additional information regarding
compliance with the Davis-Bacon Act, including Department of Labor wage determinations, is available
at http://www.dol.gov/whd/govcontracts/dbra.htm.
The following types of construction and renovation projects are allowable under PSGP, provided they
address a specific vulnerability or need identified in AMSP or otherwise support the
maintenance/sustainment of capabilities and equipment acquired through PSGP funding:
•
Maritime Command and Control Centers
•
Interagency Operations Centers (IOCs) for maritime security
•
Port Security Emergency Communications Centers
•
Buildings to house generators that support maritime security risk mitigation
•
Maritime security risk mitigation facilities (e.g., dock house, ramps, and docks for existing port
security assets)
•
Hardened security fences/barriers at access points
•
Any other building or physical facility that enhances access control to the port/MTSA facility
area
3 While the Maritime Transportation Security Act of 2002, as amended at 46 U.S.C. § 70107(b)(2), requires that such
activities are carried out consistent with Section 611(j)(8) of the Stafford Act, a subsequent amendment to the Stafford
Act by section 3 of Pub. L. No. 109-308 in 2006 redesignated the text of Section 611(j)(8) to 611(j)(9). The cross-
reference in the Maritime Transportation Security Act of 2002 has not been updated.
PSGP Appendix | February 2021
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•
PSGP funding may be used to purchase and/or upgrade a barge to support a staging area for
maritime/port security patrols or maritime security risk mitigation responses. (Certain areas
throughout the Nation may require a barge that can be permanently anchored or moored in certain
areas to support maritime security risk mitigation activities.)
To be considered eligible for funding, the construction of fusion centers, operations centers, or
communications centers must offer a port wide benefit and support information sharing and operational
coordination among regional interagency and other port security partners. Applicants are reminded that
the period of performance is 36 months. Eligible costs for construction or renovation projects may not
exceed $1 million (federal-share) per project, which may not exceed 10% of the total amount of the
award, as stated in 46 U.S.C. § 70107(b)(2)(A) and (B) (Section 102 of the Maritime Transportation
Security Act of 2002, Pub. L. 107-295, as amended). Grant recipients are not permitted to use PSGP funds
for construction projects that are eligible for funding under other federal grant programs. PSGP funds may
only be used for construction activities directly related to maritime security risk mitigation enhancements.
All construction or renovation projects require Environmental Planning and Historic Preservation (EHP)
review. The recipient is also encouraged to have completed as many steps as possible for a successful
EHP review in support of their proposal for funding (e.g., coordination with the relevant Historic
Preservation Office to identify potential historic preservation issues and to discuss the potential for project
effects; compliance with all state and local EHP laws and requirements). Projects for which the recipient
believes an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-
01-001-01, Revision 01, EHP Directive and Instruction, FEMA Directive 108-1, and FEMA Instruction
108-1-1, must also be identified to the FEMA HQ Preparedness Officer within the first six months of the
award, regardless of the length of the period of performance. Completed EHP review materials for
construction and renovation projects must be submitted no later than 12 months before the end of the
period of performance. EHP policy guidance and the EHP Screening Form, can be found online at:
https://www.fema.gov/media-library/assets/documents/90195. EHP review materials should be sent to
gpdehpinfo@fema.dhs.gov.
Training and Awareness Campaigns
Training and Awareness Campaigns address the Soft Targets/Crowded Places; Cybersecurity; Emergent
Threats; and Training and Awareness Campaign Priorities.
Training
Port areas should assess their training and qualification requirements and coordinate training needs and
qualification requirements of incident response personnel. Funding for personnel training is limited to
those courses that are essential to enhance maritime security and have been listed in the FEMA
approved course catalog by the FEMA National Training and Education Division (NTED) or the USCG.
Approved courses are listed in the following catalogs maintained by NTED: NTED Course Catalog,
Federal Sponsored Course Catalog, and the State Sponsored Course Catalog. The catalogs may be viewed
at http://www.firstrespondertraining.gov. A listing of courses that are currently approved for PSGP
funding is included in the table below.
Some training activities require EHP Review, including exercises, drills or trainings that require any type of
land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP
review can be found online at: https://www.fema.gov/media-library/assets/documents/90195.
Funding for training courses not listed in
PSGP Appendix | February 2021
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Table 3 may be permitted on a case-by-case basis depending on the specific maritime security risk
mitigation training needs of the eligible PSGP applicant. In such cases, an applicant will be required to
explain in the IJ why none of the approved courses referenced in
Table 3 satisfy the identified training need and must submit detailed course information for review and
consideration by the local COTP field review team and the Nation Review Panel.
Further, in accordance with 46 U.S.C. § 70107(c)(2)(C), no cost share is required to train law
enforcement agency personnel in the enforcement of security zones under section 46 U.S.C. § 70132 or
assisting the enforcement of such security zones. Training denoted with an asterisk (*) in the table below
is exempt from cost share only to train law enforcement agency personnel who enforce security zones.
Additional training of law enforcement agency personnel may be exempt if specifically identified by the
COTP as exempt and necessary for enforcement or the assistance of enforcement of security zones as
specified by 46 U.S.C. § 70132. Requests that fail to include a cost share for training that is not exempt
from cost share requirements as outlined in 46 U.S.C. § 70132 will not be considered for funded. Training
for law enforcement agency personnel who do not provide enforcement of security zones are not exempt
from cost share. Training rosters and certificates must be provided to FEMA upon request. Please consult
your COTP prior to requesting cost share exempt training for enforcement of security zones. Refer to
Section C.4 of the NOFO for more specific cost share information for that specific year’s requirements.
Seminars and workshops are not considered “Training”, however applicants wishing to host seminars or
workshops with PSGP funding may be eligible for funding following the criteria set forth in the
“Exercise” section of this guidance.
Table 3: Approved PSGP Training Courses
National Training and Education Division
Course Number
Course Name
AWR-144
Port and Vessel Security for Public Safety and Maritime Personnel
AWR-213
Critical Infrastructure Security and Resilience Awareness
AWR-366-W
Developing a Cyber Security Annex for Incident Response
MGT-335
Event Security Planning for Public Professionals
MGT-335-W
Event Security Planning for Public Professionals, Web Based
MGT-400
Master of Arts Degree in Homeland Security
MGT-425
Homeland Security Executive Leaders Program (ELP)
MGT-452
Physical and Cybersecurity for Critical Infrastructure
MGT-456
Integration of Cybersecurity Personnel into the Emergency Management
Operations Center for Cyber Incidents
PER-330
The Surface Transportation Emergency Preparedness and Security for Mass
Transit and Passenger Rail (STEPS-PT)
PER-331
Surface Transportation Emergency Preparedness and Security for Senior
Officials or Administrators (STEPS Sr)
Federal-Sponsored
Course Number
Course Name
DHS-006-PREV
Seaport Security Anti-Terrorism Training Program (SSATP)
DHS-011-PREV
Maritime PRND Operations Course
DHS-016-PREV
Protective Measures Training for Security Officers, Mid-Level
Safety/Security Supervisors, and Property Managers
*DHS-011-PROT
NASBLA BOAT Tactical Operators Course
*DHS-009-PROT
Boat Operator's Anti-Terrorism Training
PSGP Appendix | February 2021
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DHS-126-RESP
NASBLA BOAT Crew Member Course
*DHS-128-RESP
NASBLA - Pursuit and Stop Course
State-Sponsored
Course Number
Course Name
CA-006-PREV
Maritime Company, Vessel, and Facility Security Officer
CA-007-PREV
Basic Maritime Security Awareness
CA-008-PREV
Basic First Responder Operational Maritime Security (FROMS)
CA-015-RESP
Maritime Facility Security Officer
CA-020-RESP
WMD & Terrorism Awareness for Security Professionals
ME-001-PROT
Maritime Security Awareness for Military, First Responder and Law
Enforcement Personnel
ME-002-PROT
Command Strategies and Tactics for Marine Emergencies
*ME-003-PROT
Tactical Boat Operations for Maritime Security and LE Personnel
ME-002-RESP
Emergency Medical Operations in the Maritime Domain
NJ-003-PREV
Government Agency Maritime Security Awareness Program (GAMSAP)
NJ-015-PREV
Security Awareness & Vigilance for Everyone
NY-001-PREV
Maritime Infrastructure Protection
NY-001-PROT
Safe Boat Operators
*NY-002-PREV
Tactical Escorts and Security Zones
NY-002-PROT
Pattern Line Search/Recovery Course
NY-004-RESP
Vehicle Borne Improvised Explosive Device Security Checkpoint
Exercises
Exercise activities address the Soft Targets/Crowded Places; Cybersecurity; Emergent Threats; and
Exercises Priorities.
Exercises funded under the PSGP typically include Seminars, Workshops, Tabletop, Functional, Drills,
and Full-Scale exercises. PSGP-funded exercises must have a maritime security focus and include
applicable documentation, after action reports, and improvement plans. See below for additional
information.
Maritime entity training needs and qualification requirements of incident response personnel should be
regularly tested through emergency exercises and drills. Exercises must test operational protocols that
would be implemented in the event of a terrorist attack in the maritime environment in accordance with
the Area Maritime Security Training Exercise Program (AMSTEP) or the TSA Intermodal Security
Training Exercise Program (I-STEP) guidelines. AMSTEP or I-STEP exercises will follow the latest
change in requirements contained in the Navigation and Inspection Circular (NVIC) 09-02. Exercises
must be designed, developed and conducted consistent with the Homeland Security Exercise and
Evaluation Program (HSEEP). Funding used for exercises will only be permitted for those exercises that
are in direct support of a MTSA-regulated facility or a port area’s MTSA-required exercises (see 33
C.F.R. § 105.220 for a facility and 33 C.F.R. § 103.515 for the AMSP). These exercises must be
coordinated with the COTP and AMSC and be consistent with HSEEP. More information on HSEEP may
be found at https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep.
Some exercise activities require EHP Review, including exercises, drills or trainings that require any type of
land, water, or vegetation disturbance or building of temporary structures or that are not located at facilities
designed to conduct training and exercises. Additional information on training requirements and EHP
review can be found online at https://www.fema.gov/media-library/assets/documents/90195.
PSGP Appendix | February 2021
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Recipients are required to submit an After-Action Report/Improvement Plan (AAR/IP) for each PSGP-
funded exercise to hseep@fema.dhs.gov, and the appropriate local COTP no later than 90 days after
completion of the exercise conducted within the PSGP period of performance (POP). Recipients are
reminded of the importance of implementing corrective actions iteratively throughout the progressive
exercise cycle. Recipients are required to use the HSEEP AAR/IP template located at
https://preptoolkit.fema.gov/web/hseep-resources/improvement-planning.
PSGP funds may be used for the following exercise activities:
Funds Used to Design, Develop, Conduct, and Evaluate an Exercise. This includes costs related to
planning, meeting space, and other meeting costs, facilitation costs, materials and supplies, travel, and
documentation. Exercises afford organizations the opportunity to validate plans and procedures, evaluate
capabilities, and assess progress toward meeting capability targets in a controlled, low-risk setting. Any
shortcoming or gap identified, including those for children and individuals with disabilities or access and
functional needs, should be identified in an effective corrective action program that includes development
of improvement plans that are dynamic documents, with corrective actions continually monitored and
implemented as part of improving preparedness through the exercise cycle.
Hiring of Full- or Part-Time Staff or Contractors/Consultants. Full- or part-time staff may be hired to
support exercise-related activities. Hiring of contractors/consultants must follow the applicable federal
procurement requirements at 2 C.F.R. §§ 200.317-200.327. Such costs must be included within the
funding allowed for program management personnel expenses, which must not exceed 10% of the total
allocation. Dual compensation is never allowable, meaning, in other words, that an employee of a unit of
government may not receive compensation from his or her unit or agency of government and from an
award for a single period of time (e.g., 1:00 p.m. to 5:00 p.m.), even though such work may benefit both
entities. Personnel hiring, overtime, and backfill expenses are permitted under this grant only to the extent
that such expenses are for the allowable activities within the scope of the grant.
Overtime and Backfill Costs. The entire amount of overtime costs, including payments related to
backfilling personnel that are the direct result of time spent on the design, development and conduct of
exercises are allowable expenses. These costs are allowed only to the extent the payment for such services
is in accordance with the policies of the state or unit(s) of local government and has the approval of the
state or the awarding agency, whichever is more restrictive. Dual compensation is never allowable.
Travel. Domestic travel costs are allowable as expenses by employees who are on travel status for
official business related to the planning and conduct of exercise project(s). International travel costs are
not permitted.
Supplies. Supplies are items that are expended or consumed during the course of the planning and
conduct of the exercise project(s) (e.g., gloves, non-sterile masks, and disposable protective equipment).
Other Items. These costs include the rental of space/locations for exercise planning and executing, rental
of equipment, etc. Recipients are encouraged to use free public space, locations, or facilities, whenever
available, prior to the rental of space, locations, or facilities. These also include costs that may be
associated with inclusive practices and the provision of reasonable accommodations and modifications to
provide full access for children and adults with disabilities.
