Dinuba City Council
August 12, 2025

Section 2 ‒ Federal Changes and Initiatives | 2024
National
Campaigns and
Programs Cont.

National
Cybersecurity
Review
NIMS
Implementation
Countering Violent Extremism (CVE) Training - Foreign
terrorist groups and individual terrorist thought leaders recruit or inspire Westerners to carry out attacks against western and U.S. targets, including individuals living in communities with the U.S. via, but not limited to, print, video, and social media, as well as through personal
interaction. But we also know that violent extremism is not a phenomenon restricted solely to one community and
that any effort to counter violent extremism must be
applicable to all ideologically motivated violence. Efforts to provide information and training regarding CVE should emphasize the strength of local communities’ approach.

The National Cybersecurity Review (NCSR) is a required
assessment for all Subrecipients of State Homeland Security Program (SHSP) and Urban Areas Security Initiative (UASI) funding to be completed between October 2024 and
February 2025.

The NCSR is a no-cost, anonymous, and annual selfassessment designed to measure gaps and capabilities of state, local, tribal, territorial, nonprofit, and private sector agencies’ cybersecurity programs.

Additionally, FEMA recognizes that some subawards will
not be issued until after the NCSR has closed. In these cases, Subrecipients will be required to complete the first available NCSR offered after the subaward has been
issued by Cal OES.

The Chief Information Officer (CIO), Chief Information
Security Officer (CISO), or equivalent should complete the NCSR. If there is no CIO or CISO, the most senior
cybersecurity professional should complete the
assessment. Additional information may be found in IB 439 and 429a.

Prior to the allocation of any federal preparedness awards, Subrecipients must ensure and maintain the adoption and implementation of the National Incident Management
System (NIMS).
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Section 2 ‒ Federal Changes and Initiatives | 2024
Law Enforcement
Terrorism
Prevention
Activities
At least 35% of the grant funding under SHSP and UASI must be dedicated to Law Enforcement Terrorism Prevention
Activities (LETPA). This required LETPA allocation can be from SHSP, UASI, or both and may be met by funding
projects in any combination of the six NPAs and any other investments.

Allowable expenditures can be found in the authorizing
legislation, Preparedness Grants Manual, Information
Bulletin (IB) No. 473 Supplemental Guidance for LETPA
Expenditures, the National Prevention Framework, and
National Protection Framework.

For an activity to be counted towards the LETPA
requirement, it must have a law enforcement terrorism
prevention nexus. If an activity is listed in the authorizing legislation or can be directly tied to a capability in the National Prevention Framework or shared capability in the National Protection Framework, then it is presumed to have law enforcement nexus and be a LETPA. For all other
claimed activities, nexus to law enforcement and terrorism prevention must be clearly explained.

Refer to IB 485 - FY23 LETPA Supplemental Guidance to the NOFO for further direction on how to account for LETPA
activities, best practices for submitting LETPA investments, and information on how to distinguish LETPA from other
activities.

Management
and
Administration
The Management and Administration (M&A) allowance for
Subrecipients is set at a maximum of 5% for FY 2024 HSGP.

Indirect Costs Indirect costs are allowable under the FY 2024 HSGP Grant Award.

Subrecipients with an indirect cost rate approved by their cognizant federal agency may claim indirect costs based on the established rate. Indirect costs claimed must be calculated using the base approved in the indirect cost negotiation agreement. A copy of the approved
negotiation agreement is required at the time of
application.
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Section 2 ‒ Federal Changes and Initiatives | 2024
Indirect Costs
Cont.

Organization
Costs – Overtime
Indirect costs are in addition to the M&A allowance and must be included in the Grant Award application as a
“Project” and reflected in GCS on the Indirect Cost page if being claimed under the award.

Indirect costs must be claimed no more than once
annually, and only at the end of the Subrecipient’s fiscal year. An exception to this rule applies if there is a mid-year change to the approved indirect cost rate; in this case, costs incurred to date must be claimed. At that time, a Grant Subaward Modification reflecting the rate change
must also be submitted to Cal OES, along with a copy of the new Indirect Cost Rate Agreement.

The FEMA Preparedness Grants Manual, published by
FEMA, states that State and local governments are not
permitted to use the de minimis rate. These costs are
allowable only when an exception is granted to the SAA
by FEMA per 2 C.F.R. Part 200, Appendix VII, paragraph
D.1.b. Subrecipients should not include these costs in their future applications until further notice. If necessary, subrecipients may work with their Grants Analyst to modify their existing projects to remove these costs that were included in their advanced application.

Operational overtime costs are allowable for increased
security measures at critical infrastructure sites if associated with detecting, deterring, disrupting, and preventing acts of terrorism and other catastrophic events.

Per section D-13 of The U.S. Department of Homeland
Security (DHS) Notice of Funding Opportunity (NOFO Fiscal Year 2024 Homeland Security Grant Porgram), all
operational overtime requests must clearly explain how the request meets the criteria of one or more of the listed Authorized Operational Overtime Categories. Requests
must address the threat environment as it relates to the event or activity requiring operational overtime support and explains how the overtime activity is responsive to the threat.
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Section 2 ‒ Federal Changes and Initiatives | 2024
Organization
Costs – Overtime
Cont.

Post-event operational overtime requests will only be
considered on a case-by-case basis, where it is
demonstrated exigent circumstances prevented
submission of a request in advance of the event or activity.

Requests for overtime costs must be submitted to Cal OES via Allowability Request Log (ARL) Form in GCS at the time of application, if the activity will occur within one year of the final application submission. All subsequent requests must be submitted at least 60 days in advance of the
activity.

All operational overtime costs must be formally preapproved in writing by DHS/FEMA.

Personnel Cap Pursuant to 6 U.S.C. § 609(b), SHSP and UASI funds may be used for personnel costs, totaling up to 50 percent of each fund source. A Subrecipient may request this requirement be waived by DHS/FEMA, via Cal OES. Requests for
personnel cap waivers must be submitted separately for
each fund source in GCS , with the following information:
• Documentation explaining why the cap should be
waived;
• Conditions under which the request is being submitted; and
• A budget and method of calculation of personnel costs both in percentages of the Grant Award and in total
dollar amount (waivers must be calculated separately
for SHSP and UASI, outlining salary, fringe benefits, and any M&A costs).

Subrecipient requests to exceed the personnel cap must
be received by Cal OES at the time of application in GCS.

Subaward modifications impacting the personnel cap will be reviewed on a case-by-case basis and may require the submittal of the above-mentioned information.

Please see IB 421b for more information on the waiver
process.
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Section 2 ‒ Federal Changes and Initiatives | 2024
Equipment
Typing/
Identification
and Use
Equipment
Maintenance/
Sustainment
Emergency
Communications
Projects
Telecom
Equipment and
Services
Prohibitions
Allowable HSGP equipment is listed on the FEMA
Authorized Equipment List (AEL) website.

Subrecipients that allocate HSGP funds towards equipment are required to type and identify the capability associated with that equipment.

The FEMA Resource Typing Library Tool (RTLT) can be used to help determine the type and capability.

Per FEMA policy, the purchase of weapons and weapon
accessories are not allowed with HSGP funds. Special rules apply to pharmaceutical purchases,medical
countermeasures, and critical emergency supplies; refer to page A-10 of the FEMA Preparedness Grants Manual for
additional information.

Expenditures for general purpose equipment are allowable if they align to and support one or more core capabilities identified in the NPG, and in addition, are
deployable/sharable through the Emergency
Management Assistance Compact and allowable under
6 U.S.C. § 609. Refer to the NOFO and Preparedness Grants Manual for examples of allowable general-purpose
equipment.

Use of HSGP funds for maintenance contracts, warranties, repair or replacement costs, upgrades, and user fees are allowable as described in FEMA IBs 336 and 379, as well as Grant Programs Directorate (GPD) Policy FP-205-402-125-1.

All Subrecipient emergency communications projects must comply with the SAFECOM Guidance on Emergency
Communications Grants and describe in their application how such activities align with the goals of the Statewide Communications Interoperability Plan.

Effective August 13, 2020, section 889(f)(2)-(3) of the John S. McCain National Defense Authorization Act for FY 2019 (NDAA) and 2 C.F.R. § 200.216, 200.471, and Appendix II to 2 C.F.R. Part 200 prohibit DHS/FEMA Recipients and
Subrecipients (including their contractors and
subcontractors) from using any FEMA funds under open or 13

Section 2 ‒ Federal Changes and Initiatives | 2024
Telecom
Equipment and
Services
Prohibitions Cont.

