AFG awards are out – and audits will soon follow

On June 9, DHS/FEMA announced the first round of Assistance to Firefighters Grants (AFG) Program awards for 2022. That announcement was followed with a second round of award announcements on June 23. I expect the award announcements to continue for the next 8 to 10 weeks.

If you have been awarded an AFG grant, one thing you can rest assured will happen is some type of post-award monitoring.

The FEMA Grant Programs Directorate and the 10 FEMA regions monitor recipients to ensure that project goals, objectives, performance requirements, budgets and other related grant requirements are met. At the same time, monitoring also provides an opportunity for training and technical assistance to support the award recipients.

Prepare, don’t panic

Following a few simple tips should prevent you from going into a panic when you get notice from FEMA that they are going to conduct a review of your award.

• Organize your information: My first suggestion is to start a grant award folder, whether electronic or old-fashioned paper in a binder.
• Keep a digital record: Try to conduct all your correspondence by email. All of your conversations with the local media, potential vendors, bidders, even your conversations with FEMA personnel should all be done by email. Keep this correspondence in your folder, too. For any communication over the phone or in person, follow up with an email describing the details of that voice conversation or typing out notes to yourself.
• Track bids: The items you purchase must be the result of fair and open competition among vendors. Keep every cost estimate you receive and place it in your grant award folder. If your AFG award has to go through a department meeting before it is awarded to a vendor, make sure to keep a copy of the minutes of that meeting as well. The department secretary should attest that the copy is a true and correct copy of the minutes of that meeting.

What documents will I need for FEMA?

Below is a list of the most recent documents that FEMA has requested from an AFG awardee during the initial review by FEMA. You will generally have 30 days to assemble this information and to email it to FEMA.

• Documentation of your policies and internal controls, such as:
  • The policies that guide your department in the execution of the budgeted line item, if awarded or amended to the grant
  • Property Control and Inventory Management
  • Reporting and Closeout Procedures
  • Drawdowns and Payment Requests
  • Contracting and Procurement Policies
  • External and Internal Communications (e.g., Media, Governments, FEMA, etc.)
  • Source Documentation and File Management
• Documentation to support your application submitted to FEMA:
  • Regional Partnerships or Memorandum of Understanding (MOU); letters of support and/or agreement to Regional Award and partnerships under this grant award; Regional Grant Recipients only
  • Mutual Aid Agreements
• Documentation to support your procurement process:
  • Procurement documents (Generic Spec List, List of Vendors Solicited, Request for Proposals, Vendor bid solicitations, Vendor Responses (included No Bid responses) Executed/Signed Contracts, etc.) supporting the purchase of with grant funds.

A visit from FEMA

After the initial review process, FEMA will schedule a conference call or site monitoring visit to conduct the desk-monitoring. This is a process used by the FEMA to monitor grantees for financial compliance with their AFG Award. It is used to determine if the grantee complied with all aspects of the grant award agreement.

Recommended participants for this desk monitoring should include the primary grant manager, the fire department chief, and any other staff who were involved in the grant administration and/or implementation.

Desk monitoring normally takes about an hour. The time will be utilized by FEMA to explain their process and to go over the grantees’ award and their expenditures. The FEMA representative may have questions if they don’t understand the department’s policies or if they aren’t clear on an expenditure that has been submitted for payment by the grantee. There is also an ample amount of time for the department to ask any questions that they may have.

Completing the process

After the monitoring is complete, your department will receive a letter from FEMA formally advising you of the results. The letter will also detail any additional information FEMA might need to complete their review. If there are no findings from the desk review, your obligations for that particular grant have been completed.

If FEMA’s letter reveals that there are unresolved compliance issues with your grant, then you should make every effort to follow their recommendations and rectify these items as soon as possible. If they are not resolved in a timely fashion, you will jeopardize your department’s ability to apply for future federal grants, and you may also be required to repay any questionable expenditures back to FEMA.  If the items in question remain unresolved, FEMA does have the option to turn its findings over to the U.S. Attorney’s Office for investigation and possible prosecution.

Don’t find yourself in this situation! Follow these simple tips to maintain grant compliance.