The National Exercise Program (NEP) serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. Recipients are strongly encouraged to nominate exercises into the
NEP. For additional information on the NEP, please refer to http://www.fema.gov/national-exercise-
program.
PSGP Appendix | February 2021
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Management and Administration (M&A)
M&A costs are allowed under this program. M&A costs are activities directly related to managing and
administering the award. Recipients may use up to 5% of the amount of the award for their M&A. PSGP
funds may be used for the following M&A costs:
•
Hiring full-time or part-time staff, including contractors and consultants, to execute the following:
o Management of the awarded fiscal year’s PSGP award;
o Design and implementation of the awarded fiscal year’s PSGP submission meeting
compliance with reporting/data collection requirements, including data calls;
o Information collection and processing necessary to respond to FEMA data calls;
o Travel expenses related to PSGP grant administration; and
o Acquisition of authorized office equipment, including personal computers or laptops for
PSGP M&A purposes.
Allowable Indirect Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the
Grants Management Specialist for further instructions. Applicants who wish to use a cost allocation plan
in lieu of an indirect cost rate must also reach out to the Grants Management Specialist for further
instructions. Post-award requests to charge indirect costs will be considered on a case-by-case basis and
based upon the submission of an agreement or proposal as discussed above or based upon the de minimis
rate or cost allocation plan, as applicable.
Unallowable Costs
Projects that do not provide a compelling maritime security benefit or have a direct nexus toward
maritime security risk mitigation are not permitted. For example, projects that are primarily for economic
or safety benefit (as opposed to having a direct maritime security risk mitigation benefit) are ineligible for
PSGP funding. In addition, projects that provide a broad homeland security benefit (e.g., a
communication system or fusion center for an entire city, county, state, etc.) as opposed to providing
primary benefit to the port are ineligible for PSGP funding since these projects should be eligible for
funding through other preparedness grant programs. The following projects and costs are considered
ineligible for award consideration:
•
Grant funds must comply with IB 426 and may not be used for the purchase of the following
equipment: firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels,
or vehicles of any kind with weapons installed;
•
Projects in which federal agencies are the primary beneficiary or that enhance federal property,
including sub-components of a federal agency;
PSGP Appendix | February 2021
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•
Projects that study technology development for security of national or international cargo supply
chains (e.g., e-seals, smart containers, container tracking or container intrusion detection devices);
•
Proof-of-concept projects;
•
Development of training;
•
Projects that duplicate capabilities being provided by the Federal Government (e.g., vessel traffic
systems);
•
Business operating expenses (certain security-related operational and maintenance costs are
allowable—see “Maintenance and Sustainment” and “Operational Costs” for further guidance);
•
Transportation Worker Identification Credential (TWIC) card fees;
•
Reimbursement of pre-award security expenses;
•
Outfitting facilities, vessels, or other structures with equipment or items providing a benefit rather
than a direct security benefit. Examples of such equipment or items include but are not limited to
office furniture, CD players, DVD players, AM/FM radios, TVs, stereos, entertainment satellite
systems, entertainment cable systems and other such entertainment media, unless sufficient
justification is provided. This includes weapons and associated equipment (i.e., holsters, optical
sights, and scopes), including but not limited to, non-lethal or less-than-lethal weaponry including
firearms, ammunition, and weapons affixed to facilities, vessels, or other structures;
•
Expenditures for items such as general-use software, general-use computers, and related
equipment (other than for allowable M&A activities, or otherwise associated) preparedness or
response functions), general-use vehicles and licensing fees;
•
Land acquisitions and right of way purchases;
•
Funding for standard operations vehicles utilized for routine duties, such as patrol cars and fire
trucks;
•
Fuel costs (except as permitted for training and exercises);
•
Exercise(s) that do not support maritime security preparedness efforts;
•
Patrol vehicles and firefighting apparatus, other than those CBRNE detection equipped vehicles
for port area and/or facility patrol or response purposes;
•
Specialty vehicles such as trucks for towing boat trailers and armored personnel carriers;
•
Providing protection training to public police agencies or private security services to support
protecting VIPs or dignitaries;
•
Aircraft pilot training, including aircraft operations such as aircraft ditch training;
•
Post incident investigation training;
•
Basic or advanced dive training (except marine unit CBRNE detection/response dive training);
•
Training for personnel not primarily assigned to maritime security activities or MTSA required
security personnel (e.g., vessel patrol officers, facility security officers); and
•
Reimbursement for the maintenance and wear and tear costs of general use vehicles (e.g.,
construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances, repair or
cleaning of Personal Protective Equipment (PPE), etc.).
Maintenance and Sustainment Costs
The use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement
costs, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise
noted. Preparedness grant funds may be used to purchase maintenance contracts or agreements, warranty
coverage, licenses and user fees. These contracts may exceed the period of performance if they are
purchased incidental to the original purchase of the system or equipment as long as the original purchase
of the system or equipment is consistent with that which is typically provided for, or available through,
these types of agreements, warranties, or contracts. When purchasing a stand-alone warranty or extending
an existing maintenance contract on an already-owned piece of equipment system, coverage purchased
PSGP Appendix | February 2021
Page G-16
may not exceed the period of performance of the award used to purchase the maintenance agreement or
warranty. As with warranties and maintenance agreements, this extends to licenses and user fees as well.
Grant funds are intended to support the National Preparedness Goal and fund projects that build and
sustain the core capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and
recover from those threats that pose the greatest risk to the security of the Nation. In order to provide
recipients the ability to meet this objective, the policy set forth in IB 379: Guidance to State
Administrative Agencies to Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for
the expansion of eligible maintenance and sustainment costs that must be in (1) direct support of existing
capabilities; (2) must be an otherwise allowable expenditure under the applicable grant program, and (3)
be tied to one of the core capabilities in the five mission areas outlined in the Goal. Additionally, eligible
costs may also be in support of equipment, training, and critical resources that have previously been
purchased with either federal grant or any other source of funding other than FEMA preparedness grant
program dollars.
Port-Wide Risk Management Plans
Port areas with existing PRMPs are encouraged to maintain their PRMPs and use them to identify
projects that will serve to address remaining maritime security vulnerabilities. These ports are also
encouraged to develop or maintain a BCRTP. For purposes of regional strategic and tactical planning,
these plans must take into consideration all port areas covered by their AMSP, align with the port area’s
AMSP, consider the entire port system strategically as a whole, and identify actions designed to
effectively mitigate security risks associated with the system’s maritime critical infrastructure and key
resources.
Additional Port Security Resources
•
U.S. Department of Transportation “BUILD” grants for National Infrastructure Investments may
include funding to support roads, bridges, transit, rail, ports or intermodal transportation, see
https://www.transportation.gov/BUILDgrants
•
Cybersecurity assessments may be available via CISA, see https://www.cisa.gov/cyber-resource-
hub
Sample Memorandum of Understanding/Agreement (MOU/MOA)
The sample MOU/MOA below demonstrates all of the elements required in the PSGP NOFO for
acceptance for review as part of a grant application from a state or local agency providing security
services to MTSA-regulated entities.
PSGP Appendix | February 2021
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Memorandum of [Understanding / Agreement]
Between [provider of layered security] and [recipient of layered security]
Regarding [provider of layered security’s] Use of Port Security Grant Program Funds
1. PARTIES. The parties to this Agreement are the [Provider of Layered Security] and the [Recipient of security
service].
2. AUTHORITY. This Agreement is authorized under the provisions of [applicable Area Maritime Security
Committee (AMSC) authorities and/or other authorities].
3. PURPOSE. The purpose of this Agreement is to set forth terms by which [Provider of security service] shall
expend Port Security Grant Program project funding in providing security service to [Recipient of security
service]. Under requested PSGP grant, the [Provider of security service] must provide layered security to
[Recipient of security service] consistent with the approach described in an approved grant application.
4. RESPONSIBILITIES: The security roles and responsibilities of each party are understood as follows:
(1) [Recipient of security service]
Roles and responsibilities in providing its own security at each MARSEC level
(2) [Provider of security service]
[-An acknowledgement by the facility that the applicant is part of their facility security plan.]
[-The nature of the security that the applicant agrees to supply to the regulated facility (waterside
surveillance, increased screening, etc.).]
[-Roles and responsibilities in providing security to [Recipient of security service] at each MARSEC level.]
5. POINTS OF CONTACT. [Identify the POCs for all applicable organizations under the Agreement; including
addresses and phone numbers (fax number, e-mail, or internet addresses can also be included).]
6. OTHER PROVISIONS. Nothing in this Agreement is intended to conflict with current laws or regulations of
[applicable State] or [applicable local Government]. If a term of this agreement is inconsistent with such
authority, then that term shall be invalid, but the remaining terms and conditions of this agreement shall remain
in full force and effect.
7. EFFECTIVE DATE. The terms of this agreement will become effective on [EFFECTIVE DATE].
8. MODIFICATION. This agreement may be modified upon the mutual written consent of the parties.
9. TERMINATION. The terms of this agreement, as modified with the consent of both parties, will remain in
effect until the grant end dates for an approved grant. Either party upon [NUMBER] day’s written notice to the
other party may terminate this agreement.
APPROVED BY: Organization and Title
EMPG Program Appendix | February 2021
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Program Appendix H:
Emergency Management Performance Grant Program
As a reminder, although this appendix contains Emergency Management Performance Grant (EMPG)
Program-specific information and requirements, the main content of this Manual (non-appendix
information) contains important information relevant to all preparedness grant programs, including the
EMPG Program. Please be sure to read the main content of this Manual in addition to the program-specific
appendices.
Alignment of the EMPG Program to the National Preparedness System
The EMPG Program contributes to the implementation of the National Preparedness System by supporting
the building, sustaining, and delivery of core capabilities. Core capabilities are essential for the execution of
critical tasks for each of the five mission areas outlined in the National Preparedness Goal (the Goal). The
EMPG Program’s allowable costs support efforts to build and sustain core capabilities across the
Prevention, Protection, Mitigation, Response, and Recovery mission areas described in the Goal.
FEMA requires recipients to prioritize grant funding to demonstrate how EMPG Program-funded
investments support closing capability gaps or sustaining capabilities identified in the Threat and Hazard
Identification and Risk Assessment (THIRA)/Stakeholder Preparedness Review (SPR) process and other
relevant information sources, such as: 1) after-action reports (AARs) following exercises or real-world
events; 2) audit and monitoring findings; 3) Hazard Mitigation Plans; and/or 4) other deliberate planning
products. In advance of issuing the FY 2021 EMPG Program awards, FEMA Regional Administrators will
identify regional priorities based on their unique knowledge of the region’s preparedness and emergency
management needs and will share those priorities with the states and territories within their region. The final
priorities will be identified and mutually agreed to by the state or territory and Regional Administrator
through a collaborative negotiation process. Ideally, all EMPG Program-funded projects, as outlined in the
approved FY 2021 EMPG Program Work Plan, will support the priorities identified through this
collaborative approach. See EMPG Program Work Plan section for additional guidance.
FEMA continues to emphasize capabilities that address the greatest risks to the security and resilience of
the United States. When applicable, funding should support deployable assets that can be used anywhere in
the Nation through automatic assistance and mutual aid agreements, including, but not limited to, the
Emergency Management Assistance Compact (EMAC). The EMPG Program supports investments that
improve the ability of jurisdictions nationwide to:
•
Prevent a threatened or an actual act of terrorism;
•
Protect our citizens, residents, visitors, and assets against the greatest threats and hazards;
•
Mitigate the loss of life and property by lessening the impact of future disasters;
•
Respond quickly to save lives, protect property and the environment, and meet basic human needs
in the aftermath of a catastrophic incident; or
•
Recover through a focus on the timely restoration, strengthening, and revitalization of
infrastructure, housing, and a sustainable economy, as well as the health, social, cultural, historic,
and environmental fabric of communities affected by a catastrophic incident.
EMPG Program Appendix | February 2021
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The core capabilities contained in the Goal are highly interdependent and require the use of existing
preparedness networks and activities to improve training and exercise programs, innovation, and
appropriate administrative, finance, and logistics systems.
Implementation of the National Preparedness System
Identifying and Assessing Risk and Estimating Capability Requirements
By December 31, 2021, recipients are required to complete a THIRA/SPR that addresses all 32 core
capabilities and is compliant with Comprehensive Preparedness Guide (CPG) 201, Third Edition. Specific
guidance on the requirements for each core capability will be forthcoming in 2021, as some core
capabilities have fewer reporting requirements than others. Building on the requirement implemented in
2020, recipients must respond to a series of planning-related questions as part of the THIRA/SPR process.
Recipients are required to submit a THIRA every three years to establish a consistent baseline for
assessment. Although the THIRA will be only required every three years, recipients will continue to be
required to submit an SPR annually. For additional guidance on the THIRA/SPR, please refer
to Comprehensive Preparedness Guide (CPG) 201, Third Edition.