Prohibited and
Controlled
Equipment
new awards for the following telecommunications
equipment or services:
1) Telecommunications equipment produced by Huawei
Technologies Company or ZTE Corporation, (or any
subsidiary or affiliate of such entities);
2) For the purpose of public safety, security of government facilities, physical security surveillance of critical
infrastructure, and other national security purposes,
video surveillance and telecommunications equipment
produced by Hytera Communications Corporation,
Hangzhou Hikvision Digital Technology Company, or
Dahua Technology Company (or any subsidiary or
affiliate of such entities);
3) Telecommunications or video surveillance services
provided by such entities or using such equipment; or
4) Telecommunications or video surveillance equipment or services produced or provided by an entity that the
Secretary of Defense, in consultation with the Director of National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an
entity owned or controlled by, or otherwise connected
to, the People’s Republic of China.

Additional guidance is available in FEMA Policy #405-143- 1, Prohibitions on Expending FEMA Award Funds for
Covered Telecommunications Equipment or Services
Effective May 25, 2022, Executive Order (EO) 14074,
Advancing Effective, Accountable Policing and Criminal
Justice Practices to Enhance Public Trust and Public Safety, Section 12(a) of EO 14074 directs the Department of
Homeland Security (DHS) to review its grant programs and, consistent with applicable law, prohibits the use of grant funding to purchase certain types of military equipment by state, local, tribal, and territorial law enforcement
agencies (LEAs).
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Section 2 ‒ Federal Changes and Initiatives | 2024
Prohibited and
Controlled
Equipment Cont.

Small Unmanned
Aircraft Systems
For all awards issued on or after January 1, 2023, the
policy directly prohibits certain types of equipment outright (prohibited equipment), whereas other types of equipment may be controlled, or LEAs are required to submit
certifications prior to purchase.

Even if equipment is listed as controlled equipment and is not outright prohibited, that does not automatically make it allowable under a particular FEMA program.

Subrecipients should refer to applicable program
guidance or contact your Grants Analyst to determine if a particular type of equipment is allowable under that
program.

Additional information regarding Prohibited and Controlled Equipment is available on FEMA Policy 207-22-0002. FEMA Controlled Equipment Request Form can submitted in GCS.

All requests to purchase Small Unmanned Aircraft Systems (SUAS) with FEMA grant funding must comply with FEMA
Policy 207-22-0002 and include copies 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. The Authorized Equipment Listing for 03OE-07-SUAS details
questions that must be included in the SUAS Request
justification. Reference the Presidential Memorandum:

Promoting Economic Competitiveness While Safeguarding
Privacy, Civil Rights, and Civil Liberties in Domestic Use of Unmanned Aircraft Systems for additional information.

FEMA approval is required before a SUAS can be
purchased with HSGP grants funds.

Subrecipients must submit Cal OES’ UAS-Drone Request
Form, Controlled Equipment Self-Certification Form and
FEMA’s Controlled Equipment Request Form for FEMA
approval. Requests for drone/UAS accessories follow the same UAS process that requires FEMA review and
approval.
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Section 2 ‒ Federal Changes and Initiatives | 2024
Emergency
Operations Plans
Conflict of
Interest
Build America,
Buy America Act
(BABAA)
Subrecipients should update their Emergency Operations
Plan (EOP) at least once every two years to remain
compliant with the Comprehensive Preparedness Guide
101 version 2.0.

To eliminate and reduce the impact of conflicts of interest in the subaward process, Subrecipients and pass-through entities must follow their own policies and procedures
regarding the elimination or reduction of conflicts of
interest when making subawards. Subrecipients and passthrough entities are also required to follow any applicable federal, state, local, and tribal statutes or regulations governing conflicts of interest in the making of subawards.

Subrecipients must disclose to their Grants Analyst, in writing, any real or potential conflict of interest as defined by the federal, state, local, or tribal statutes or regulations, which may arise during the administration of the HSGP
subaward within five days of learning of the conflict of interest.

Under FEMA financial assistance programs, the BABAA
requirements apply to:
• New awards made on or after January 2, 2023,
• New funding that FEMA obligates to existing awards or through renewal awards on or after January 2, 2023;
and
• Infrastructure projects.

Funds provided under this program may not be used for a project for infrastructure unless the iron and steel,
manufactured products, and construction materials used
in that infrastructure are produced in the United States. 16

Section 2 ‒ Federal Changes and Initiatives | 2024
Build America,
Buy America Act
(BABAA) Cont.

The Buy America preference only applies to articles,
materials, and supplies that are consumed in, incorporated into, or affixed to an infrastructure project. As such, it does not apply to tools, equipment, and supplies, such as
temporary scaffolding, brought to the construction site and removed at or before the completion of the
infrastructure project. Additionally, the Buy America
preference does not apply to equipment and furnishings, such as movable chairs, desks, and portable computer
equipment, that are used at or within the finished
infrastructure project but are not an integral part of the structure or permanently affixed to the infrastructure
project.

When necessary, Subrecipients may apply for a waiver
from these requirements.

Additional information regarding the BABAA can be found on FEMA’s website under
Buy America Preference Buy America Preference.
17

Section 3 ‒ State Changes and Initiatives | 2024
FY 2024
Investments
The State prioritized the following investment strategies for the FY 2024 subawards:

1. Enhance Information and Intelligence Sharing and
Cooperation with Federal Agencies, including DHS
(National Priority);

2. Enhance the Protection of Soft Targets/Crowded Places (National Priority);

3. Enhance Cybersecurity (National Priority);

4. Enhancing Community Preparedness and Resilience
(National Priority);

5. Combating Domestic Violent Extremism (National
Priority);

6. Strengthen Emergency Communications Capabilities
Through Planning, Governance, Technology, and
Equipment;

7. Enhance Medical and Public Health Preparedness;

8. Strengthen Information Sharing and Collaboration (nonFusion Center);

9. Enhance Multi-Jurisdictional/Inter-Jurisdictional AllHazards/Whole Community Incident Planning, Response & Recovery Capabilities;

10. Protect Critical Infrastructure and Key Resources
(includes Food and Agriculture); and

11. Enhance Election Security (National Priority).
18

Section 3 ‒ State Changes and Initiatives | 2024
California
Homeland
Security Strategy
Goals
State Initiative
Funding
“On Behalf Of”
Public Alert and
Warning
The State prioritized the following California Homeland Security Strategy Goals for the FY 2024 subawards:

1. Enhance Information Collection, Analysis, and Sharing, in Support of Public Safety Operations Across California;

2. Protect Critical Infrastructure and Key Resources from All Threats and Hazards;

3. Strengthen Security and Preparedness Across
Cyberspace;

4. Strengthen Communications Capabilities through
Planning, Governance, Technology, and Equipment;

5. Enhance Community Preparedness;

6. Enhance Multi-Jurisdictional/Inter-Jurisdictional AllHazards Incident Catastrophic Planning, Response, and Recovery Capabilities;

7. Improve Medical and Health Capabilities;

8. Enhance Incident Recovery Capabilities;

9. Strengthen Food and Agriculture Preparedness; and

10. Enhance Homeland Security Exercise, Evaluation, and Training Programs.

For FY 2024, Cal OES shall retain 20% of the SHSP and 17.3% of the UASI funding for state initiatives.

Cal OES may, in conjunction with local approval
authorities, designate funds “on behalf of” local entities who choose to decline or fail to utilize their subaward in a timely manner.

Cal OES encourages Subrecipients to consider the use of this funding to assist their jurisdiction’s alignment with the State of California Alert and Warning Guidelines,
developed pursuant to Senate Bill 833 of the 2018
Legislative Session.
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Section 4 ‒ Required State Application Components | 2024 Grant
Subaward
Application
Subrecipient
Grants
Management
Assessment
Application
Forms
Subrecipients must complete and submit their Grant Subaward Application through the online Cal OES Grants Central System (GCS). All forms and required fields must be completed in order to submit the application in the GCS.

Cal OES may require revisions and/or additional
documentation to finalize the submission of the Grant
Subaward Application in the GCS. The assigned Grants Analyst can provide technical assistance in completing these
components.

Per 2 C.F.R. § 200.332, Cal OES is required to evaluate the risk of non-compliance with federal statutes, regulations, and grant terms and conditions posed by each Subrecipient of passthrough funding. The Subrecipient Grants Management Assessment Form contains questions related to an organization’s experience in the management of federal grant awards. It is used to determine and provide an appropriate level of technical assistance, training, and grant oversight to Subrecipients during the subaward. The Subrecipient Grants Management Assessment Form is a required application form and can be completed in GCS.

Federal Funding Accountability and Transparency Act (FFATA) Financial Disclosure – Use the FFATA Financial Disclosure Form in GCS to provide the information required by the Federal Funding Accountability and Transparency Act of 2006.

