Lesson 3 Overview and Objectives

This lesson discusses the best practices for and common mistakes made on documentation required for reimbursement of Emergency Work.

Upon completion of this lesson, participants will be able to:

Describe documentation that supports application for reimbursement of Emergency Protective Measures

Best Practices for Documenting Emergency Protective Measures

There are four primary best practices for documenting Emergency Protective Measures.

Applicants who incorporate the following best practices into their routine operations sufficiently document Emergency Protective Measures:

Organize documents
Establish tracking mechanisms to provide sufficient data and documentation
Share knowledge with other communities
Identify force account versus contract costs

Best Practice: Organize Documents

Applicants need to establish policies and procedures for storing and organizing documentation.

Adopting a standard method for organizing documents allows Applicants to find and identify the required documentation when requesting grant reimbursement for Emergency Protective Measures.

Organizing documents also assists Applicants in other endeavors outside of acquiring grant funding from FEMA.

Example: Organize Documents

Applicants have many options to organize their documents prior to an incident.

Usually, the best option is uploading documents needed to procure grants to FEMA's Grants Portal prior to any incident occurring. Potential Applicants do not need to wait for an event to update and maintain common records or policies needed for a Public Assistance grant. Steady-state documentation can include:

Insurance policies
Mutual aid agreements, if applicable
Purchasing/procurement policies
Personnel/payroll policies (including fringe benefits)
Maintenance records

Other options include keeping a hard copy or online version of the above-mentioned documents:

Applicants need to keep up-to-date hardcopies in a location that will not be damaged by flooding or a fire, such as a safe
Applicants need to keep up-to-date versions of their documents in Grants Portal

Note: For more information on documentation. please refer to the course: IS-1006 Documenting Disaster Damage and Developing Project Files.

Multiple online computer folders linked together with files.

Best Practice: Establish Tracking Mechanisms

Another best practice for Applicants is establishing tracking mechanisms. The Applicant should create an emergency activity code to differentiate the activities that will be used to support the request for the Public Assistance Grant.

Adopting reliable tracking methods allows Applicants to distinguish emergency activities from day-to-day and steady-state operations when requesting reimbursement for Emergency Protective Measures. An Applicant who tracks their activities reduces the risk of jeopardizing Public Assistance grant funding.

Example: Establish Tracking Mechanisms

Applicants need to use an effective mechanism to track their Emergency Protective Measures in order to obtain grant funding from the Public Assistance Grant Program.

FEMA suggests that Applicants use, but are not limited to, the following tracking mechanisms:

Input activities into a spreadsheet
Fill out organization's form that records activities
Input activities into the organization's activity log book

Select this link for an example of a volunteer tracking document.

Best Practice: Share Knowledge with Other Communities

Applicants need to share effective documentation and tracking mechanisms with other communities to promote mutual awareness of proven organization tracking mechanisms.

Example: Share Knowledge with Other Communities

Agencies, communities, and organizations who share their knowledge and best practices of effective documentation and tracking mechanisms for activities they conduct, create a more efficient and sophisticated system for Applicants to apply for and obtain Public Assistance grant funding.

One example of this best practice includes:

Hosting regularly scheduled meetings (e.g., civic meetings) with partners or community entities to discuss best practices and exchange knowledge on the Public Assistance process

A group of people talking at a table in a meeting.

Best Practice: Force Account versus Contract Costs

An Applicant who applies for a Public Assistance grant should always separate Force Account and contract costs. This distinguishes the two groups of labor for internal and external purposes. Based on the separation, Applicants can better prepare any additional paperwork that FEMA would need.

A Force Account is an Applicant's internal or 'in-house' labor and equipment resources.

Contract costs are associated with acquiring competitively procured contracted services.

Example: Force Account versus Contract Costs

Force Account labor and contract labor costs are treated by FEMA differently.