Reporting:
•
In each EMPG Program recipient’s Biannual Strategy Implementation Report (BSIR), as part of
programmatic monitoring, the recipient is required to describe how expenditures support closing
capability gaps or sustaining capabilities identified in the THIRA/SPR process. EMPG Program
recipients will, on a project-by-project basis, check one of the following:
o Building a capability with EMPG Program funding; or
o Sustaining a capability with EMPG Program funding.
Building and Sustaining Core Capabilities
Recipients must describe how proposed EMPG Program-funded projects will close capability gaps or
sustain capabilities identified through the THIRA/SPR process or other relevant information sources that
identify capability needs. See EMPG Program Work Plan section for additional guidance and
requirements.
National Incident Management System (NIMS) Implementation
EMPG Program recipients and subrecipients are required to implement NIMS. EMPG Program funds may
be used to meet the requirements described in the NIMS Implementation Objectives for Local, State, Tribal,
and Territorial Jurisdictions. This document should be used as a guide for both identifying NIMS
implementation objectives and needs and as a tool for evaluating NIMS compliance. NIMS guides all levels
of government, nongovernmental organizations (NGO), and the private sector to work together to prevent,
protect against, mitigate, respond to, and recover from incidents. NIMS provides stakeholders across the
whole community with the shared vocabulary, systems, and processes to successfully deliver the
capabilities described in the National Preparedness System. EMPG Program recipients must use
standardized resource management concepts for resource typing, credentialing, and an inventory to
facilitate the effective identification, dispatch, deployment, tracking, and recovery of resources.
National Qualification System (NQS)
EMPG Program recipients are strongly encouraged to implement components of the NQS and may use their
EMPG Program funds to support NQS implementation efforts. Beginning in FY 2022, FEMA intends to
EMPG Program Appendix | February 2021
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make the implementation of NQS a requirement of award for EMPG Program funding. Jurisdictions should
achieve, or work toward achieving, each of the activities listed below. The activities that support NQS
implementation include:
•
Ensuring that incident personnel qualifying for a position meet the minimum training requirements
from the Job Title/Position Qualification for that position. All of the NIMS resource typing
definitions and job title/position qualifications can be downloaded from the Resource Typing
Library Tool (RTLT).
•
Developing organizational qualification procedures in alignment with the NIMS Guideline for the
National Qualification System (NQS). These procedures include:
o Qualification, certification, and credentialing processes for incident management and
emergency management personnel.
o Qualification review board, or equivalent review processes for incident management and
emergency management personnel qualifications.
o Individual and team coach and evaluation processes for incident management and
emergency management personnel qualifications.
•
Conducting exercises in accordance with the Homeland Security Exercise and Evaluation Program.
Data collection methods of the implementation of the NQS include the following:
Ways that the NIC is tracking collecting data on NQS:
•
NIMS Survey
•
Unified Reporting Tool questions
•
NIMS Regional Coordinator Program Guide that allows NIMS Regional Coordinators to
review state NIMS programs
Reporting:
•
Recipients will answer questions in the applicable secondary NIMS assessment portion of the
Unified Reporting Tool (URT) as part of a jurisdiction’s THIRA/SPR submission. This involves
reporting on the status of the qualification system used within the jurisdiction and sub-jurisdictions,
as outlined in the EMPG Program Notice of Funding Opportunity (NOFO).
•
Reporting will also be through a review by the FEMA Regional NIMS Coordinators during annual
technical assistance visits with the states, tribes, and territories within their regions.
Logistics Planning
Distribution Management Plans
Continuing the mandate from 2020, EMPG Program recipients are required to develop and maintain a
Distribution Management (DM) plan as an annex to their existing Emergency Operations Plan (EOP).
Comprehensive Preparedness Guide (CPG) 101 provides guidance on the fundamentals of planning and
development of Emergency Operations Plans. The FEMA Distribution Management Plan Guide (August
2019) provides information on how to develop the DM plan annex, key DM plan components, how to
review and update a DM plan, and how FEMA reviews and evaluates the plans.
The DM plan must be reviewed by recipients on an annual basis and updated as necessary by September 30
of each year. A question in the URT under the CPG 101 captures whether a jurisdiction has developed and
incorporated a DM plan in its EOP.
•
The DM plan should focus on the distribution of commodities and supplies such as food, water,
generators and tarps to survivors following a disaster
EMPG Program Appendix | February 2021
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•
The DM plan should address strategies/plans for the following:
o
Requirements Defining
o
Resource Ordering
o
Distribution Methods
o
Inventory Management
o
Staging Areas
o
Transportation
o
Demobilization
FEMA Regional Logistics Branch will work with EMPG Program recipients to provide technical assistance
during the development and maintenance of their DM plans, and to ensure all recipients have effective DM
plans capable of integrating with federal, NGOs, private sector, and state, local, tribal, and territorial
stakeholders during major disasters. Recipients should refer to the following for additional guidance:
•
Information Bulletin (IB) 442, Guidance on Distribution Management Plans for the Fiscal Year
2019 Emergency Management Performance Grants Program
Additional Logistics Planning Resources
FEMA recommends that EMPG Program recipients use the following resources in developing their DM
plan. To learn more about these programs and documents, or for any questions, please contact the Logistics
Section Chief from your FEMA Region.
•
The Logistics Capability Assessment Tool 2 (LCAT2) Flyer: The LCAT2 Flyer provides an
overview of the LCAT2, how it is beneficial, how the LCAT process works, and how to obtain an
LCAT2.
•
Points of Distribution (PODs) Training: FEMA Logistics developed a comprehensive POD
training to assist states in developing actionable emergency distribution plans and understanding
associated challenges. Additional information, including an explanatory DVD, POD guide, and
online exam, are available on the Emergency Management Institute’s (EMI) website at
https://training.fema.gov/is/courseoverview.aspx?code=IS-26.
•
Interagency Logistics (IL) Training: This basic IL training course familiarizes participants with
the IL concepts of planning and response. The course also provides an overview of IL Partner
disaster response organizations, discusses parameters for logistics support coordination, and creates
a whole community forum to exchange the best logistics practices. Recipients may find more
information on the course by visiting: https://training.fema.gov/emigrams/2018/1439%20-
%20training%20opportunity%20-
%20l8540%20basic%20interagency%20logistics%20fy19.pdf?d=10/2/2018.
•
Other Logistics Planning Resources: Recipients will find additional planning guidance at:
Planning Guides | FEMA.gov. Specific to logistics planning, Comprehensive Preparedness Guide
(CPG) 101, Version 2.0 provides guidance on how to incorporate logistics into EOPs. Additionally,
the Supply Chain Resilience Guide provides emergency managers with recommendations and best
practices on how to analyze local supply chains and work with the private sector to enhance supply
chain resilience using a five-phased approach.
Funding for Critical Emergency Supplies
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an
allowable expense under the EMPG Program. Each state must have FEMA’s approval of a five-year viable
inventory management plan prior to allocating grant funds for stockpiling purposes. The inventory
EMPG Program Appendix | February 2021
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management five-year plan should include a distribution strategy and related sustainment costs if the grant
expenditure is more than $100,000.
Reporting
Annual DM plan reviews will be reported in the Periodic Performance Report (PPR) for the quarter ending
September 30 of the most recently awarded EMPG Program. Reviews that result in an update must be
submitted to the regional grants division director or EMPG Program manager for review by regional
logistics staff. The Regional Logistics Staff will review and rate the plans using the FEMA Distribution
Management Plan Guide, August 2019.
Evacuation Planning
EMPG Program recipients should review and update their EOP at least once every two years in accordance
with Comprehensive Preparedness Guide (CPG) 101 v2, Developing and Maintaining Emergency
Operations Plans. Recipients are highly encouraged to include an evacuation plan or annex as part of their
EOP as well as plans to exercise and validate the evacuation plan and capabilities. At a minimum, recipients
should incorporate the National Response Framework’s Mass Evacuation Incident Annex’s planning
considerations, and other FEMA documents related to evacuation planning, when developing their own
Evacuation Plan or Annex. See National Response Framework (NRF), Third Edition (June 2016) and NRF
Mass Evacuation Incident Annex (June 2008). Additional National Preparedness resources are available at:
National Preparedness | FEMA.gov and Planning Guides | FEMA.gov. Specific to evacuation planning, the
Evacuation and Shelter in Place Guidance identifies relevant concepts, considerations, and principles that
can inform jurisdictions in planning for evacuation and/or shelter-in-place protective actions.
Disaster Housing Planning
State-Led Disaster Housing Task Force
Based on lessons learned from recent disasters, FEMA strongly encourages EMPG Program recipients to
establish a State-Led Disaster Housing Task Force (SLDHTF) plan as part of their EOP or as a standalone
document and update their plan at least once every two years.
SLDHTFs lead and coordinate state, local, private sector, and community-based actions to assess housing
impacts, identify appropriate post-disaster housing options, and establish processes for expediting post-
disaster housing delivery. SLDHTF plans should clearly identify the roles, responsibilities, composition,
and mobilization procedures for the SLDHTF, and how the SLDHTF integrates into the incident command
structure. To have a successful SLDHTF plan, FEMA encourages recipients to:
•
Complete the State Housing Strategy Template; and
•
Establish a State Disaster Recovery Coordinator.
State Housing Strategy Template
EMPG Program recipients are strongly encouraged to update their State Housing Strategy using the State
Housing Strategy Template provided by FEMA Individual Assistance (IA) as part of their EOP or as a
standalone document. In addition to the State Housing Strategy Template, recipients are encouraged to
define and emphasize sheltering, short term, and permanent housing planning.
The State Housing Strategy Template helps states identify priorities and document critical, jurisdiction-
specific processes and procedures to promote an efficient disaster housing mission. The template walks
recipients through the following planning considerations as seen in the table below.
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Table 4: State Housing Template Sections and Planning Considerations
Template Section
Planning Considerations
SLDHTF Plan
Organization
Participant inclusion, approaches for various types of housing disasters, available
materials, available assistance programs, and sources for surge staffing
Housing
Background
Identifying a jurisdiction’s current housing situation, priorities, capabilities,
challenges, and known risks
Sheltering Phase
Strategy
Identifying planning leads, current resources, timeline, key partners, cross-
jurisdictional agreements, and other risks
Interim Housing
Strategy
Identifying planning leads, current resources and capabilities, known areas of
difficulty, key partners, relocation strategies, and risks
Permanent
Housing Strategy
Identifying planning leads, long-term housing needs and prioritizations, current
resources and capabilities, known areas of implementation challenges, relocation
strategies, and risks
Pre-Disaster
Activities
Creating communication plans, survivor transition plans, mitigation plans, and
program closeout goals
Post-Disaster
Activities
Prioritizing disaster housing recovery activities, creating timelines for project
completion, documenting planned actions for assessing the availability of
affordable housing resources and expediting the delivery of housing by expediting
permitting and waiver processes, establishing an information sharing method,
creating an Environmental and Historical Preservation (EHP) strategy, identifying
potential locations for Manufactured Housing Units and Recreational Vehicles,
and identifying available federal disaster housing assistance
State-Administered Direct Housing Implementation
FEMA encourages states to develop the capacity to administer FEMA Direct Housing Assistance through a
reimbursable Inter-Governmental Service Agreement (IGSA). Under this arrangement, FEMA determines
disaster survivors’ eligibility for specific direct housing options and makes all determinations regarding
continuing eligibility, appeals, and eligibility terminations. FEMA also monitors the state’s administration
of approved Direct Housing Options to ensure compliance with federal environmental, historic
preservation, and floodplain management requirements as well as program conditions specified within the
IGSA. States that choose to administer Direct Housing Assistance through an IGSA are required to develop
a Direct Housing Administrative Plan and are encouraged to establish pre-placed contract to support the
delivery of direct housing. Any pre-placed contract would need to comply with applicable federal
procurement requirements at 2 C.F.R. §§ 200.317-200.327. For more information, regarding Direct
Housing Assistance, please refer to the Individuals and Households Unified Guidance available at
https://www.fema.gov/assistance/individual/program-policy-guide.
Disaster Housing Exercises
Recipients are encouraged to exercise and validate their long-term sheltering and housing stabilization plans
as part of an existing exercise program. This includes:
•
Validating the organizational structure of the Housing Task Force and internal readiness
capabilities to address post-disaster housing recovery issues or administer FEMA Direct Housing
Assistance under an IGSA
•
Validating disaster housing communication plans and procedures that coordinate and integrate the
activities and information generated by internal/external partners
EMPG Program Appendix | February 2021
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•
Validating data systems, security, and exchange protocols
•
Validating planned actions and milestones transitioning from emergency sheltering to temporary
housing to permanent housing and long-term recovery
Additional Disaster Housing Planning Resources
Recipients are encouraged to review the planning guidance available at Planning Guides | FEMA.gov. The
Planning Guides page includes: Planning Considerations: Disaster Housing Guidance for State, Local,
Tribal and Territorial Partners (May 2020), which supplements Comprehensive Preparedness Guide (CPG)
101: Developing and Maintaining Emergency Operations Plans. It provides guidance on national housing
priorities, types of housing, key considerations and housing-specific planning recommendations for state,
local, tribal and territorial (SLTT) jurisdictions to use, in conjunction with the Six-Step Planning Process
described in CPG 101, to develop or improve disaster housing plans.