Certification Regarding Lobbying – Use the Certification Regarding Lobbying Form in GCS to certify lobbying activities, as stipulated by the Byrd Anti-Lobbying Amendment,
31 U.S.C. § 1352.

Intelligence Analysts Certificates – Pursuant to the Preparedness Grants Manual, Cal OES must have certificates for completion of training for fusion center analytical personnel. Please provide copies of certificates for each intelligence analyst, if applicable.

UASI Footprint (UASIs Only) – The Urban Area Working Group (UAWG) establishes the ‘footprint’ of the UA. A map or list defining the footprint must be included with the application.

UAWG Member Roster (UASIs Only) – A list of all current UAWG members with positions or titles.
20

Section 4 ‒ Required State Application Components | 2024 Application
Forms Cont.

Indirect Cost Rate Agreement – If claiming indirect costs at a federally-approved rate, please provide a copy of the approved indirect cost rate agreement.

Standard
Assurances
The Standard Assurances list the requirements to which the Subrecipients will be held accountable. The FY 2024 Standard Assurances are a required application form within GCS.

NOTE: Self-created Standard Assurances will not be accepted.

Program
Standard
Assurances
Addendum
The Program Standard Assurances Addendum specifies
additional requirements that Subrecipients must meet. The Program Standard Assurances Addendum is a required
application form within GCS.

Operational
Areas and
Urban Areas
Governing Body Resolution – The GBR appoints AAs (identified by the individual’s name or by a position title) to act on behalf of the governing body and the Applicant by executing any actions necessary for each application and subaward. All Applicants are required to submit a copy of an approved GBR with their grant application in GCS. Resolutions may be valid for up to three grant years given the following:
• The resolution identifies the applicable grant program (e.g., EMPG and/or HSGP);
• The resolution identifies the applicable grant years, (e.g., FY 2023, FY 2024, FY 2025; and
• Adheres to any necessary elements required by local
protocols, rules, etc., if applicable.

Resolutions that only identify a single grant program will only be valid for that single program. Resolutions that do not identify applicable grant years will only be valid for the grant year in which the resolution was submitted.

Authorized Agent Information – For each person or position appointed by the governing body, identify the individual in the Cal OES Grants Central System (GCS) by assigning them the Authorized Agent role. More than one person is recommended for designation as the AA.
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Section 4 ‒ Required State Application Components | 2024 Operational
Areas and
Urban Areas
Cont.

Operational
Areas Only
Urban Areas
Only
All changes in AA and contact information must be submitted through the GCS. If the GBR identifies the AA by name, a new Resolution is needed when changes are made. If the GBR
identifies the AA by position and/or title, changes may be made by an existing AA, who can register the new AA in the GCS.

Cal OES will not accept signatures of an AA’s designee, unless authorized by the governing body's resolution. A change to an AA's designee must be submitted through the GCS.

Approval Authority Body – OAs must appoint an Anti-Terrorism Approval Body (Approval Authority) to have final approval of the OA’s application for HSGP funds. Each member of the Approval Authority must provide written agreement with the OA’s
application for HSGP funds. The Approval Authority shall consist of the following representatives, and additional voting members may be added by a simple majority vote of the following standing members:
• County Public Health Officer or designee responsible for Emergency Medical Services
• County Fire Chief or Chief of Fire Authority
• Municipal Fire Chief (selected by the OA Fire Chiefs) • County Sheriff
• Chief of Police (selected by the OA Police Chiefs)
Urban Area Working Groups – 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 UA. It also must be inclusive of local Citizen Corps Council and tribal representatives.

The UAWG should also ensure the integration of local emergency management, public health, and health care systems into a coordinated sustained local capability to respond effectively to a mass casualty incident. Additional group composition criteria are found in the FEMA Preparedness Grants Manual.

Threat Hazard Identification and Risk Assessment – Subrecipients are required to submit a THIRA for all 32 core capabilities.

Beginning in 2019, UAs are required to submit a THIRA every three years. An annual capability assessment will still be required. 22

Section 4 ‒ Required State Application Components | 2024 Urban Areas
Only Cont.

Fusion
Centers Only
State
Agencies and
Tribes Only
Stakeholder Preparedness Review – The SPR is an annual grant requirement for all states, territories, and UAs. It is an annual capability assessment, which helps jurisdictions identify capability gaps and prioritize investment requirements to reach the targets set in their THIRA.

All fusion center investments must align to, and reference, specific performance areas of the assessment that the funding is intended to support.

Fusion Centers are also required to follow all Reporting and Administrative Metrics for California Fusion Centers, as set forth in the Governor’s Homeland Security Advisor/Cal OES Director’s letter dated March 16, 2016. These operational and administrative metrics set forth an integrated and coordinated approach for regular and proactive information and intelligence sharing between all fusion centers in the California State Threat Assessment System (STAS).

State Agencies, and federally recognized tribes may submit the Signature Authorization Form in lieu of a GBR, signed by the most senior ranking official, such as the Secretary, Director, President, Chancellor, or Chairperson.
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Section 5 ‒ State Application Process | 2024
Application
Submission
Late or
Incomplete
Application
HSGP Contact
Information
Subaward
Approval
Subrecipients must complete and submit their Grant Subaward Application through the online Cal OES Grants Central System (GCS). All forms and required fields must be completed in order to submit the application in GCS. During the application process, if it is determined not all allocated funds can be expended by the end of the period of performance, please inform a Grants Analyst as soon as possible. The completed application should be submitted in the GCS no later than the date provided in the GCS, and the FY 2024 HSGP Timeline, referenced as Attachment B.

Late or incomplete applications may be denied. If an application is incomplete, the Grants Analyst may request additional information. Requests for late submission of applications must be made in writing to the Grants Analyst prior to the application due date. Cal OES has sole discretion to accept or reject a late or incomplete grant application.

The Grants Analyst Regional Assignments Map is linked and available on the Cal OES website under “Regional Assignments”.

Subrecipients will receive a formal notification of award no later than 45 days after Cal OES accepts the federal grant award. The award letter must be signed, dated, and returned to Cal OES within 20 calendar days. Once the completed application, along with the signed award letter, is received and the application is approved in GCS, reimbursement of eligible subaward
expenditures may be requested in GCS.
24

Section 6 ‒ Post Award Requirements | 2024
Payment Request
Process
To request an advance or cash reimbursement of HSGP
funds, Subrecipients must first complete a payment request in GCS.

Payments can only be made if the Subrecipient has an
approved application.

Advances and
Interest Earned on
Advances
An Advance payment is a payment that is requested before Subrecipients have disbursed the funds for program purposes.

Subrecipients may be paid an advance, provided they
maintain a willingness and ability to maintain procedures to minimize the time elapsing between the receipt of funds and their disbursement. The timing and amount of advance
payments must be as close as administratively feasible to the actual disbursements by the Subrecipient for project costs.

Federal rules require advances to be deposited in interestbearing accounts. Interest earned in amounts up to $500 per year may be retained by Subrecipients for administrative expenses; any additional interest earned on federal advance payments must be returned annually to Cal OES.

Semi-Annual
Drawdown
Requirements
All Subrecipients must report expenditures and request funds at least semi-annually throughout the period of performance.

Semi-annual drawdowns should occur by March and
October of each calendar year following final approval of the subaward application, except for the final cash request, which must be submitted within 20 calendar days after the end of the period of performance.

Modifications Post-award budget and scope modifications must be requested through GCS.The Subrecipient may implement
grant modification activities, and incur associated expenses, only after receiving written final approval of the modification from Cal OES through GCS.

Subrecipients must provide a written justification with all modification requests. The justification will be completed in GCS. Please reference GMM 2018-17 for additional
information regarding modification requests.

Modifications to NP Projects have additional restrictions as indicated below:
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Section 6 ‒ Post Award Requirements | 2024
Modifications
Cont.

Training
Requirements
Exercises,
Improvement
Plans, and AfterAction Reporting
Modifications which do not change the project scope and do not decrease the overall project budget can be
processed via regular modification request.

Modifications which change the project scope or decrease the overall project budget will require DHS/FEMA approval and must be requested in GCS.

All grant-funded training activities must receive Cal OES approval prior to starting the training event. Cal OES shall allow Subrecipients to develop a “placeholder” for future training conferences when an agenda has not been
established at the time Subrecipient applications are due.

Please work with a Grants Analyst and the Training Branch to identify a possible “placeholder” for these types of training activities.

When seeking approval of non-DHS/FEMA developed
courses, course materials must be submitted with the
approval requests. Conditional approvals are not offered.