Force Account labor is labor performed by non-contracted forces (such as City, County, or State employees). For example:

A police officer works for his/her department during an incident and accrues 20 hours of overtime directly related to Emergency Protective Measures
After the incident, the department applies for reimbursement under the Public Assistance Grant Program
FEMA provides a grant, reimbursing the 20 hours of overtime incurred by the police officer during the incident

Contract labor is labor performed by contracted forces (labor performed due to enforceable provisions of a contract). For example:

The Miami-Dade Police Department contracts ten police officers to assist during an incident. They all work on Emergency Protective Measures
After the incident, the Miami-Dade Police Department applies for reimbursement under Public Assistance Grant Program
FEMA provides a grant reimbursing all the hours worked by the contracted police officers

Police provide protection to properties in the Santa Maria neighborhood near Humacao, Puerto Rico.

Common Applicant Mistakes

Critical mistakes made documenting and tracking Emergency Protective Measures activities jeopardize Applicants from receiving reimbursement.

Common Applicant mistakes in which documentation and tracking do not meet requirements for reimbursement include:

Incomplete timesheets
Insufficient call logs
Absence of a written payroll policy
Inability to tie labor hours to equipment
Inability to document the type of work/activity conducted

Common Applicant Mistake: Incomplete Timesheets

Applicants who submit incomplete timesheets is one of the most common mistakes preventing them from meeting the documentation requirements for Emergency Protective Measures.

FEMA considers timesheets that only record time spent on the event, rather than full hours or pay period hours, incomplete and do not validate the amount of eligible overtime. Applicants need to ensure completeness and accuracy of all timesheets documenting activities related to Emergency Protective Measures.

Submitting incomplete timesheets prevent Applicants from receiving reimbursement for eligible costs related to performing Emergency Protective Measures.

Select this link for an example timesheet.

Common Applicant Mistake: Insufficient Call Logs

A Call log is a list of calls a department was requested to respond to during an incident. They are typically found with the fire and police departments. Having a call log assists FEMA in differentiating between regular calls and event-related calls.

Applicants who submit insufficient call logs is one of the common mistakes jeopardizing grant funding for Emergency Protective Measures activities.

Applicants often use call logs to document and track activities and link them to the event for reimbursement of Emergency Protective Measures.

Call logs that lack description of actions or do not link actions to the event are considered insufficient. To adequately document the activities coordinated during phone calls, Applicants must ensure that call logs provide a detailed description of activities and connect the activities to the event.

Select this link for an example of a volunteer tracking document.

Common Applicant Mistake: Absence of a Written Payroll Policy

Written payroll policies help FEMA determine reimbursable costs. Lack of a written payroll policy commonly prevents Applicants from receiving reimbursement for Emergency Protective Measures.

To sufficiently document and track labor associated with Emergency Work, Applicants must have a written payroll policy that identifies pay periods, overtime rules, and distinguishes between emergency activities and day-to-day operations.

Select this link for an example payroll policy.

Police and Fire Department Payroll Policies

Police and fire departments may differ in how they set their payroll policies due to union contracts and rules. The Applicant should know their union contracts and rules and have them reflected in their payroll policy.

There are different guidelines for volunteer status and full-time employees regarding payroll policies and overtime. For example, some fire departments are considered "volunteer," however they receive a flat rate payment (stipend) for every call they respond to while on duty versus a full-time employee who receives regular and overtime pay regardless of the amount of calls they respond to on a shift.

Common Applicant Mistake: Inability to Tie Hours to Equipment

Another common mistake Applicants make when documenting Emergency Protective Measures activities, is not being able to tie labor hours to equipment.

To properly document and track Emergency Protective Measures activities, Applicants must adopt documentation practices that clearly tie labor hours to the use of equipment. Good tracking mechanisms include:

Input activities into a spreadsheet
Fill out organization's form that records activities
Input activities into the organization's activity log book
Log information into a one-page work order with the hours worked, equipment used, and what work the personnel performed for every type of work

Information within the tracking mechanisms includes:

Personnel who worked
Description of the activity each personnel conducted
Number of hours personnel worked on each activity
Equipment used for each activity
Description of which personnel used the equipment and for how long
Material that was used in the activity
Amount of material used in the activity

Person on a computer working on a spreadsheet with documents and pens nearby.