State Disaster Recovery Coordinator
The Pre-Disaster Recovery Planning Guide helps states prepare for recovery by developing pre-disaster
recovery plans that follow a process to engage members of the whole community, develop recovery
capabilities, and create an organizational framework for recovery efforts.
FEMA strongly recommends that EMPG Program recipients include pre-disaster recovery planning as part
of their State Readiness and Preparedness efforts by establishing a State Disaster Recovery Coordinator
(SDRC). An effective pre-disaster recovery plan and process is crucial to help recipients prepare for major
disaster incidents and recover effectively. Recipients are encouraged to use the Pre-Disaster Recovery
Planning Guide to help inform their identification and establishment of a SDRC. The SDRC position should
be included in the State Administrative Plan with the following responsibilities:
•
Develop the pre-disaster recovery plan, including state-level leadership and structure, formation of
communication channels, multi-agency coordination, and building whole-community partnerships
to support recovery efforts.
•
Set the stage for necessary strategic, operational, and tactical post-disaster planning, actions, and
processes.
•
Maximize impact of federal, private sector, and nongovernmental dollars to enable recovery and
resilience.
•
Accelerate the delivery of resources, including funding and technical assistance, to disaster-
impacted communities.
•
Enable state leadership to better organize and identify gaps in the state’s recovery capabilities.
Disaster Financial Management Policies and Procedures
Lessons learned from recent hurricane seasons and wildfires demonstrate the need for impacted
jurisdictions to improve their ability to immediately track and account for disaster costs. Disaster financial
management includes policies and procedures that work to recover expenses pertaining to damage,
emergency protective measures, and debris management during and after a disaster. These policies and
procedures include, but are not limited to, those supporting eligible contract costs and force account labor,
materials, and equipment.
State Administrative Plan
FEMA strongly recommends that EMPG Program recipients include disaster financial management
planning as part of their State Administrative Plan. An effective disaster financial management plan and
process is crucial to help recipients prepare for declarations of emergencies or major disasters and plan for
EMPG Program Appendix | February 2021
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reimbursement. Table 5 details the processes that should be included in the State Administrative Plan and
recommendations on where they should be placed.
Table 5: State Administrative Plan Guidance
State Administrative Plan
Section Recommendations
Processes
•
Section V Part D: Project
Funding and Reimbursement
•
Section V Part G: Records
and Reports
•
A process to ensure subrecipients are tracking and
documenting disaster costs necessary for federal
reimbursement, such as receipts, invoices, procurement
documents, contracts, and insurance coverage/claims
•
Section V Part D: Project
Funding and Reimbursement
•
Section V Part G: Records
and Reports
•
A process to document disaster cost operations such as labor,
equipment, and materials that are allowable under federal
requirements
•
Section V Part D: Project
Funding and Reimbursement
•
A process to ensure that subrecipients are not receiving a
duplication in benefits
•
Section IV Part B:
Organization and Staffing
•
A process to ensure pre-disaster contracts and procurement
strategies are in place, if necessary
Additionally, recipients are encouraged to use EMPG Program funds for training that develops, delivers,
and exercises disaster financial management procedures.
Disaster Financial Management Resources
Recipients are encouraged to use the following resources to inform their disaster financial management
planning efforts:
•
State Administrative Plan Template: Recipients are recommended to use the State
Administrative Plan template found on FEMA’s Public Assistance webpage to inform their
planning efforts. The template includes example structure and content as a model for states to create
own Administrative Plan.
•
Public Assistance Program and Policy Guide: The Public Assistance Program and Policy Guide
(PAPPG) is a comprehensive, consolidated policy document for the Public Assistance program
provides an overview of the Public Assistance program implementation process.
•
Public Assistance Frequently Asked Questions and Guidance: Recipients are encouraged to
view the Public Assistance Frequently Asked Questions and guidance found on the Public
Assistance webpage to assist with disaster financial management planning efforts. The webpage
provides information pertaining to documentation, Public Assistance grant funding eligibility, and
hazard mitigation and can be found at https://www.fema.gov/assistance/public/policy-guidance-
fact-sheets/job-aids-faqs.
•
OIG Audit Tips: Recipients are recommended to consult the DHS OIG report, Audit Tips for
Managing Disaster-Related Project Costs (OIG-17-120-D) for further assistance in documenting
and accounting for disaster-related costs. This report is informed by OIG audit findings and can
assist recipients in addressing issues that are frequent findings in disaster-related audits.
•
Disaster Financial Management Guide: The Disaster Financial Management Guide provides
guidance for state, local, tribal, and territorial partners on establishing and implementing sound
disaster financial management practices.
EMPG Program Appendix | February 2021
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Training and Exercises
Integrated Preparedness Plan (IPP)
Recipients are expected to engage senior leaders and other whole community stakeholders to identify
preparedness priorities specific to training and exercise needs, which will guide development of a
state/territory multi-year IPP. Similar to the EMPG Program Work Plan development process, these
priorities should be informed by various factors, including jurisdiction-specific threats and hazards (i.e., the
THIRA); areas for improvement identified by real-world events and exercises (i.e. AARs); external
requirements such as state or national preparedness reports (i.e. SPRs), homeland security policy, and
industry reports; and accreditation standards, regulations, or legislative requirements. Recipients must
document these priorities, in conjunction with the Work Plan development process, and use them to deploy
a schedule of preparedness events and activities in the IPP. Information related to IPPs and Integrated
Preparedness Planning Workshops (IPPWs) can be found on the FEMA website at
https://www.fema.gov/emergency-managers/national-preparedness/exercises/hseep and
https://preptoolkit.fema.gov/.
Recipients shall ensure that their EMPG Program Work Plans and IPPs align with and are complementary
to one another and are used in tandem to support shared priorities for building and sustaining the
state/territory’s preparedness capabilities. Recipients should use the same shared set of priorities in both
their IPP and EMPG Program Work Plan, so that EMPG Program investments and projects help recipients
implement the planning, training, and exercise activities in their IPPs and advance their IPP priorities. To
this end, recipients should develop their IPPs and EMPG Program Work Plans together to create a planned,
organized, and methodical approach for closing capability gaps over multiple years. This will help ensure
that priorities for both the IPP and EMPG Program Work Plan are based on closing capability gaps
documented in their THIRA/SPR and other relevant sources of information. For example, if a recipient
selects Logistics and Distribution Management, Resilient Communications, and Housing as its priorities for
its EMPG Program Work Plan, those should also be priorities in its IPP. Additionally, IPPs should include
all planning, training, and exercise activities funded by the EMPG Program and included in EMPG Program
Work Plans, as well as activities funded by other sources. This will ensure that recipients’ preparedness
projects, investments, and activities are concentrated, focused, and oriented towards closing gaps related to
their top priorities, regardless of funding source.
Validating Capabilities through Exercises
All recipients are required to develop and maintain a progressive exercise program consistent with
Homeland Security Exercise and Evaluation Program (HSEEP) guidance in support of the National
Exercise Program (NEP). The NEP serves as the principal exercise mechanism for examining national
preparedness and measuring readiness. The NEP is a two-year cycle of exercises across the nation that
validates capabilities in all preparedness mission areas. The two-year NEP cycle is guided by Principals’
Strategic Priorities, established by the National Security Council, and informed by preparedness data from
jurisdictions across the Nation. See Exercises | FEMA.gov for additional information.
Although there are no minimum exercise requirements, FEMA Regional Administrators and State
Emergency Management Directors will negotiate an exercise program that addresses the priorities and
capability gaps identified through the collaborative work plan development process. These exercises must
be included in the FY 2021 EMPG Program Work Plan submitted for regional approval and should also be
included in the state/territory’s IPP. See the EMPG Program Work Plan section for additional guidance.
The NEP provides exercise sponsors the opportunity to receive exercise design and delivery assistance,
tools and resources, enhanced coordination, and the ability to directly influence and inform policy and
EMPG Program Appendix | February 2021
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preparedness programs. If you have any questions or would like to request assistance through the NEP,
please visit the NEP website or reach out to the NEP directly at NEP@fema.dhs.gov.
Reporting
•
All EMPG Program-funded exercise activities must be captured in the approved EMPG Program
Work Plan.
•
Recipients must have a current multi-year IPP that identifies preparedness priorities and activities.
The current multi-year IPP must be submitted to hseep@fema.dhs.gov and the regional EMPG
Program manager before January 31st of each year.
•
Recipients are encouraged to enter their exercise information into the Preparedness Toolkit at
https://preptoolkit.fema.gov/.
•
Recipients must submit AAR/IPs to hseep@fema.dhs.gov and copy their regional EMPG Program
manager and indicate which fiscal year’s funds were used (if applicable).
•
AAR/IPs must be submitted no later than December 31st of each year. For exercises conducted
during the final quarter of a calendar year, submission of AAR/IPs must occur within 90 days of
exercise completion. Regardless of conduct date, recipients are encouraged to submit AAR/IPs
within 90 days after completion of the single exercise or progressive series.
o Recipients are encouraged to submit AAR/IPs reflecting tabletop exercises that validate
critical plans or those reflecting large-scale functional or full-scale exercises that took place
at the state, territorial, tribal, or UASI level. Recipients are discouraged from submitting
AAR/IPs specific to local jurisdictions which reflect drills.
o If a state, territory, or local jurisdiction has experienced a major disaster and they would
like to request exemptions for a scheduled exercise, the recipient should send this request to
its assigned FEMA Regional EMPG Program manager through the Quarterly Performance
Progress Report. Exemptions will be reviewed on a case-by-case basis by the regional
EMPG Program manager.
o Recipients can access a sample AAR/IP template at https://preptoolkit.fema.gov/web/hseep-
resources/improvement-planning.
Training
Similar to the exercise guidance above, training activities should align to a current, Multi-Year IPP
developed through an annual IPPW and build from training gaps identified in the THIRA/SPR and work
plan development process. Further guidance concerning the IPP and the IPPW can be found at
https://preptoolkit.fema.gov/web/hseep-resources/home.
Training should foster the development of a community-oriented approach to emergency management that
emphasizes engagement at the community level, strengthens best practices, and provides a path toward
building sustainable resilience, all of which is included in the curriculum of the EMI Basic Academy. The
EMI Basic Academy provides a foundational education in emergency management as a way for emergency
managers to begin or advance their career. The goal of the Basic Academy is to support the early careers of
emergency managers through a training experience combining knowledge of all fundamental systems,
concepts, and practices of cutting-edge emergency management.
EMPG Program funds used for training should support the nationwide implementation of NIMS. The NIMS
Training Program establishes a national curriculum for NIMS and provides information on NIMS courses.
Recipients are encouraged to place emphasis on the core competencies as defined in the NIMS Training
Program. NIMS is also included in the curriculum of the EMI Basic Academy. The NIMS Training
Program can be found at https://www.fema.gov/emergency-managers/nims/implementation-training.
EMPG Program Appendix | February 2021
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NIMS implementation requires jurisdictions to ensure that their incident personnel receive pertinent NIMS
training in alignment with the NIMS Training Program. Jurisdictions report their NIMS implementation
status of their jurisdiction and sub-jurisdictions, including the training of personnel, using the 2021 SPR.
All EMPG Program-funded personnel are expected to be trained emergency managers. All EMPG Program-
funded personnel shall complete either the Independent Study courses identified in the Professional
Development Series or the National Emergency Management Basic Academy delivered either by EMI or at
a sponsored state, local, tribal, territorial, regional or other designated location. Further information on the
National Emergency Management Basic Academy and the Emergency Management Professional Program
can be found at: https://training.fema.gov/empp/. A complete list of Independent Study Program Courses
may be found at http://training.fema.gov/is.
In addition to training activities aligned to and addressed in the IPP, all EMPG Program-funded personnel
(including full- and part-time state, local, tribal, and territorial [SLTT] recipients and subrecipients) shall
complete the following training requirements and record proof of completion:
1) NIMS Training, Independent Study (IS)-100 (any version), IS-200 (any version), IS-700 (any
version), and IS-800 (any version)4, AND;
2) Professional Development Series (PDS) OR the Emergency Management Professionals Program
(EMPP) Basic Academy listed in the chart below.