Subrecipients must complete a Training Request Form and submit it electronically to the Cal OES Training Branch to be approved with a Training Feedback Number before
beginning any training activities. This includes project components like travel to, materials for, or attendance in training courses. Training Feedback Numbers should be
obtained no later than 30 days before the first day of the training or related activities. Requests that are submitted with less than 30 days prior to the start of the training or activity are not guaranteed to be approved in time and run the risk of training being unallowable. Training Feedback numbers must be included on the Training budget page in GCS to be
considered for reimbursement.

For more information on this or other training-related inquiries, contact the Cal OES Training Branch at (916) 845-8745 or [email protected].

Subrecipients should engage stakeholders to identify longterm training and exercise priorities. These priorities should address capability targets and gaps identified through the THIRA and SPR process, real-world events, previous exercises, and national areas for improvement identified in the NPR. 26

Section 6 ‒ Post Award Requirements | 2024
Exercises,
Improvement
Plans, and AfterAction Reporting
Cont.

Procurement
Standards and
Written
Procedures
Procurement
Thresholds
Subrecipients must report on all exercises conducted with HSGP grant funds. An After-Action Report
(AAR)/Improvement Plan (IP) or Summary Report (for
Seminars and Workshops) must be completed and submitted to Cal OES within 90 days after exercise/seminars/workshops are conducted. It is acceptable to submit an Exercise
Summary Report for Seminars and Workshops in lieu of a full AAR/IP.

Please e-mail AAR/IPs and Summary Reports to:
• [email protected]
• [email protected]
• [email protected]
For exercise-related issues and/or questions, please email the Cal OES Exercise Team at [email protected].

Exercise costs will not be considered for reimbursement until an AAR/IP is received by Cal OES.

Subrecipients are required to conduct procurement activities in with documented procurement procedures that align with federal procurement standards outlined in 2 C.F.R. Part 200. In cases where there is a conflict between the local procedures and federal standards, the more stringent requirements must be followed. Additionally, subrecipients must implement written conflict of interest policies that govern the actions of employees involved in the selection, award, and
administration of contracts. These policies should include provisions for disciplinary actions in the event of violations.

Under 2 C.F.R. Part 200, procurement thresholds are defined as follows:
• Micro-purchase threshold: This is the maximum amount for which purchases can be made without requiring
competitive quotes or formal procurement processes,
provided the price is reasonable. The micro-purchase
threshold is set at $10,000.
27

Section 6 ‒ Post Award Requirements | 2024
Procurement
Thresholds Cont.

Procurement
Documentation
Noncompetitive
Procurement
• Simplified acquisition threshold: This sets the maximum amount for which federal procurement procedures may be
simplified. The threshold is $250,000. For purchases at or below this amount, subrecipients may use streamlined
methods, such as obtaining competitive price or rate
quotations from an adequate number of qualified sources.

Purchases exceeding $250,000 require more formal
procurement procedures, including sealed bids or
competitive proposals.

Subrecipients must adhere to these thresholds and, in cases of conflict between local procurement procedures and
federal requirements, must apply the more stringent
threshold.

Subrecipients must maintain records that document the
procurement process, including the rationale for the
procurement method, contract type, contractor selection or rejection, and the basis for the contract price. To be
allowable, costs must be properly documented. Acceptable documentation includes, but is not limited to:
• Solicitation materials (e.g., requests for quotes, bids, or proposals)
• Responses to solicitations (e.g., quotes, bids, or proposals) • Independent cost estimates and post-solicitation cost/price analyses, if applicable
• Contract documents and amendments
• Evidence of required contract provisions
• Other documents mandated by federal regulations at the time the grant was awarded
All noncompetitive procurements exceeding the simplified acquisition threshold requires Cal OES prior written approval to be eligible for reimbursement. This method of procurement must be approved by the local Purchasing Agent prior to submitting a request for Cal OES approval. A copy of the Purchasing Agent’s approval must be included with the
Cal OES Request for Noncompetitive Procurement
Authorization completed in GCS. Cal OES may request
additional documentation that supports the procurement
effort.
28

Section 6 ‒ Post Award Requirements | 2024
Noncompetitive
Procurement
Cont.

Performance
Bond
Environmental
Planning and
Historic
Preservation (EHP)
Cal OES will not reimburse for any noncompetitive
procurement contracts for any HSGP terrorism-related
training, regardless of the cost of the training. Exceptions to this policy may be approved in limited circumstances, e.g., related to a procurement effort that has resulted in
inadequate competition. Please refer to GMM2017-01A and GMM2021-05 for additional guidance.

Due to the risks associated with delays in vendor delivery of large equipment procurements, DHS/FEMA allows
Subrecipients to obtain a “performance bond” for items that are paid for up front to ensure delivery of the equipment within the grant period of performance.

Cal OES requires Subrecipients to obtain a performance bond when procuring any equipment item over $250,000, or for any vehicle, aircraft, or watercraft that requires full or partial payment prior to receiving the final product(s).

Performance Bond Waivers may be granted on a case-bycase basis and must be submitted to Cal OES in GCS prior to procurement.

DHS/FEMA is required to ensure all activities and programs that are funded by the agency comply with federal
Environmental Planning and Historic Preservation (EHP)
regulations. Subrecipients proposing projects or activities (including, but not limited to, training, exercises, the installation of equipment, and construction or renovation projects) that have the potential to impact the environment, or a historic structure must participate in the EHP screening process. EHP Screening Memos must include detailed project information, explain the goals and objectives of the proposed project, and include supporting documentation.

DHS/FEMA may also require the Subrecipient to provide a confidential California Historical Resources Information System (CHRIS) report in addition to the EHP Screening Form.

Determination on the necessity of a CHRIS report is based upon information disclosed on the form. Grants Analysts will provide additional instructions should this report be required. 29

Section 6 ‒ Post Award Requirements | 2024
Environmental
Planning and
Historic
Preservation (EHP)
Cont.

Construction and
Renovation
Inventory Control
and Property
Management
EHP Screening Requests should be submitted to Cal OES as early as possible. All projects/activities triggering EHP must receive DHS/FEMA written approval prior to commencement of the funded activity.

Updated information may be referenced in the FEMA GPD
EHP Policy Guidance.

When applying for construction activity at the time of
application, including communication towers, Subrecipients must submit evidence of approved zoning ordinances,
architectural plans, any other locally required planning permits, and a notice of federal interest. Additionally, Subrecipients are required to submit an SF-424C Budget and Budget Detail that cites project costs. Communication tower construction requests also require evidence that the Federal Communications Commission’s Section 106 review process
was completed.

Subrecipients using funds for construction projects must comply with the Davis-Bacon Act. Subrecipients 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.

Project construction using SHSP and UASI funds may not
exceed $1,000,000 or 15% of the grant subaward (for the purposes of limitations on funding levels, communications towers are not considered construction).

Written approval for construction must be provided by
DHS/FEMA prior to the use of any HSGP funds for construction or renovation. No construction activities (including site preparation, utility installations, and any groundbreaking activities) or equipment installations on existing structures, may begin until the EHP review process is complete.

Subrecipients must use standardized resource management concepts for resource typing and credentialing, in addition to maintaining an inventory by which to facilitate the effective identification, dispatch, deployment, tracking, and recovery 30

Section 6 ‒ Post Award Requirements | 2024
Inventory Control
and Property
Management
Cont.

Equipment
Disposition
Performance
Reporting
Extension
Requests
of resources.

Subrecipients must have an effective inventory management system, to include:
• Property records that document description, serial/ID number, fund source, title information, acquisition date, cost, federal cost share, location, use, condition, and ultimate disposition;
• A physical inventory conducted at least every two years; • A control system to prevent loss, damage, and theft of grant purchased equipment and supplies; and
• Adequate maintenance procedures to keep the property
in good condition.

When original or replacement equipment acquired under the HSGP is no longer needed for program activities, the
Subrecipient must contact the Grants Analyst to request disposition instructions. See 2 C.F.R. § 200.313(e).

Subrecipients must complete a BSIR each Winter and Summer using the DHS/FEMA Grants Reporting Tool (GRT) for all
awards prior to FY 2024. All subsequent BSIR reports will be submitted in FEMA GO. BSIR must be completed for the
duration of each subaward period of performance or until all grant activities are completed and the subaward is formally closed by Cal OES. Failure to submit a BSIR could result in subaward reduction, suspension, or termination.

The Subrecipient will be required to ensure up-to-date project information is entered. The appropriate budget pages in GCS may assist with the BSIR data entry process. For additional assistance with the BSIR, please contact your Grants Analyst.