Activity 1 (1 of 3)

Please determine if the following project would generally meet the Public Assistance eligibility requirements. Review the documentation provided to assist in making a determination. Then, move to the next screen to find FEMA's determination.

Scenario:

During the Hurricane Matthew incident period of October 4 through October 15, the City of Skoll encountered high winds and wind driven rain, which resulted in hazards to public health and safety. The City dispatched City police and public works resources to protect the public and respond to disaster-related 911 calls. Public works employees tended to wells and lift station pumps and maintained generator power to pumps while power was lost. The City also rented a pump to reduce flooding at a pump station.

Documentation:

Activity 1 (3 of 3)

The Applicant's project in this case is eligible for Public Assistance grant funding under Emergency Protective Measures.

The reasons are as follows:

The Applicant used Force Account labor, equipment, and rental equipment from the public works and police department
The Applicant rented generators prior to the event to make sure the wells and lift station pumps retained power
The Applicant rented a pump prior to the event to reduce flooding at a pump station
The documentation provides the cost breakdown of the Force Account labor, equipment, and rental equipment

The Public Assistance Program and Policy Guide states that "costs related to pre-positioning resources specifically for the declared incident are eligible if the resources are used in the performance of eligible Emergency Work. Pre-positioning resources for the purpose of evacuating, or providing emergency medical care during the evacuation period (such as ambulances and busses), is eligible even if those resources are not ultimately used, provided the staging of those resources was necessary and prudent based on the data at the time of staging."

Please also refer to the Public Assistance Program and Policy Guide for the definition of Emergency Protective Measures.

Activity 2 (1 of 3)

Please determine if the following documentation is enough to support eligibility or does not do so. Then, move to the next screen to find FEMA's determination.

Scenario:

During the incident period of August 15 to September 23, flooding in Summit City and LaGrande caused an increase in the demand for the services provided by the private nonprofit organization Trust for Children. Additionally, the services Trust for Children provided were expanded to include all of Ridgecrest County.

As a result of the impact of the heavy rains and flooding brought by Hurricane Fred, the demand for Trust for Children's services saw an increase and, consequently, Trust for Children incurred increased operating costs of approximately:

$22,642 for the food bank temporary staff
$47,630 for case management temporary staff
An undisclosed amount for equipment purchases for temporary staff
An undisclosed amount for security at facility where services are offered

Documentation:

Activity 2 (3 of 3)

In the aftermath of Hurricane Fred's impact, the demand for the services provided by Trust for Children increased and drove up operating costs. Trust for Children requests reimbursement for these increased costs in four areas:

Food bank
Case management
Equipment purchases for temporary staff
Security for the facility where services are offered

Government entities have the legal responsibility to provide Emergency Protective Measures in their communities, such as food distribution after a disaster. However, they may request and designate, under a legal agreement, a Private Nonprofit organization as a responsible entity (44 C.F.R. 206.223(a)(3)). In these cases, FEMA reimburses the government entity, which then reimburses the Private Nonprofit Organization.

Unfortunately, Trust for Children was never designated as the responsible entity under a legal agreement. In addition, the work performed by Trust for Children's temporary staff did not fall under any specific FEMA Public Assistance Category of Work (44 C.F.R. 206.224-226). Because Trust for Children's work was not deemed eligible, the equipment purchases and facility security were not eligible for reimbursement under FEMA Public Assistance.

Lesson 3 Summary

In this lesson, the participant learned about the documentation requirements for Emergency Work reimbursement under the Public Assistance Program.

The next lesson provides a review of the key concepts covered throughout the course.