Professional Development Series or Basic Academy
PDS
Professional Development Series
Basic Academy
Basic Academy Pre-requisites and Courses
IS-120.a: An Introduction to Exercises
OR
IS-100 (any version): Introduction to the
Incident Command System
IS-230.d: Fundamentals of Emergency
Management
IS-700 (any version): National Incident
Management System (NIMS)-An Introduction
IS-235.b: Emergency Planning
IS-800 (any version): National Response
Framework, An Introduction
IS-240.b: Leadership and Influence
IS-230.d: Fundamentals of Emergency
Management
IS-241.b: Decision Making and
Problem Solving
E/L101: Foundations of Emergency
Management
IS-242.b: Effective Communication
E/L102: Science of Disasters
IS-244.b: Developing and Managing
Volunteers
E/L103: Planning Emergency Operations
E/L104: Exercise Design
E/L105: Public Information & Warning
The EMI Basic Academy provides this foundational Emergency Management education. To ensure the
professional development of the emergency management workforce, the recipients must ensure a routine
capabilities assessment is accomplished and an IPP is developed and implemented.
4 NIMS training courses IS-100, IS-200, IS-700, and IS-800 only need to be taken once to fulfill requirements. Also,
previous versions of the IS courses are still considered as meeting the NIMS training requirement.
EMPG Program Appendix | February 2021
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Additional Training Information
Per FEMA Grant Programs Directorate Information Bulletin 432, Review and Approval Requirements for
Training Courses Funded Through Preparedness Grants, issued on July 19, 2018, states, territories, tribal
entities, and high-risk urban areas are no longer required to request approval from FEMA for personnel to
attend non-DHS FEMA training as long as the training is coordinated with and approved by the state,
territory, tribal, or high-risk urban area Training Point of Contact (TPOC) and falls within the FEMA
mission scope and the jurisdiction’s EOP.
FEMA will conduct periodic reviews of all state, territory, and urban area training funded by FEMA. These
reviews may include requests for all course materials and physical observation of, or participation in, the
funded training. If these reviews determine that courses are outside the scope of this guidance, recipients
will be asked to repay grant funds expended in support of those efforts.
For further information on developing courses using the instructional design methodology and tools that can
facilitate the process, SAAs and TPOCs are encouraged to review the NTED Training Resource and
Development Center (TRDC) website at https://www.firstrespondertraining.gov/frts/trdc/state.
NTED’s National Preparedness Course Catalog
This online searchable catalog features a compilation of courses managed by the three primary FEMA
training organizations: the CDP, EMI, and NTED. The catalog features a wide range of course topics in
multiple delivery modes FEMA for federal, state, local, territorial, and tribal audiences. The catalog is
located at http://www.firstrespondertraining.gov.
Reporting
•
All EMPG Program-funded training activities must be captured in the approved EMPG Program
Work Plan and should be included in the IPP. This includes training for which the only expenses
are for overtime and/or backfill costs associated with emergency management personnel attending
the training.
•
Recipients must report their NIMS implementation status of their jurisdiction and sub-jurisdictions,
including the training of personnel, in the applicable secondary NIMS assessment portion of the
URT as part of their THIRA/SPR submission.
•
Recipients must maintain proof of completion of training requirements.
•
Training Information Reporting System (“Web Forms”): Web Forms is an electronic data
management system built to assist SAA TPOCs and federal agencies to submit non-NTED training
courses for inclusion in the State/Federal-Sponsored Course Catalog. The information collected is
used in a two-step review process to ensure that the training programs adhere to the EMPG
Program’s intent and the course content is sound and current. While reporting training activities
through Web Forms is not required under the EMPG Program, the system remains available and
can be accessed through the FEMA Toolkit to support recipients in their own tracking of training
deliveries.
Reviewing and Updating Planning Products
Based on the applicant’s current THIRA/SPR, capability levels, resources, and plans should be reviewed on
an annual basis to determine if they remain relevant or need to be updated. This review should be based on
a current THIRA/SPR and utilize information gathered during the capability validation process. These
reviews will provide a means to determine priorities, direct preparedness actions, and calibrate goals and
objectives.
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Additional Considerations
Strengthening Governance Integration
FEMA preparedness grant programs are intended to support the core capabilities across the five mission
areas of Prevention, Protection, Mitigation, Response, and Recovery that are necessary to prepare for
incidents that pose the greatest risk to the Nation’s security. Each program reflects the Department’s intent
to build and sustain an integrated network of national capabilities across all levels of government and the
whole community. Disparate governance structures must be integrated and refined to ensure resources are
targeted to support the most critical needs of a community based on risk-driven, capabilities-based
planning. Strong and inclusive governance systems better ensure that disparate funding streams are
coordinated and applied for maximum impact.
FEMA requires that all governance processes that guide the allocation of preparedness grant funds adhere to
the following guiding principles:
•
Coordination of Investments: Resources must be allocated to address the most critical capability
needs as identified in the SPR and coordinated among affected preparedness stakeholders.
•
Transparency: Stakeholders must be provided visibility on how preparedness grant funds are
allocated and distributed, and for what purpose.
•
Substantive Local Involvement: The tools and processes that are used to inform the critical
priorities, which FEMA grants support, must include local government representatives. At the state
and regional levels, local risk assessments must be included in the overarching analysis to ensure
that all threats and hazards are accounted for.
•
Accountability: FEMA recognizes that unique preparedness gaps exist at the local level. Grant
recipients are responsible for ensuring the effective use of funds to address those gaps and for
maintaining and sustaining existing capabilities.
•
Support of Regional Coordination: Inter/intra-state partnerships and dependencies at the state and
regional levels, including those within metropolitan areas, must be recognized.
Program Performance Reporting Requirements
Performance Progress Reports (PPR)
Recipients are responsible for providing performance reports to FEMA on a quarterly basis. As explained in
the Standardized Programmatic Reporting section below, the Quarterly PPRs must be based on the
approved EMPG Program Work Plan and are due no later than 30 days after the end of the quarter.
Although not mandatory, recipients are encouraged to use the updated EMPG Program Work Plan Template
– specifically the Grant Activities Outline – to report on the status of planned project activities, any risks
that may affect project progress or success, and updates to project schedules. The PPR (in the form of an
updated Work Plan) shall be submitted in ND Grants. See EMPG Program Work Plan section for additional
guidance.
Programmatic Reporting Periods and Due Dates
The following reporting periods and due dates apply for the PPR:
Reporting Period
Report Due Date
October 1 – December 31
January 30
January 1 – March 31
April 30
April 1 – June 30
July 30
July 1 – September 30
October 30
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Standardized Programmatic Reporting for the EMPG Program
The EMPG Program Work Plan Template has been modified to standardize data collection, which enables
improved analysis and reporting. The EMPG Program Work Plan includes eight components: (1) Grant
Investment Strategy, (2) Budget Overview, (3) Grant Activities Outline, (4) Project Activities Outline, (5)
Personnel Data Table, (6) Training Data Table, (7) Exercise Data Table, and (8) Detailed Budget. Baseline
data on personnel, training, and exercises, as well as the Grant Activities Outline and Project Activities
Outline, must be provided in the EMPG Program Work Plan at the time of application and will form the
basis of the Quarterly PPR submissions.
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EMPG Program Funding Guidelines
Allowable Costs
Management and Administration (M&A)
M&A activities are those defined as directly relating to the management and administration of EMPG
Program funds, such as financial management and monitoring. It should be noted that salaries of state and
local emergency managers are not typically categorized as M&A, unless the state or local EMA chooses to
assign personnel to specific M&A activities.
If the SAA is not the EMA, the SAA is not eligible to retain funds for M&A. M&A costs are allowable for
both state and local-level EMAs. The state EMA may use up to 5% of the EMPG Program award for M&A
purposes. In addition, local EMAs may retain and use up to 5% of the amount received from the state for
local M&A purposes.
Allowable Indirect Costs
Indirect costs are allowable under this program as described in 2 C.F.R. Part 200, including 2 C.F.R. §
200.414. Applicants with a current negotiated indirect cost rate agreement that desire to charge indirect
costs to an award must provide a copy of their negotiated indirect cost rate agreement at the time of
application. Not all applicants are required to have a current negotiated indirect cost rate agreement.
Applicants that are not required by 2 C.F.R. Part 200 to have a negotiated indirect cost rate agreement but
are required by 2 C.F.R. Part 200 to develop an indirect cost rate proposal must provide a copy of their
proposal at the time of application. Applicants who do not have a current negotiated indirect cost rate
agreement (including a provisional rate) and wish to charge the de minimis rate must reach out to the Grants
Management Specialist for further instructions. Applicants who wish to use a cost allocation plan in lieu of
an indirect cost rate must also reach out to the Grants Management Specialist for further instructions. Post-
award requests to charge indirect costs will be considered on a case-by-case basis and based upon the
submission of an agreement or proposal as discussed above or based upon the de minimis rate or cost
allocation plan, as applicable.
Whole Community Preparedness
EMPG Program funds may be used to foster whole community preparedness for disasters and emergencies
as stated in the 2018 – 2022 FEMA Strategic Plan, particularly Objective 1.3, Help People Prepare for
Disasters. Recipients, and FEMA must learn from and work with a broad and inclusive base of stakeholders
to understand the circumstances and challenges different groups of people face, particularly those who may
have the hardest time in the aftermath of a disaster, such as the aging population and those with access and
functional needs. By engaging these stakeholders, EMPG Program recipients can help FEMA develop and
promote a suite of well-targeted solutions for individuals and communities to adopt. Recipients should
coordinate preparedness initiatives with FEMA and whole community partners to efficiently apply federal
funding to reach the goal of individual and community resilience.
Planning
Planning spans all five mission areas of the Goal and provides a methodical way to engage the whole
community in the development of a strategic, operational, and/or community-based approach to
preparedness. EMPG Program funds may be used to develop or enhance emergency management planning
activities. Some examples include:
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Emergency Operations Plan
•
Maintaining a current EOP that is aligned with guidelines set out in Comprehensive Preparedness
Guide (CPG) 101: Developing and Maintaining Emergency Operations Plans
•
Modifying existing incident management and emergency operations plans
•
Developing/enhancing large-scale and catastrophic event incident plans
Communications Plans
•
Developing and updating Statewide Communication Interoperability Plans
•
Developing and updating Tactical Interoperability Communications Plans
Administrative Plans
•
Developing/enhancing financial and administrative procedures for use before, during, and after
disaster events in support of a comprehensive emergency management program
Whole Community Engagement/Planning
•
Developing or enhancing mutual aid agreements/compacts, including required membership in
EMAC
•
Developing/enhancing emergency operations plans to integrate citizen/volunteer and other NGO
resources and participation
•
Integrating program design and delivery practices that ensure representation and services for under-
represented, diverse populations that may be more impacted by disasters, including children,
seniors, individuals with disabilities or access and functional needs, individuals with diverse culture
and language use, individuals with lower economic capacity, and other underserved populations
Resource Management Planning
•
Developing/enhancing logistics and resource management plans
•
Developing/enhancing volunteer and/or donations management plans
Shelter and Evacuation Planning
•
Developing/enhancing sheltering and evacuation plans, including plans for alerts/warning, crisis
communications, pre-positioning of equipment for areas potentially impacted by mass evacuations,
and re-entry
Recovery Planning
•
Disaster housing planning, such as creating/supporting a state disaster housing task force and
developing/enhancing state disaster housing plans
•
Pre-event response, recovery, and mitigation plans in coordination with state, local, and tribal
governments
•
Developing/enhancing other response and recovery plans
Developing recovery plans and preparedness programs consistent with the principles and guidance
in the National Disaster Recovery Framework (NDRF) that will provide the foundation for recovery
programs and whole community partnerships. Preparedness and pre-disaster planning were given
special attention within the NDRF with specific guidance: Planning for a Successful Disaster
Recovery (pages 63-70). For more information on the NDRF see National Disaster Recovery
Framework | FEMA.gov.
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Continuity Planning
Continuity planning and operations are an inherent element of each core capability. Continuity operations
increase resilience and the probability that organizations can perform essential functions. FEMA develops
and promulgates Federal Continuity Directives (FCDs) to establish continuity program and planning
requirements for executive departments and agencies and Continuity Guidance Circulars (CGCs) for SLTT
governments, non-governmental organizations, and private sector critical infrastructure owners and
operators. This direction and guidance assist in developing capabilities for continuing the essential functions
of federal, state, local, tribal, territorial governmental entities as well as the public/private critical
infrastructure owners, operators, and regulators enabling them.
Presidential Policy 40, FCD 1, FCD 2, CGC 1, and CGC 2 outline the overarching continuity requirements
and guidance for organizations and provide guidance, methodology, and checklists. For additional
information on continuity programs, guidance, and directives, visit http://www.fema.gov/guidance-
directives and https://www.fema.gov/about/offices/continuity.
Allowable continuity planning activities include the development of the following:
•
Continuity of Operations (COOP) and Continuity of Government (COG) planning products for the
continuance of essential functions and associated leadership;
•
Risk-based needs assessments based on the THIRA to inform risk mitigation efforts to ensure the
continuity of essential functions and associated leadership; and
•
Public and private sector outreach and messaging regarding continuity resilience benefits and
strategies.