Extensions to the initial period of performance identified in the subaward will only be considered through formal, written requests to your Grants Analyst. Upon receipt of the extension request, Cal OES will:

1. Verify compliance with performance reporting
requirements by confirming the Subrecipient has
submitted all necessary performance reports;

2. Confirm the Subrecipient has provided sufficient
justification for the request; and
31

Section 6 ‒ Post Award Requirements | 2024
Extension
Requests Cont.

3. If applicable, confirm the Subrecipient has demonstrated sufficient progress in past situations where an extension was authorized by Cal OES.

Extension requests will be granted only due to compelling legal, policy, or operational challenges, must be projectspecific and will only be considered for the following reasons:

1. Contractual commitments with vendors that prevent
completion of the project within the period of
performance;

2. The project must undergo a complex environmental
review which cannot be completed within this timeframe;

3. Projects are long-term by design and therefore,
acceleration would compromise core programmatic
goals; and

4. Where other special circumstances exist.

To be considered, extension requests must be received no later than 60 days prior to the end of the Subrecipient’s period of performance and must contain specific and
compelling justifications as to why an extension is required. All extension requests must address the following:

1. Grant program, fiscal year, and award number;

2. Reason for delay;

3. Current status of the activity/activities;

4. Approved period of performance termination date and
new project completion date;

5. Amount of funds drawn down to date;

6. Remaining available funds, both federal and non-federal;

7. Budget outlining how remaining federal and non-federal funds will be expended;

8. Plan for completion, including milestones and timeframes for each milestone and the position/person responsible for implementing the plan for completion; and

9. Certification the activity/activities will be completed within the extended period of performance without any
modification to the original Project Scope.

General questions regarding extension requirements and the extension request form, should be directed to your Program Analyst. For additional information, please see IB 379. 32

Section 6 ‒ Post Award Requirements | 2024
Extension
Requests
Cont.

Extension requests for personnel and salaries do not meet the requirements of IB 379 and will not be granted. Subrecipients are expected to complete all grant-funded personnel
activities by the end of the subaward period of performance.

Progress Reports
on Grant
Extensions
All Subrecipients that receive Cal OES approval to extend their FY 2024 Grant Subaward period of performance may be required to submit progress reports indicating completed and future project milestones on all extended projects. Progress reports must be submitted electronically to the Subrecipient’s Grants Analyst. Deadlines for the submission of progress reports will be established at the time of extension approval.

Monitoring Cal OES Grants Monitoring actively monitors Subrecipients, through day-to-day communications, programmatic site
visits, desk, and on-site compliance assessments. The purpose of the compliance assessment is to ensure Subrecipients are in compliance with applicable state and federal regulations, grant guidelines, and programmatic requirements.

Monitoring activities may include, but are not limited to:
• Verifying entries recorded on the GCS budget categories are properly supported with source documentation;
• Eligibility of and support for expenditures, typically covering two to three years of data;
• Comparing actual Subrecipient activities to those
approved in the grant application and subsequent
modifications, including the review of timesheets and
invoices as applicable;
• Procurements and contracts;
• Ensuring equipment lists are properly maintained and
physical inventories are conducted;
• Ensuring advances have been disbursed in accordance
with applicable guidelines; and
• Confirming compliance with Standard Assurances; and
• Information provided on performance reports and
payment requests
NOTE: It is the responsibility of all Subrecipients that pass down grant funds to other entities, to maintain and utilize a formal process to monitor the grant activities of their subawards. This requirement includes, but is not limited to, on-site verification 33

Section 6 ‒ Post Award Requirements | 2024
Monitoring
Cont.

Failure to Submit
Required Reports
Suspension/
Termination
of grant activities, as required. It is common for Subrecipients to receive findings in a programmatic site visit or compliance assessment, which require a Corrective Action Plan (CAP) to be submitted by Subrecipients. Those Subrecipients who fail to submit a CAP, as required, shall have a “hold” placed on any future reimbursements until the “finding” is resolved.

Periodic reporting is required by the grant. Subrecipients who miss a single reporting deadline may receive a letter
addressed to their Board of Supervisors informing them of the failure to report. County OAs and tribes who fail to report twice consecutively may have subsequent awards reduced
by 10% until timely reporting is reestablished; UASIs may have a “hold” placed on any future reimbursements.

Cal OES may suspend or terminate grant funding, in whole or in part, or other measures may be imposed for any of the following reasons:
• Failure to submit required reports.
• Failure to expend funds in a timely manner consistent with the grant milestones, guidance, and assurances.
• Failure to comply with the requirements or statutory
progress toward the goals or objectives of federal or state law.
• Failure to make satisfactory progress toward the goals or objectives set forth in the Subrecipient application.
• Failure to follow Grant Subaward requirements or Special Conditions.
• Proposing or implementing substantial plan changes to the extent that, if originally submitted, the application would not have been selected for funding.
• False certification in the application or document.
• Failure to adequately manage, monitor, or direct the
grant funding activities of their Subrecipients.

Before taking action, Cal OES will provide the Subrecipient reasonable notice of intent to impose corrective measures and will make every effort to informally resolve the problem. 34

Section 6 ‒ Post Award Requirements | 2024
Closeout
Records Retention
Cal OES will close-out Subrecipient awards when it
determines all applicable administrative actions and all required work of the federal award have been completed.

Subawards will be closed after:
• All funds have been requested and reimbursed, or
disencumbered;
• Receiving all applicable Subrecipient reports indicating all approved work has been completed, and all funds have
been distributed;
• Completing a review to confirm the accuracy of reported information;
• Reconciling actual costs to subawards, modifications, and payments; and
• Verifying the Subrecipient has submitted a final BSIR showing all grant funds have been expended.

The records retention period is three years from the date of the Cal OES Grant Closeout letter, or until any pending litigation, claim, or audit started before the expiration of the three-year retention period has been resolved and final action is taken.

For indirect cost rate proposals, cost allocation plans, or other rate computation records, the start of the record retention period is dependent on whether the proposal, plan, or other computation is required to be submitted to the federal
government (or to the pass-through entity) for negotiation purposes. See 2 C.F.R. § 200.334(f).

In order for any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g).

The Cal OES Grant Closeout Letter will notify the Subrecipient of the start of the records retention period for all
programmatic and financial grant-related records.

If the State Administrative Agency’s award remains open after the Subrecipient’s submission of the final BSIR, Cal OES will complete any additional BSIR reporting required under the award on behalf of the Subrecipient.

Closed grants may still be monitored and audited. Failure to 35

Section 6 ‒ Post Award Requirements | 2024
Records Retention
Cont.
maintain all grant records for the required retention period could result in a reduction of grant funds, and an invoice to return costs associated with the unsupported activities.

If documents are retained longer than the required retention period, FEMA, the DHS Office of Inspector General,
Government Accountability Office, and pass-through entity have the right to access these records as well. See 2 C.F.R. §§ 200.334, 200.336.
36

Attachment A ‒ FY 2024 HSGP Allocations | 2024
*SHSP allocations reflect National Priority Area project adjustments State Homeland Security Program (SHSP)
Operational Area Total Award Operational Area Total Award ALAMEDA 1,453,851 ORANGE 2,718,746
ALPINE 75,998 PLACER 420,772
AMADOR 108,571 PLUMAS 91,008
BUTTE 248,256 RIVERSIDE 2,130,587
CALAVERAS 112,830 SACRAMENTO 1,400,136
COLUSA 93,346 SAN BENITO 130,337
CONTRA COSTA 1,042,148 SAN BERNARDINO 1,913,858
DEL NORTE 97,417 SAN DIEGO 2,830,483
EL DORADO 234,278 SAN FRANCISCO 775,892
FRESNO 927,408 SAN JOAQUIN 737,499
GLENN 96,159 SAN LUIS OBISPO 316,482
HUMBOLDT 187,964 SAN MATEO 696,626
IMPERIAL 226,248 SANTA BARBARA 446,265
INYO 90,923 SANTA CLARA 1,664,434
KERN 839,747 SANTA CRUZ 295,835
KINGS 202,266 SHASTA 226,214
LAKE 127,354 SIERRA 77,691
LASSEN 98,828 SISKIYOU 111,698
LOS ANGELES 8,300,952 SOLANO 448,956
MADERA 208,274 SONOMA 477,966
MARIN 288,172 STANISLAUS 535,072
MARIPOSA 89,272 SUTTER 158,389
MENDOCINO 150,140 TEHAMA 129,162
MERCED 315,459 TRINITY 88,432
MODOC 82,186 TULARE 475,346
MONO 86,086 TUOLUMNE 121,004
MONTEREY 437,680 VENTURA 770,793
NAPA 188,460 YOLO 261,139
NEVADA 159,879 YUBA 144,674
*Total 37,165,648
37

Attachment A ‒ FY 2024 HSGP Allocations | 2024
Fusion Centers
Region Total Award
SAN FRANCISCO BAY AREA 1,792,050
SACRAMENTO/CENTRAL VALLEY AREA 2,565,000
GREATER LOS ANGELES AREA 2,887,500
SAN DIEGO AREA 2,047,500
ORANGE AREA 835,000
*Total 10,127,050
* SHSP allocations reflect National Priority Area project adjustments Urban Areas Security Initiative (UASI)
*A minimum of 35% of UASI funding must be for Law Enforcement Terrorism Prevention Urban Area
Federal
Allocation to
State
Allocation to
UASI State Initiatives
ANAHEIM/SANTA ANA AREA 4,712,190 3,896,981 815,209
BAY AREA 32,754,895 27,088,298 5,666,597
LOS ANGELES/LONG BEACH AREA 59,395,378 49,119,978 10,275,400 RIVERSIDE AREA 3,500,484 2,894,900 605,584
SACRAMENTO AREA 3,410,728 2,820,672 590,056
SAN DIEGO AREA 14,760,877 12,207,245 2,553,632
Total 118,534,552 98,028,075 20,506,477
38

Attachment B ‒ FY 2024 HSGP Timeline | 2024
DHS/FEMA Announcement of 2024 HSGP NOFO April 16, 2024
Cal OES Application Due to DHS June 24, 2024
DHS Award to California September 27, 2024
Subrecipient period of performance begins September 1, 2024 Subrecipient Workshops October 2024
Subrecipient Awards (45 days from DHS award) October 2024 2024 HSGP California Supplement release November 2024
Subrecipient Final Applications for FY24 Due to
Cal OES in GCS
February 10, 2025
Subrecipient period of performance ends May 31, 2027
Final Cash Requests due to Cal OES Within twenty (20) calendar days after end of grant
Cal OES’s period of performance ends August 31, 2027
39

GAVIN NEWSOM

GOVERNOR

NANCY WARD

DIRECTOR
3650 SCHRIEVER AVENUE, MATHER, CA 95655
(916) 845-8506 TELEPHONE (916) 845-8511 FAX
www.CalOES.ca.gov
DELIVERED VIA E-MAIL: [email protected]
October 28, 2024
Sabrina Bustamante
Emergency Services Manager
Tulare County
5957 S. Mooney Boulevard
Visalia, CA 93277
SUBJECT: NOTIFICATION OF SUBRECIPIENT ALLOCATION
Fiscal Year (FY) 2024 Homeland Security Grant Program (HSGP) Grant Subaward Period of Performance: 09/01/2024-05/31/2027 Dear Ms. Bustamante:

We are pleased to announce the approval of your FY 2024 HSGP subaward in the amount of $475,346.

This subaward is subject to requirements in 2 CFR, Part 200, including the Notice of Funding Opportunity (NOFO), the Preparedness Grants Manual, the California Supplement to the NOFO, reporting requirements, and all applicable federal, state, and local requirements. All activities funded with this subaward must be completed within the subaward period of performance.

Your organization will be required to prepare and submit the Biannual Strategy Implementation Report (BSIR) to Cal OES semi-annually for the duration of the subaward period of performance or until all activities are completed and the subaward is formally closed. Throughout the subaward cycle, milestones set in the BSIR will be used as indicators of project feasibility, performance, and grant management capacity. This information may also be used in assessing proposals in future grant opportunities. Failure to submit required reports could result in subaward reduction, suspension, or termination.

Subrecipients must obtain additional approval prior to incurring costs for activities such as aviation, watercraft, allowability request logs, noncompetitive

Sabrina Bustamante
October 28, 2024

__________________________________ __________________
Sabrina Bustamante Date
Tulare County
procurement, and projects requiring Environmental Planning and Historic Preservation review.

Next Steps:
 Your signature is required on this letter. Please sign and return this letter via email to your Cal OES Grants Analyst (GA) within 20 calendar days of receipt and keep a copy for your records.
 If you have not already, please visit the Grants Central System (GCS) webpage to register your organization.
 You will be notified to complete your application as soon as it is available in GCS – we anticipate mid-January 2025.
 Once the completed application is submitted and approved in GCS, you will be able to request reimbursement of eligible subaward expenditures in the system.

Please contact your GA if you have questions or need further assistance.

Sincerely,

NANCY WARD
Director
10/30/2024

APPROVAL AUTHORITY
MEMBERS Member/Alternate Name Title Address Phone E-mail Police Chief Member- Mike Marquez Police Chief, City of Woodlake 350 N. Valencia Blvd., Woodlake, CA 93286 (559) 564-3346 [email protected] AlternateMunicipal Fire Chief Member- Dan Griswold Fire Chief, City of Visalia 420 N Burke St Visalia, CA 93292 (559) 713-4220 [email protected] AlternateCounty Sheriff Member- Mike Boudreaux Sheriff 833 S. Akers St.

Visalia, CA 93277 (559) 802-9435 [email protected] AlternateCounty Fire Chief Member- Charles Norman Fire Chief 835 S Akers St.

Visalia, CA 93277 (559) 967-5420 [email protected] Alternate- Kevin Riggi Division Chief (559) 731-9151 [email protected] County Public Health Officer Member- Dr. Thomas Overton Health Officer 5957 S. Mooney Blvd.

Visalia, CA 93277 (559) 624-8480 [email protected] Alternate2024 APPROVAL AUTHORITY MEMBERS

HOMELAND SECURITY GRANT PROGRAM
835 S Akers St.

Visalia, CA 93277

SYSTEM FOR AWARD MANAGEMENT (SAM)

REQUIREMENTS
If your agency is using HSGP grant funds to contract with anyone, you MUST verify that they are NOT debarred on the Government’s “System for Award Management” by checking
the website:
http://www.sam.gov
 Checks must be performed at the time of the Project
Proposal, if there is a vendor change, and before payment.  Locate the “SEARCH RECORDS” menu item. You may
search by an entity’s name, UEI Number, or DUNS Number.  Enter the requested information (i.e. individual, firm, or entity’s name; UEI Number or DUNS Number). Click on
search. The search will display the results.
 If your search returned no results, click on “Printer-Friendly” and print the search results. If the search leads you to any Active Exclusion Records for that person or entity, this means they may be debarred or suspended and may NOT
be eligible to receive any grant funds.
 Attach the search results to your reimbursement request.

The printed search results are very important because the date will be printed on the report and it must be prior to the date you contract with anyone. This report must
accompany your reimbursement request to be eligible for reimbursement.
 If the contractor is listed on the website as debarred or suspended and you use their services, you will NOT be
eligible for reimbursement from Tulare County OES.
 Contractors are only allowed a maximum reimbursement of eight (8) hours per day.

Preparedness Grants
Manual
FM-207-23-001
April 2024

Preparedness Grants Manual
This page intentionally left blank

Preparedness Grants Manual
1 Table of Contents

1. Foreword ................................................................................................................................. 5

1.1. Overview of the Federal Emergency Management Agency........................................... 5

1.2. Overview of the Preparedness Grants Manual’s Intent ................................................ 5

1.3. Key Changes .................................................................................................................... 5

1.4. Overview of Preparedness Grant Programs ................................................................... 6

1.5. National Preparedness Goal ........................................................................................... 8

1.6. Strengthening Governance Integration .......................................................................... 8

2. Award Determination and Obligation ................................................................................... 10

2.1. Federal Award Administration Information ................................................................. 10

3. Recipient and Subrecipient Costs ........................................................................................ 11

3.1. Funding Restrictions .................................................................................................... 11

3.2. Direct Allowable Costs .................................................................................................. 11

3.3. Maintenance and Sustainment ................................................................................... 15

3.4. Management and Administration ................................................................................ 16

3.5. Procedures for Establishing Indirect Cost Rates ........................................................ 16

4. Administrative and National Policy Requirements ............................................................... 18

4.1. Accessibility Compliance .............................................................................................. 18

4.2. Ensuring the Protection of Civil Rights ........................................................................ 18

4.3. Disability Integration .................................................................................................... 19

4.4. Language Access .......................................................................................................... 20

4.5. Environmental Planning and Historic Preservation Compliance ............................... 20

4.6. Davis-Bacon Act Compliance ....................................................................................... 23

4.7. National Incident Management System Implementation .......................................... 23

4.8. SAFECOM Guidance Compliance ................................................................................ 24

4.9. Resilient Communications Guidance .......................................................................... 26

4.10. FirstNet ......................................................................................................................... 27

4.11. Department of Homeland Security/FEMA Communications Support Services........ 28

5. Post-Award Management and Implementation .................................................................... 31

5.1. Reporting ...................................................................................................................... 31