Organization
Per the Robert T. Stafford Disaster Relief and Emergency Assistance Act, Pub. L. No. 93-288, as amended,
(42 U.S.C. §§ 5121-5207), EMPG Program funds may be used for all-hazards emergency management
operations, staffing, and other day-to-day activities in support of emergency management, including hazard
mitigation staffing of the State Hazard Mitigation Officer (SHMO) position; staffing CERT and Citizen
Corps positions at the state and local levels to promote whole community engagement in all phases of
emergency management; performing closeout activities on FEMA Disaster Assistance grants; staffing
permanent technical advisors on children’s needs at the state, local, tribal, and territorial levels; and
supporting fusion center analysts who are directly involved in all-hazards preparedness activities as defined
by the Stafford Act. Proposed staffing activities should be linked to accomplishing the activities outlined in
the EMPG Program Work Plan. Recipients are encouraged to fund at least one dedicated Planner, Training
Officer, and Exercise Officer. Personnel costs, including salary, overtime, compensatory time off, and
associated fringe benefits, are allowable EMPG Program costs and must comply with 2 C.F.R. Part 200,
Subpart E – Cost Principles.
Federal (and Mutual Aid) Emergency Response Official (F/ERO) Credentialing and Validation
The following costs related to F/ERO credentialing and validation are allowable under the EMPG Program:
•
Working group meetings and conferences relating to emergency responder credentialing and
validation;
•
Compiling data to enter into an emergency responder repository;
•
Coordinating with other state, local, territorial, and tribal partners to ensure interoperability among
existing and planned credentialing and validation systems and equipment; and
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•
Planning to incorporate emergency responder identity and credential validation into training and
exercises.
Equipment
Allowable equipment categories for the EMPG Program are listed in the Authorized Equipment List (AEL).
Unless otherwise stated, equipment must meet all mandatory regulatory and/or FEMA-adopted standards to
be eligible for purchase using these funds. In addition, agencies will be responsible for obtaining and
maintaining all necessary certifications and licenses for the requested equipment. Allowable equipment
includes equipment from the following AEL categories:
•
Personal Protective Equipment (PPE) (Category 1)
•
Information Technology (Category 4)
•
Cybersecurity Enhancement Equipment (Category 5)
•
Interoperable Communications Equipment (Category 6)
•
Detection Equipment (Category 7)
•
Power Equipment (Category 10)
•
Chemical, Biological, Radiological, Nuclear, and Explosive (CBRNE) Reference Materials
(Category 11)
•
CBRNE Incident Response Vehicles (Category 12)
•
Physical Security Enhancement Equipment (Category 14)
•
CBRNE Logistical Support Equipment (Category 19)
•
Other Authorized Equipment (Category 21)
In addition to the above, general purpose vehicles may be procured in order to carry out the responsibilities
of the EMPG Program. If recipients have questions concerning the eligibility of equipment not specifically
addressed in the AEL, they should contact their regional EMPG Program manager for clarification.
Applicants should analyze the cost benefits of purchasing versus leasing equipment, especially high cost
items and those subject to rapid technical advances. Large equipment purchases must be identified and
explained. For more information regarding property management standards for equipment, please reference
2 C.F.R. Part 200, including 2 C.F.R. §§ 200.310, 200.313, and 200.316. Also see 2 C.F.R. §§ 200.216,
200.471, and FEMA Policy #405-143-1 regarding prohibitions on covered telecommunications equipment
or services.
In general, with exception of critical emergency supplies and the associated inventory management plan,
equipment included in the AEL may be purchased without separate approval from FEMA. However, as
with all grant-funded activities, the equipment purchase must be well justified and reasonable. Furthermore,
the purchase must be supported by the approved Work Plan. If the equipment is not clearly supported by the
approved work plan, the recipient must seek advance approval from the applicable FEMA Regional Grant
Program Office prior to purchasing the equipment, and an updated Work Plan may be required.
FEMA will consider requests to purchase equipment that is not listed in the AEL on a case-by-case basis.
Such requests should be submitted in writing to the applicable FEMA Regional Grant Program Office.
FEMA’s review and approval of such requests will involve both the FEMA regional office and GPD
program staff to ensure nationwide consistency in the decision-making process and to support any
necessary updates to the AEL.
Requirements for Small Unmanned Aircraft Systems
All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply
with IB 426 and also include a description of the policies and procedures in place to safeguard individuals’
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privacy, civil rights, and civil liberties of the jurisdiction that will purchase, take title to or otherwise use the
sUAS equipment.
Acquisition and Use of Technology to Mitigate UAS (Counter-UAS)
In August 2020, FEMA alerted of an advisory guidance document issued by DHS, the Department of
Justice, the Federal Aviation Administration, and the Federal Communications Commission:
https://www.dhs.gov/publication/interagency-legal-advisory-uas-detection-and-mitigation-technologies.
The purpose of the advisory guidance document is to help non-federal public and private entities better
understand the federal laws and regulations that may apply to the use of capabilities to detect and mitigate
threats posed by UAS operations (i.e., Counter-UAS or C-UAS).
The Departments and Agencies issuing the advisory guidance document, and FEMA, do not have the
authority to approve non-federal public or private use of UAS detection or mitigation capabilities, nor do
they conduct legal reviews of commercially available product compliance with those laws. The advisory
does not address state and local laws nor potential civil liability, which UAS detection and mitigation
capabilities may also implicate.
It is strongly recommended that, prior to the testing, acquisition, installation, or use of UAS detection
and/or mitigation systems, entities seek the advice of counsel experienced with both federal and state
criminal, surveillance, and communications laws. Entities should conduct their own legal and technical
analysis of each UAS detection and/or mitigation system and should not rely solely on vendors’
representations of the systems’ legality or functionality. Please also see the DHS press release on this topic
for further information: https://www.dhs.gov/news/2020/08/17/interagency-issues-advisory-use-technology-
detect-and-mitigate-unmanned-aircraft.
Funding for Critical Emergency Supplies
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an
allowable expense under the EMPG Program. FEMA must approve a state’s five-year viable inventory
management plan prior to allocating grant funds for stockpiling purposes. The five-year plan should include
a distribution strategy and related sustainment costs if the grant expenditure is over $100,000.
Training
EMPG Program funds may be used for a range of emergency management-related training activities to
enhance the capabilities of state and local emergency management personnel through the establishment,
support, conduct, and attendance of training. Training activities should align to a current, multi-year IPP
developed through an annual IPPW and build from training gaps identified in the THIRA/SPR process.
Further guidance concerning the IPP and the IPPW can be found at https://preptoolkit.fema.gov/web/hseep-
resources/program-management.
EMPG Program funds may be used for emergency management-related training activities to enhance the
capabilities of state and local emergency management personnel. Training activities should align to a
current, Multi-Year IPP developed through an annual Integrated Preparedness Planning Workshop (IPPW)
and build from training gaps identified in the THIRA/SPR process. Further guidance concerning the IPP
and the IPPW can be found at https://preptoolkit.fema.gov/web/hseep-resources/program-management.
Training should:
•
Foster the development of a community-oriented approach to emergency management that
emphasizes engagement at the community level;
•
Strengthen best practices; and,
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•
Provide a path toward building sustainable resilience.
Allowable training-related costs include the following:
•
Funds Used to Develop, Deliver, and Evaluate Training: Includes costs related to administering
training, such as planning, scheduling, facilities, materials and supplies, reproduction of materials,
and equipment. Training should provide the opportunity to demonstrate and validate skills learned,
as well as to identify any gaps in these skills. Any training or training gaps, including those for
children and individuals with disabilities or access and functional needs, should be identified in the
Multi-Year IPP and addressed in the training cycle. States are encouraged to use existing training
rather than developing new courses. When developing new courses, states are encouraged to apply
the Analyze, Design, Develop, Implement, and Evaluate (ADDIE) model for instruction design.
More information is available at https://www.firstrespondertraining.gov.
•
Overtime and Backfill: Overtime costs, including payments related to backfilling personnel, that
are the direct result of attendance at FEMA and/or approved training courses and programs are
allowable. These costs are allowed only to the extent the payment for such services is in accordance
with the policies of the state or unit(s) of local government and has the approval of the state or
FEMA, whichever is applicable. In no case is dual compensation allowable. That is, an employee of
a unit of government may not receive compensation from their unit or agency of government and
from an award for a single period of time (e.g., 1 p.m. to 5 p.m.), even though such work may
benefit both activities.
•
Travel: Travel costs (e.g., airfare, mileage, per diem, and hotel) are allowable as expenses by
employees who are on travel status for official business related to approved training. International
travel is not an allowable cost under this program unless approved in advance by FEMA.
•
Hiring of Full- or Part-Time Staff or Contractors/Consultants: Full- or part-time staff or
contractors/consultants may be hired to support direct training-related activities. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§
200.317-200.327. Payment of salaries and fringe benefits must be in accordance with the policies of
the state or unit(s) of local government and have the approval of the state or FEMA, whichever is
applicable.
•
Certification/Recertification of Instructors: Costs associated with the certification and re-
certification of instructors are allowed. States are encouraged to follow the FEMA Instructor
Quality Assurance Program to ensure a minimum level of competency and corresponding levels of
evaluation of student learning. This is particularly important for those courses that involve training
of trainers.
Additional types of allowable training or training-related activities include, but are not limited to:
•
Developing/enhancing systems to monitor training programs
•
Conducting all-hazards emergency management training
•
Attending EMI training or delivering EMI train-the-trainer courses
•
Attending other FEMA-approved emergency management training
•
State-approved, locally sponsored CERT training
•
Mass evacuation training at local, state, territorial and tribal levels
Exercises
Allowable exercise-related costs include:
EMPG Program Appendix | February 2021
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•
Funds Used to Design, Develop, Conduct and Evaluate Preparedness Exercises: This includes
costs related to planning, meeting space and other meeting costs, facilitation costs, materials and
supplies, travel, and documentation. Recipients are encouraged to use free public
space/locations/facilities whenever available prior to the rental of space/locations/facilities.
Exercises should provide the opportunity to demonstrate and validate skills learned, as well as to
identify any gaps in these skills. Gaps identified during an exercise, including those for children and
individuals with disabilities or access and functional needs, should be included in the AAR/IP and
addressed in the exercise cycle.
•
Hiring of Full- or Part-Time Staff or Contractors/Consultants: Full- or part-time staff may be
hired to support direct exercise activities. Payment of salaries and fringe benefits must be in
accordance with the policies of the state or unit(s) of local government and have the approval of the
state or FEMA, whichever is applicable. The services of contractors/consultants may also be
procured to support the design, development, conduct, and evaluation of exercises. Hiring of
contractors/consultants must follow the applicable federal procurement requirements at 2 C.F.R. §§
200.317-200.327.
•
Overtime and Backfill: The entire amount of overtime costs, including payments related to
backfilling personnel, that are the direct result of time spent on the design, development and
conduct of exercises are allowable expenses. These costs are allowed only to the extent the payment
for such services is in accordance with the policies of the state or unit(s) of local government and
has the approval of the state or FEMA, whichever is applicable. Dual compensation is never
allowable, meaning, in other words, that an employee of a unit of government may not receive
compensation from their unit or agency of government and from an award for a single period of
time (e.g., 1:00 p.m. to 5:00 p.m.), even though their work may benefit both entities.
•
Travel: Travel costs (e.g., airfare, mileage, per diem, hotel) are allowable as expenses by
employees who are on travel status for official business related to the planning and conduct of the
exercise activities.
•
Supplies: Supplies are items that are expended or consumed while planning and conducting the
exercise activities (e.g., gloves, non-sterile masks, and disposable protective equipment).
•
HSEEP Implementation: This refers to costs related to developing and maintaining an exercise
program consistent with HSEEP.
•
Other Items: These costs are limited to items consumed in direct support of exercise activities,
such as space/locations rentals for planning and conducting an exercise, equipment rentals (e.g.
portable toilets, tents), food/refreshments, and the procurement of other essential nondurable goods.
Costs associated with inclusive practices and the provision of reasonable accommodations and
modifications that facilitate full access for children and adults with disabilities are allowable.
Unauthorized exercise-related costs include:
•
Reimbursement for maintenance and/or wear and tear costs of general use vehicles (e.g.,
construction vehicles) and emergency response apparatus (e.g., fire trucks, ambulances). The only
vehicle costs that are reimbursable are fuel/gasoline or mileage.
•
Equipment that is purchased for permanent installation and/or use beyond the scope of exercise
conduct (e.g., electronic messaging signs)
•
Durable and nondurable goods purchased for installation and/or use beyond the scope of exercise
conduct
Construction and Renovation
Construction and renovation projects for a state, local, tribal, or territorial government’s principal
Emergency Operations Center (EOC), as defined by the SAA are allowable under the EMPG Program.
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FEMA must provide written approval prior to the use of any EMPG Program funds for construction or
renovation. Requests for EMPG Program funds for construction of an EOC must be accompanied by an
EOC Investment Justification (located in the Related Documents tab of the EMPG Program Grants.gov
posting) to their regional EMPG Program manager for review. Additionally, recipients are required to
submit a SF-424C Form and Budget detail citing the project costs and an SF-424D Form for standard
assurances for the construction project.