Preparedness Grants Manual
2 5.2. Federal Financial Reporting Requirements ................................................................ 31

5.3. Program Performance Reporting Requirements ........................................................ 32

5.4. Biannual Strategy Implementation Report ................................................................. 33

5.5. Closeout Reporting Requirements .............................................................................. 33

5.6. Administrative Closeout ............................................................................................... 34

5.7. Disclosing Information per 2 C.F.R. § 180.335 ......................................................... 34

5.8. Reporting of Matters Related to Recipient Integrity and Performance..................... 35

6. Additional Information .......................................................................................................... 36

6.1. Monitoring and Oversight............................................................................................. 36

6.2. Case Studies and Use of Grant-Funded Resources During Real-World Incident Operations .................................................................................................................... 39

6.3. Termination Provisions ................................................................................................ 40

6.4. Period of Performance Extensions .............................................................................. 40

6.5. Conflicts of Interest in the Administration of Federal Awards or Subawards ........... 41

6.6. Procurement Integrity .................................................................................................. 42

6.7. Financial Assistance Programs for Infrastructure ...................................................... 46

6.8. Records Retention ........................................................................................................ 46

6.9. Actions to Address Noncompliance ............................................................................. 47

6.10. Audits ............................................................................................................................ 48

6.11. Reporting Issues of Fraud, Waste, and Abuse ........................................................... 50

6.12. Payment Information .................................................................................................... 50

6.13. Whole Community Preparedness ................................................................................ 50

7. Resources ............................................................................................................................. 52

7.1. Department of Homeland Security/FEMA Provided Training and Education ........... 52

7.2. Training Not Provided by the Department of Homeland Security/FEMA .................. 52

7.3. Training Information Reporting System (“Web-Forms”) ............................................. 52

7.4. FEMA’s National Preparedness Course Catalog ........................................................ 52

7.5. Exercises ....................................................................................................................... 53

7.6. Planning Assistance ..................................................................................................... 53

7.7. Training Information ..................................................................................................... 53

7.8. Weblinks ....................................................................................................................... 54

Preparedness Grants Manual
3 7.9. Emergency Management Accreditation Program ....................................................... 54

8. Homeland Security Grant Program and Tribal Homeland Security Grant Program ............. 55

8.1. Alignment to the National Preparedness System (Homeland Security Grant Program, Tribal Homeland Security Grant Program) .................................................................. 55

8.2. Reporting on the Implementation of the National Preparedness System (Homeland Security Grant Program, Tribal Homeland Security Grant Program) ......................... 56

8.3. Funding Guidelines (Homeland Security Grant Program, Tribal Homeland Security Grant Program) ............................................................................................................. 59

8.4. Allowable Costs (Homeland Security Grant Program) ................................................ 59

8.5. Fusion Centers (Homeland Security Grant Program) ................................................. 60

8.6. Investment Modifications – Changes in Scope or Objective (Tribal Homeland Security Grant Program) .............................................................................................. 64

8.7. Continuity Capability (Homeland Security Grant Program, Tribal Homeland Security Grant Program) ............................................................................................................. 65

8.8. Senior Advisory Committee (Homeland Security Grant Program) ............................. 65

8.9. Urban Area Working Group (Homeland Security Grant Program) ............................. 68

8.10. Supplemental State Homeland Security Program and Urban Area Security Initiative Guidance (Homeland Security Grant Program) .......................................................... 70

8.11. Operation Stonegarden Operational Guidance (Homeland Security Grant Program) ....................................................................................................................................... 71

8.12. Supplemental Resources (Homeland Security Grant Program, Tribal Homeland Security Grant Program) .............................................................................................. 79

9. Nonprofit Security Grant Program ........................................................................................ 83

9.1. Program Funding Guidelines and Priorities ................................................................ 83

9.2. Nonprofit Security Grant Program Investment Modifications – Changes in Scope or Objective ....................................................................................................................... 83

9.3. Pass-Through Requirements ....................................................................................... 84

10. Surface Transportation Security Grant Programs (Transit Security Grant Program, Intercity Passenger Rail Program, Intercity Bus Security Grant Program) .................................. 86

10.1. Program Funding Guidelines and Priorities (Transit Security Grant Program, Intercity Passenger Rail Program, Intercity Bus Security Grant Program) .............................. 86

10.2. Changes in Scope or Objectives (Transit Security Grant Program, Intercity Passenger Rail Program, Intercity Bus Security Grant Program) ................................................. 86

10.3. Security Plan Requirements (Transit Security Grant Program, Intercity Passenger Rail Program, Intercity Bus Security Grant Program) ................................................. 86

10.4. Allowable Cost Guidance ............................................................................................. 89

Preparedness Grants Manual
4 11. Port Security Grant Program ................................................................................................ 91

11.1. Program Funding Guidelines and Priorities ................................................................ 91

11.2. Allowable Cost Guidance ............................................................................................. 91

11.3. Port-Wide Risk Management Plans ............................................................................. 93

11.4. Port Security Grant Program Investment Modifications ............................................ 93

12. Emergency Management Performance Grant Program ....................................................... 94

12.1. Alignment of the Emergency Management Performance Grant Program to the National Preparedness System ................................................................................... 94

12.2. Implementation of the National Preparedness System ............................................. 95

12.3. Logistics Planning ......................................................................................................... 99

12.4. Evacuation Planning ................................................................................................... 100

12.5. Disaster Housing Planning ......................................................................................... 101

12.6. State Disaster Recovery Coordinator ........................................................................ 102

12.7. Disaster Financial Management Policies and Procedures ...................................... 102

12.8. Training and Exercises ............................................................................................... 104

12.9. Reviewing and Updating Planning Products ............................................................. 108

12.10. Program Performance Reporting Requirements ...................................................... 108

13. Abbreviations and Acronyms .............................................................................................. 109

U.S. Department of Homeland Security
Washington, DC 20472
April 12, 2024

MEMORANDUM FOR RECORD
FROM: Pamela S. Williams
Assistant Administrator
Grant Programs Directorate
SUBJECT: Preparedness Grants Manual, April 2024

The Grant Programs Directorate’s Office of Grants Administration (OGA) has developed FEMA Manual 207-23-001, Preparedness Grants Manual, April 2024. FEMA has developed the Preparedness Grants Manual (PGM) to guide preparedness grant recipients, including subrecipients, on how to manage their grants. The preparedness grant programs covered in the PGM include the following:
 Homeland Security Grant Program (comprising the State Homeland Security Grant Program, the Urban Area Security Initiative, and Operation Stongarden);  Tribal Homeland Security Grant Program;
 Nonprofit Security Grant Program;
 Transit Security Grant Program;
 Intercity Passenger Rail Program;
 Intercity Bus Security Grant Program;
 Port Security Grant Program; and
 Emergency Management Performance Grant Program.

Recipients seeking guidance on policies and procedures for managing the aforementioned FEMA preparedness grants should reference this manual for further information. Chapters 8-12 of the PGM contain program-specific information and requirements, while the main content of the PGM (chapters 1-7) contains important information relevant to all preparedness grant programs unless otherwise noted.

The PGM has been updated pursuant to FEMA Directive 112-12 v2, Development and Management of FEMA Policy (October 28, 2019), and in collaboration with the Regional Grants Management Divisions, the OGA program areas and their Department of Homeland Security counterparts (e.g., the U.S. Coast Guard, the Transportation Security Administration, and the Cybersecurity and Infrastructure Security Agency), the Office of External Affairs (including Tribal Affairs), the Office of Chief Counsel, the Office of Environmental and Historic Preservation, the Office of Resilience Strategy, the Office of Equal Rights, the Office of Disability Integration and Coordination, the Office of Policy and Program Analysis, and other financial assistance support offices.

The PGM April 2024 update associated with this memorandum supersedes the previously published version of the PGM issued on February 27, 2023, for Fiscal Year 2024 and into the future, and is effective as of the date of this memorandum. An explanation of specific updates to the PGM can be found in Section 1.3, Key Changes, after the Table of Contents.

Please contact the GPD Office of Enterprise Grants Services Policy Division at fema-gpd[email protected] if you have any questions regarding FEMA Manual 207-23-001, Preparedness Grants Manual, April 2024.

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5 1. Foreword

1.1. Overview of the Federal Emergency Management Agency The mission of the Federal Emergency Management Agency (FEMA) is helping people before, during, and after disasters, and the agency has done so for more than 40 years. FEMA remains committed to building resilience 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 areas impacted by any emergency or disaster are the true first responders—individuals, families, neighbors, and local communities. FEMA’s role is to coordinate federal resources to supplement SLTT capabilities. FEMA does this by coordinating across all levels of government meaning that states, local governments, Tribal Nations, and territories are FEMA’s primary partners.