The above examples are not intended to exclude other construction projects as potentially allowable costs.
For example, construction of a facility for the storage of critical emergency supplies, as a Point of
Distribution (POD) for emergency distribution, and/or to serve as a staging area for deployment of
emergency response resources is potentially an allowable expense. Other construction or renovation
projects, such as a secondary or local EOC, will be considered on a case-by-case basis, as described below
in the guidance regarding advance written approval.
EHP Compliance
Recipients and subrecipients proposing projects that have the potential to impact the environment,
including, but not limited to, the construction of communication towers, modification or renovation of
existing buildings, structures, and facilities, new construction including replacement of facilities, and some
training activities, must participate in the FEMA EHP review process.
Recipients and subrecipients are also encouraged to have completed as many steps as possible for a
successful EHP review in support of their proposal for funding (e.g., coordination with their State Historic
Preservation Office to identify potential historic preservation issues and to discuss the potential for project
effects, compliance with all state and EHP laws and requirements). Projects for which the recipient believes
an Environmental Assessment (EA) may be needed, as defined in DHS Instruction Manual 023-01-001-01,
Revision 01, FEMA Directive 108-1, and FEMA Instruction 108-1-1, must also be identified to the regional
EMPG Program manager within six months of the award, and completed EHP review materials must be
submitted at least 12 months before the end of the period of performance. EHP review packets should be
sent to gpdehpinfo@fema.gov. Please refer to the EHP section of this Manual for additional information on
EHP requirements.
Advance Approval Requirement
Recipients must receive advance written approval from FEMA prior to the use of any annual EMPG
Program funds for construction or renovation, including such activities at the sub-recipient level. Such costs
would need to fall within the scope of the recipient’s final approved Work Plan, otherwise an updated Work
Plan may be required. Such requests should be submitted in writing to the applicable FEMA Regional Grant
Program Office. FEMA’s review and approval will involve both the regional office and FEMA Grant
Programs Directorate.
Real Property Use and Disposition Requirements
Real property improved under a federal award falls under the 2 C.F.R. Part 200 guidance for real property.
In accordance with 2 C.F.R. § 200.311, a recipient or subrecipient may only use real property acquired or
improved under a federal award for the originally authorized purpose, as long as it is needed for that
purpose, during which time the recipient or subrecipient must not dispose of or encumber its title or other
interests. However, upon the end of that period where it needs the property for the originally authorized
purpose (i.e., the functional use of the property for which FEMA awarded the grant), the recipient or
subrecipient will then dispose of the property in keeping with the requirements set forth in 2 C.F.R. §
200.311.
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When a grant-funded property is no longer needed for the originally authorized purpose, the recipient or
subrecipient (through the pass-through entity) must obtain disposition instructions from the cognizant
FEMA Regional Administrator or the pass-through entity.
Construction of Communication Towers
When applying for funds to construct communication towers, recipients and subrecipients must submit
evidence that the Federal Communication Commission’s (FCC) Section 106 review process has been
completed and submit all documentation resulting from that review to FEMA prior to submitting materials
for EHP review.
Davis-Bacon Act Compliance
EMPG Program recipients using funds for construction projects must comply with the Davis-Bacon Act and
subsequent legislation (40 U.S.C. §§ 3141 et seq.). See 42 U.S.C. § 5196(j)(9). Grant recipients must ensure
that their contractors or subcontractors for construction projects pay workers no less than the prevailing
wages for laborers and mechanics employed on projects of a character similar to the contract work in the
civil subdivision of the state in which the work is to be performed. Additional information regarding
compliance with the Davis-Bacon Act, including Department of Labor (DOL) wage determinations, is
available at https://www.dol.gov/whd/govcontracts/dbra.htm.
Acquisition of Real Property
Acquisition of real property is permissible if such property is needed to support other allowable program
costs or activities.
Advance Approval Requirement
Consistent with the requirements outlined above regarding construction activities, recipients and
subrecipients (through the pass-through entity) must obtain advance written approval from the cognizant
FEMA Regional Administrator prior to obligating annual EMPG Program funds for acquisition of real
property. Additionally, in cases of acquisition or improving real property, recipients are required to submit a
SF-429-B, Real Property Status Report, Attachment B providing details of the relevant property to be
acquired.
Property Use, Reporting, and Disposition Requirements
The acquisition, use, and disposition of real property shall be subject to the provisions of 2 C.F.R. Part 200.
In accordance with 2 C.F.R. Part 200, recipients and subrecipients are required to report on the status of the
acquired property on an annual basis using SF-429-A Real Property Status Report, Attachment A (General
Reporting). Such reporting shall continue as long as the property is being used for the originally authorized
purpose. Please refer to IB 458a for additional guidance on disposition requirements.
Leasing of Real Property
Leasing of real property is permissible if the property is needed to support other allowable annual EMPG
Program activities.
Advance Approval Requirement
Recipients and subrecipients (through the pass-through entity) must obtain advance written approval from
the cognizant FEMA Regional Administrator prior to obligating annual EMPG Program funds for the
leasing of real property.
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Allowable Period of Lease Expenses
In cases where a property will be leased and the lease will be paid in full or in part EMPG Program funds,
any costs associated with the lease that are charged to an EMPG Program award must occur within the
period of performance of the associated award(s). Real property lease costs must also comply with 2 C.F.R.
Part 200.
Maintenance and Sustainment
Use of FEMA preparedness grant funds for maintenance contracts, warranties, repair or replacement costs,
upgrades, and user fees are allowable under all active grant awards, unless otherwise noted.
EMPG Program funds are intended to support the Goal and fund activities and projects that build and
sustain the capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover
from those threats and hazards that pose the greatest risk to the security of the Nation. To assist recipients in
meeting this objective, the policy set forth in IB 379: Guidance to State Administrative Agencies to
Expedite the Expenditure of Certain DHS/FEMA Grant Funding allows for the expansion of eligible
maintenance and sustainment costs, which must be:
1) In direct support of existing capabilities;
2) An otherwise allowable expenditure under the applicable grant program;
3) Tied to one of the core capabilities in the five mission areas contained within the Goal, and;
4) Shareable through the EMAC.
Additionally, eligible costs may also be in support of equipment, training, and critical resources that have
previously been purchased with either federal grant funding or any other source of funding other than
FEMA preparedness grant program dollars.
Unallowable Costs
Grant funds may not be used for:
•
Unallowable Equipment: Grant funds must comply with IB 426 and may not be used for the
purchase of firearms, ammunition, grenade launchers, bayonets, or weaponized aircraft, vessels, or
vehicles of any kind with weapons installed
•
Expenditures for weapons systems and ammunition
•
Costs to support hiring sworn public safety officers for the purposes of fulfilling traditional public
safety duties or to supplant traditional public safety positions and responsibilities
•
Activities and projects unrelated to the completion and implementation of the EMPG Program
Recipients should consult with their regional EMPG Program manager prior to making any investment that
does not clearly meet the allowable expense criteria established in this Manual and the EMPG Program
NOFO.
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EMPG Program Work Plan
Submission of an EMPG Program Work Plan is mandatory, as it is a required component of the EMPG
Program application. The Work Plan outlines the state’s emergency management sustainment and
enhancement efforts, including new and ongoing activities and projects, that are driven by identified
preparedness priorities and proposed for the EMPG Program period of performance. An EMPG Program
Work Plan Template (available on the Grants.gov EMPG Program application page and on the Fema.gov
website at https://www.fema.gov/grants/preparedness/emergency-management-performance) is provided to
facilitate the work plan development process. The submitted Work Plan must address all the information
requirements included in the Work Plan Template and in the supplemental guidance included in this
section. Therefore, EMPG Program applicants are strongly encouraged to use the provided EMPG Program
Work Plan Template.
Prior to submission of the EMPG Program Work Plan, the applicant must work with the Regional
Administrator or designated regional FEMA program manager to identify three to five priority areas which
will serve as the focus for EMPG Program-funded investments. The priorities must be mutually agreed to
by the applicant and Regional Administrator and should be primarily driven by the THIRA/SPR process –
specifically, the outputs from the THIRA/SPR process – and other relevant information sources. Priorities
should also reflect those included in each recipient's IPP so that recipients are focusing all investments,
projects, and other resources on a common set of priorities. As they select priorities, recipients should
consider which capability gaps would be most operationally consequential, must be closed most urgently,
and could be meaningfully addressed within the period of performance. Applicants should refer to the
EMPG Program NOFO for further guidance on the priority identification process.
Applicants must set at least one performance goal for each priority area that achieves a specific outcome.
Each goal must be specific; measurable; achievable within the period of performance; relevant to the
priority area; and have a target date for completion. Applicants must describe how achieving each goal or
objective will impact the priority area it supports by the end of the period of performance. Each goal must
include an estimate quantifying the extent to which the supporting investments will close capability gaps
(e.g. “Increase the number of people who can find and secure long-term housing within 1 year of an
incident by 10%”). The new EMPG Program Work Plan Template includes instructions and examples to
help guide this process, so that recipients can develop goals that focus on achieving specific outcomes.
The Regional Administrator or designated FEMA Regional Program Manager will ensure that the mutually
agreed priorities are fully addressed in the EMPG Program Work Plan. In addition, the EMPG Program
Regional Administrator must approve final Work Plans before states may draw down EMPG Program
funds. Grant funds will be released upon approval of the state’s final Work Plan.
Following work plan approval, regional EMPG Program managers will work closely with recipients to
monitor progress against the Work Plans during the performance period and may request further
documentation from the recipients to clarify the projected Work Plan. Further, in accordance with 2 C.F.R.
§ 200.308 – Revision of budget and program plans, any changes to the approved Work Plan – including
changes in project scope and budget changes within any direct cost category exceeding 10 percent of the
total award amount – will require advance approval from the Regional Administrator or designated regional
FEMA program manager.
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EMPG Program Work Plan Instructions
The EMPG Program Work Plan Template has been updated to support the collection of objective
information and quantitative data that will allow FEMA to more effectively measure program effectiveness
and investment impacts. This also enables compliance with 2 C.F.R. § 200.301, which requires federal
awarding agencies to measure recipient performance to show achievement of program goals and objectives,
share lessons learned, improve program outcomes, and foster adoption of promising practices. To this end,
the new EMPG Program Guidance and Work Plan requires recipients to link EMPG Program-funded
investments to THIRA/SPR results and other relevant materials that inform capability priorities and needs –
and to include specific performance measures that will allow FEMA to measure the impact of those
investments based on the core capabilities that are addressed.
The new EMPG Program Work Plan Template largely complements the THIRA/SPR process outlined in
Comprehensive Preparedness Guide (CPG) 201, Third Edition (CPG 201, v3). As noted in CPG 201, v3, a
coordinated approach to track investments, and understanding the return on investment, can help improve
the investment effectiveness. Tracking how EMPG Program-funded investments result in specific,
quantitative changes in capabilities can help guide communities’ strategic planning considerations and
inform resource allocation decisions that will maximize effectiveness in building or sustaining capabilities.
Therefore, applicants are encouraged to refer to CPG 201, v3, along with their most recent THIRA and
SPR, when developing their EMPG Program Work Plan.
The Work Plan Template consists of a Grant Investment Strategy; Budget Overview; Grant Activities
Outline; Project Activities Outline; Personnel Data Table; Training Data Table; Exercise Data Table; and
Detailed Budget. As explained above, the focus of the updates is on improving data collection to better
enable measurement of grant outcomes. Therefore, the narrative content is minimized and many of the cells
include dropdowns for selecting applicable data. This approach also helps to simplify the Work Plan
development process.
Instructions for each Work Plan section are provided below. Additional guidance and instructions are
provided in the EMPG Program Work Plan Template.
Grant Investment Strategy
The intent of the Grant Investment Strategy tab of the Work Plan Template is to provide an overview of the
state/territory's preparedness investment strategy. It should serve as the foundation for completing the
remainder of the Work Plan. It includes separate sections to explain:
•
The most recent THIRA/SPR results;
•
Significant risks and capability gaps that currently exist;
•
Resulting preparedness priorities;
•
The performance goals associated with each priority area; and,
•
The anticipated impact of the proposed EMPG Program-funded investments on the identified
preparedness priorities.
For the priorities/performance goals section, the applicant should identify the three to five priorities that
were mutually agreed to and approved between the Regional Administrator and the state/territory. The
reference materials used to identify the priorities should be cited and their relevance explained in this
section.
EMPG Program Appendix | February 2021
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At least one performance goal should be identified for each priority area. Each goal must be specific,
measurable, achievable within the period of performance, relevant to the priority area, and have a target
date for completion (i.e., SMART goal). It should describe how achieving each goal will impact the priority
area it supports by the end of the period of performance.
Budget Overview
The Budget Overview tab is auto populated based on data entered in the Detailed Budget tab. No data is
entered directly into the Budget Overview tab; rather, it summarizes the overall EMPG Program budget
entered on the Detailed Budget tab into the standard cost categories, mission areas, and core capabilities,
along with the federal and non-federal share for each.
Grant Activities Outline
The Grant Activities Outline is used to capture the proposed EMPG Program-funded projects and link them
to the identified priorities, performance goals, and gaps or needs. Coupled with the Project Activities
Outline, the Grant Activities Outline supports identification and tracking of EMPG Program-funded project
outcomes, which will enable better understanding of the impacts of those investments relative to the
performance goals and the associated core capabilities.
The worksheet includes sections that allow the applicant to identify the performance goals that are
supported by each project and the milestones that are critical to accomplishing each goal. Additional
guidance on performance goals and milestones, including specific examples of each, are provided below.
The worksheet also requires the applicant to explain the objective and anticipated impact of each project
relative to the associated priorities, performance goals, and related core capabilities:
•
The “Project Objective” should explain what the project will accomplish; specifically, how the
project will address the identified gap or need and how it supports one or more of the identified
performance goals.
•
The “Anticipated Project Impact” should explain the expected project outcome relative to the
associated priorities and performance goals.
•
The impact statement should include a quantitative estimate of the degree to which the project will
contribute to achieving the identified performance goal (see hierarchy example below).
Effective completion of the Grant Activities Outline requires an understanding of the established planning
hierarchy. Priorities are at the top of the hierarchy, followed by performance goals that define a clear
outcome or end-state and provide the basis for addressing each priority. Project proposals should be
identified based on the performance goals. High priority capability gaps or needs identified through the
THIRA/SPR process and other assessments are also used to inform project selection and to identify specific
project objectives. Project objectives, and accompanying impact statements, should complement the
performance goals by including similar outcome-focused metrics, as explained above. Lastly, project
activities are identified. Project activities are key components and/or milestones that are critical to
successful completion of the project. An example of this hierarchy is provided below:
❖ Priority: Logistics and Supply Chain Management
➢ Performance Goal: Within three years, the [state/territory] will have the capability to identify
and mobilize life-sustaining commodities, resources, and services to 10,000 people requiring
shelter and 100,000 people requiring food and water, within 24 hours of an incident, and to
maintain the distribution system for at least 30 days.
EMPG Program Appendix | February 2021
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•
Project: Update State Logistics and Distribution Management Plan, and qualify 40
additional personnel for logistics operations in NQS.
o Project Objective/Impact: Increase capacity to identify and mobilize life-sustaining
commodities, resources, and services to people requiring shelter, food, and water by
50%, allowing the state to do so for 7,500 people requiring shelter and 75,000 requiring
food and water within 24 hours of an incident and maintain that distribution system for
at least 30 days.
•
Activity/Milestone: Convene cross-discipline working group meeting on May 30,
2021 to review current State Logistics and Distribution Management Plan
All EMPG Program-funded investments must be accounted for in the Grant Activities Outline. However,
recognizing that some sustainment activities, such as funding of emergency manager salaries, may not align
to a specific priority or performance goal, applicants are not required to identify priorities and performance
goals for such investments. However, all other portions of the Grant Activities Outline must be completed
as a means to justify the applicable sustainment costs.
The various elements of the Grant Activities Outline tab are outlined below, along with basic instructions
for completing the required entries. Supplemental guidance and instructions are included in the EMPG
Program Work Plan Template.
•
Project Name: Provide a descriptive name for each planned project. Examples include
“Development of Emergency Function Annexes”, “Development of Earthquake Scenario Loss
Estimations”, “Implementation of Statewide Interoperability Plan”, “NIMS Training for
Emergency Management Personnel”, “Development of Emergency Preparedness Plan for
Individuals with Disabilities”, etc.
•
Brief Project Description: Provide further details on the project, particularly where the project
name does not sufficiently describe the project.
•
Gap or Need Addressed: Briefly describe the specific gap or need addressed by the project.
•
Project Objective: Explain how the project addresses the identified gap or need, and how it
supports the identified priorities and performance goals.
•
Anticipated Project Impact: Provide a quantitative estimate of the degree to which the project
will contribute to achieving the identified performance goal.
•
Build or Sustain: Select whether the project will build or maintain/sustain the identified core
capability(ies).
•
Mission Area: Select the appropriate preparedness mission area supported by the project:
Prevention, Protection, Mitigation, Response, or Recovery. Multiple mission areas can be selected
to accommodate projects that span multiple mission areas. For example, some plans and exercises
may involve multiple mission areas.
•
RA Agreed Upon Priority Area: The applicant selects from a drop-down list that includes the 32
core capabilities, the National Priority Areas identified in the NOFO, and other priorities identified
in the latest version of the National Preparedness Report.
•
Emergency Management Functions: This field is optional. It is made available to those
states/territories that are Emergency Management Accreditation Program (EMAP) accredited and
want to continue tracking their investments by Emergency Management Function (EMF). Select
from a drop-down list the EMFs supported by the project.
•
Core Capabilities: Select up to three (primary, secondary, and tertiary) core capabilities supported
by the project.
•
POETE Category: Select whether the project relates to Planning, Organization, Equipment,
Training, or Exercises. Multiple POETE categories can be selected to accommodate projects that
EMPG Program Appendix | February 2021
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span multiple categories. For example, building capability often involves a combination of
planning, training, and exercise activities.
•
Performance Goals: List the performance goals supported by the project. As explained in the
Grant Investment Strategy section above, each goal must be specific, measurable, achievable
within the period of performance, relevant to the priority area, and have a target date for
completion (i.e., SMART goal).
•
Milestones: Identify key project activities and other deliverables or outputs that are critical to
accomplishing the identified performance goal and can be tracked to demonstrate progress toward
achieving the performance goal.
Project Activities Outline
The Project Activities Outline tab includes the basic elements of a project management plan. It is used to
capture key project activities to include both EMPG Program-funded activities that are critical to
accomplishing the project objectives as identified in the Grant Activities Outline, as well as activities that
are essential to effective project management. Thus, this product can be used as a basic project
management tool to plan and track the progress of key project activities. Key project activities should
generally correlate with the “Milestones” identified for each project included in the Grant Activities
Outline.
The Project Activities Outline enables the applicant to identify key project activities by year/quarter, the
associated project management step (Initiate, Plan, Execute, Control, or Closeout), and challenges or risks
that may affect successful completion of the activity as planned. It also allows for the tracking of project
progress by including estimated and actual completion dates for each activity and the ability to enter
quarterly accomplishments relating to the activity.
Personnel Data Table
To facilitate consistent data reporting and performance measures collection, the EMPG Program Work Plan
Template includes a Personnel Data Table to provide an accounting of state, local, tribal, and territory
personnel supported with EMPG Program funds. This will assist in documenting the extent to which EMPG
Program funding supports personnel at the state level. This should be submitted with the EMPG Program
Work Plan and a roster of EMPG Program-funded personnel. The roster of EMPG Program-funded
personnel should be updated only if numbers change more than 10 percent during the award period of
performance.
Personnel Data Table Template
Personnel Metrics
Data
EMPG Program funds (federal and match) allocated towards state/territory emergency
management personnel
EMPG Program funds (federal and match) allocated towards non-state emergency
management personnel (local, tribal)
Total Number of state/territory emergency management full-time equivalent (FTE)
personnel (including those supported and not supported by the EMPG Program)
Number of state/territory emergency management FTE personnel supported (fully or
partially) by the EMPG Program
Total number of state/territory, local, and tribal emergency management personnel
supported (fully or partially) by the EMPG Program
EMPG Program Appendix | February 2021
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Personnel Data Table Definitions
•
Line 1 – The total of all EMPG Program funds (federal and match) allocated for state/territory
emergency management personnel. This should exclude local and tribal personnel.
•
Line 2 – All EMPG Program funds (federal and match) allocated towards non-state/territory
emergency management personnel (i.e., local, tribal personnel). This excludes state/territory
personnel.
•
Line 3 – Total number of state emergency management full-time equivalent (FTE) personnel
(including those supported and not supported by the EMPG Program). This should include only
funded positions. Vacant positions should be excluded.
•
Line 4 – Number of state/territory emergency management FTE personnel supported by the EMPG
Program. This excludes local and tribal personnel.
•
Line 5 – Total number of state, territory, local, and tribal emergency management personnel funded
(fully or partially) by the EMPG Program. This number provides the "Universe" number for the
training and exercise templates.
Training Data Table
To facilitate consistent data reporting and performance measures collection, the EMPG Program Work Plan
Template includes a Training Data Table. This table should reflect training activities outlined in the multi-
year IPP and completion of required EMPG Program training courses. The data requirements are defined in
the section below. Upon entering the project name or number in the template, the cells located to the right
of the main Training Data Table will auto-populate the associated priority, mission area, capabilities, and
functional areas based on the project data included in the Grant Activities Outline.
Training Data Table Template
Training Data Table Definitions
•
Column 1 – Project Name from the Grant Activities Outline
•
Column 2 – Project Number from the Grant Activities Outline
•
Column 3 – Name of training course
•
Column 4 – Is the course required of EMPG Program-funded personnel?
•
Column 5 – Number of personnel trained
•
Column 6 – Total number of SLTT EMPG Program-funded personnel (Universe)
•
Column 7 – Total number of SLTT EMPG Program-funded personnel that completed the course
•
Column 8 – Is the training identified in the multi-year IPP?
Project
Name
Project
Number
Name of
Training
EMPG
Program
Required
Training?
(Y/N)
Number
of
Personnel
Trained
Total
Number of
SLTT EMPG
Program
Funded
Personnel
Total Number of
SLTT EMPG
Program Funded
Personnel that
completed the
Course
Training
Identified
in IPP
(Y/N)
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Exercise Data Table
To facilitate consistent data reporting and performance measure collection, an Exercise Data Table should
be completed for any exercises that meet EMPG Program requirements and/or exercises conducted in whole
or part with EMPG Program funds. The data requirements are defined in the section below. Upon entering
the project name or number in the template, the cells located to the right of the main Exercise Data Table
will auto-populate the associated priority, mission area, capabilities, and functional areas based on the
project data included in the Grant Activities Outline.
Exercise Data Table Template
Exercise Data Table Definitions:
•
Column 1 – Project Name from the Grant Activities Outline
•
Column 2 – Project Number from the Grant Activities Outline
•
Column 3 – Exercise Name
•
Column 4 – Date of exercise
•
Column 5 – Type of exercise (e.g., seminar, workshop, tabletop, games, drills, functional, and/or
full-scale)
•
Column 6 – Is the exercise part of a progressive exercise series?
•
Column 7 – Total number of SLTT EMPG Program Funded Personnel
•
Column 8 – Total number of SLTT EMPG Program Funded Personnel Participating in Exercise
•
Column 9 – Is exercise identified in the multi-year IPP?
•
Column 10– When was the AAR submitted to FEMA?
Detailed Budget
The Detailed Budget tab enables a full accounting of all project activity costs. It also enables a breakdown
of the full EMPG Program budget into various categories, including: Mission Area, Core Capabilities,
National Priority Area, RA Agreed Upon Priority, EMF, and POETE Category. The cells for each of these
categories are automatically populated based on the project number as identified in the Grant Activities
Outline.
Project Management Lifecycle
Steps
Description
Process
Initiate
The authorization to begin work or
resume work on any particular activity.
Involves preparing for, assembling resources
and getting work started. May apply to any
Project
Name
Project
Number
Name of
Exercise
Scheduled
Date
Type of
Exercise
Exercise
Fulfills
Progressive
Exercise
Requirement
(Y/N)
Total
Number
of SLTT
EMPG
Program
Funded
Personnel
Number of
SLTT EMPG
Program
Funded
Personnel
that
Participated
Exercise
Identified
in IPP
(Y/N)
Date AAR
submitted
to FEMA
EMPG Program Appendix | February 2021
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Steps
Description
Process
level, e.g. program, project, phase, activity,
task.
Plan
The purposes of establishing, at an early
date, the parameters of the project that is
going to be worked on as well as to try to
delineate any specifics and/or any
peculiarities to the project as a whole
and/or any specific phases of the project.
Involves working out and extending the
theoretical, practical, and/or useful
application of an idea, concept, or
preliminary design. This also involves a plan
for moving a project concept to a viable
project.
Execute
The period within the project lifecycle
during which the actual work of creating
the project’s deliverables is carried out.
Involves directing, accomplishing,
managing, and completing all phases and
aspects of work for a given project.
Control
A mechanism which reacts to the current
project status in order to ensure
accomplishment of project objectives.
This involves planning, measuring,
monitoring, and taking corrective action
based on the results of the monitoring.
Involves exercising corrective action as
necessary to yield a required outcome
consequent upon monitoring performance.
Or, the process of comparing actual
performance with planned performance,
analyzing variances, evaluating possible
alternatives, and taking appropriate correct
action as needed.
Close Out
The completion of all work on a project.
Can also refer to completion of a phase
of the project.
Involves formally terminating and
concluding all tasks, activities, and
component parts of a particular project, or
phase of a project.