1.2. Overview of the Preparedness Grants Manual’s Intent FEMA has developed this Preparedness Grants Manual to guide grant recipients, including subrecipients, on how to manage their grants. Recipients seeking guidance on policies and procedures for managing FEMA preparedness grants should reference this manual for further information. The Notice of Funding Opportunity (NOFO) for each program includes information needed to apply to the grant. This manual and relevant NOFOs can be reviewed and consulted in tandem.

Chapters 8-12 of this manual contain program-specific information and requirements, while the main content of this manual (chapters 1-7) contains important information relevant to all preparedness grant programs unless otherwise noted. Please be sure to read both the main content of this manual as well as the program-specific chapters, as needed.

All recipients and subrecipients of FEMA grants 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. For more information on 2 C.F.R. Part 200, please see Information Bulletin (IB) 400, FEMA’s Implementation of 2 C.F.R. Part 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Super Circular” or “Omni Circular”) dated Dec. 23, 2014, regarding FEMA’s implementation of these provisions prior to the recent 2020 revisions. For information on the recent revisions to these regulations, see 2 C.F.R.

Grants Management Policy Updates.

1.3. Key Changes
Future updates to this manual will include a section on specific line-by-line “key changes” made since the last update.

This version of the manual has significantly streamlined pertinent recipient/subrecipient information, lessening the back-and-forth needed between the NOFO and the Preparedness Grants Manual and more clearly defining that the NOFO focuses on applying for the grant, while the manual focuses on managing the grant. Between the Fiscal Year (FY) 2023 and FY 2024 versions, the manual has made the following overarching changes:

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6 1. Sections 2-7, unless otherwise noted, apply to all eight grant programs featured in the manual. These sections are considered generic requirements and do not include how to apply to the grant.

2. Specific direct allowable cost information, previously in program-specific chapters, has been moved to the NOFOs. General cost information is in Section 3.

3. The Transit Security Grant Program (TSGP), Intercity Bus Security Grant Program (IBSGP), and Intercity Passenger Rail (IPR) Program Chapters as well as the Homeland Security Grant Program (HSGP) and Tribal Homeland Security Grant Program (THSGP) Chapters are combined.

1.4. Overview of Preparedness Grant Programs
FEMA has the statutory authority to deliver numerous disaster and non-disaster (ND) financial assistance programs in support of its mission, and that of the U.S. Department of Homeland Security (DHS), largely through grants and cooperative agreements. These programs account for a significant amount of the federal assistance 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 (OMB) circulars, and federal appropriations laws and principles. FEMA has developed this manual to provide uniform direction on grant policy and implementation for the following grant programs. If the FEMA grant program you are looking for is not listed below, please navigate to FEMA.gov to find more information.

1.4.1. HOMELAND SECURITY GRANT PROGRAM
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 SLTT 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): The UASI assists high-risk 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 U.S. Customs and Border Protection (CBP), United States Border Patrol (USBP), and federal and SLTT law enforcement agencies to improve overall border security. OPSG provides funding to support joint efforts to secure U.S. 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 by participating in OPSG.

For additional information about the HSGP not found in the NOFO, manual, or other program-specific guidance, contact [email protected].

1.4.2. TRIBAL HOMELAND SECURITY GRANT PROGRAM
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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7  For additional information about the THSGP not found in the NOFO, manual, or other programspecific guidance, contact [email protected].

1.4.3. NONPROFIT SECURITY GRANT PROGRAM
The Nonprofit Security Grant Program (NSGP) provides funding for physical security enhancements and other security-related activities to nonprofit organizations that are at high risk of a terrorist or other extremist attack. The NSGP also seeks to integrate the preparedness activities of nonprofit organizations with broader state and local preparedness efforts.  For additional information about the NSGP not found in the NOFO, manual, or other programspecific guidance, contact [email protected].

1.4.4. TRANSIT SECURITY GRANT PROGRAM
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.  For additional information about the TSGP not found in the NOFO, manual, or other programspecific guidance, contact [email protected].

1.4.5. INTERCITY BUS SECURITY GRANT PROGRAM
The IBSGP provides funds to eligible private operators of intercity over-the-road buses to protect critical transportation infrastructure and travelling public from acts of terrorism, and to increase transportation infrastructure resilience.
 For additional information about the IBSGP not found in the NOFO, manual, or other programspecific guidance, contact [email protected].

1.4.6. INTERCITY PASSENGER RAIL PROGRAM - AMTRAK
The IPR Program 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.
 For additional information about the IPR Program not found in the NOFO, manual, or other program-specific guidance, contact [email protected].

1.4.7. PORT SECURITY GRANT PROGRAM
The Port Security Grant Program (PSGP) provides funding to port authorities, facility operators, and state and local agencies for activities associated with implementing Area Maritime Security Plans (AMSP), facility security plans, and other port-wide risk management efforts.  For additional information about the PSGP not found in the NOFO, manual, or other programspecific guidance, contact [email protected].

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8 1.4.8. EMERGENCY MANAGEMENT PERFORMANCE GRANT PROGRAM The Emergency Management Performance Grant (EMPG) Program provides funds to assist SLTT 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.  For additional information about the EMPG Program not found in the NOFO, manual, or other program-specific guidance, contact [email protected].

1.5. 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.” 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’s five mission areas include:
 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.” 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 details regarding the National Preparedness System and how it is supported by preparedness grant programs can be found in the program-specific chapters.

1.6. 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

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9 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.

Recipients must coordinate activities across preparedness disciplines and levels of government, including SLTT 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. 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, capabilitiesbased planning. Strong and inclusive governance systems better ensure that disparate funding streams are coordinated and applied for maximum impact. Inclusive governance can effectively support a whole community approach to emergency preparedness and management and the enhancement of core capabilities.

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 and coordinated among affected preparedness stakeholders, including appropriate representatives of at-risk, underserved communities.
 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 recipient level, local risk assessments must be included in the overarching analysis to ensure that all threats and hazards are accounted for. Primary focus should be on the needs of socially vulnerable and underserved populations—including rural populations—as well as ensuring equity for those most at risk relative to disaster preparedness, response, and recovery.  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, particularly when it comes to serving the needs of at-risk, underserved communities.
 Support of Regional Coordination: Inter/intra-government entity partnerships and dependencies at the state, territorial, tribal, and regional levels, including those within metropolitan areas, must be recognized.

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10 2. Award Determination and Obligation

2.1. Federal Award Administration Information

2.1.1. NOTICE OF AWARD
Before accepting the award, the Authorized Organizational Representative (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.

Beginning in FY 2024, notification of award approval is made through the FEMA Grants Outcomes (FEMA GO) 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.

Recipients must accept their awards within the time specified in the program-specific NOFO. The recipient shall notify FEMA within this timeframe of its intent to accept and proceed with work under the award or provide a notice of intent to decline through the FEMA GO system. For instructions on how to accept or decline an award in the FEMA GO system and for more information on FEMA GO generally, please see the FEMA GO page on FEMA.gov. Funds will remain on hold until the recipient accepts the award through the FEMA GO system and all other conditions of the award have been satisfied or until the award is otherwise rescinded. Failure to accept a grant award within the NOFOspecified timeframe may result in a loss of funds.

2.1.2. PASS-THROUGH REQUIREMENTS
Please see the applicable program-specific NOFO and chapter of this manual for information on pass-through requirements for that program.

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11 3. Recipient and Subrecipient Costs

3.1. Funding Restrictions
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 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 (POP) 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 POP).

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 chapter to this manual, the program NOFO, or the terms and conditions 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. 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 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 those costs and must be consistent with the statutory authority for the award. Grant funds may not be used for matching funds for other federal grants/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.

3.2. Direct Allowable Costs
Specific investments made in support of the funding priorities discussed in the NOFOs 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; and

8. Training.

As this list is not exhaustive, refer to the relevant program-specific NOFO, this manual, and the program-specific point of contact for more information on allowable costs, funding restrictions, funding priorities, and these categories.

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12 3.2.1. 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.

Grant funds must comply with FEMA Policy #207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards 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. Contact your Preparedness Officer with questions on the AEL.

3.2.2. REQUIREMENTS FOR SMALL UNMANNED AIRCRAFT SYSTEMS All requests to purchase Small Unmanned Aircraft Systems (sUAS) with FEMA grant funding must comply with FEMA Policy #207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards, 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. sUAS policies are not required at the time of application but must be received and approved by FEMA prior to obligating grant funds. All grant-funded procurements must be executed in a manner compliant with federal procurement standards at 2 C.F.R. §§ 200.317 – 200.327. For recipients that use grant funds for sUAS, FEMA advises that there is a general privacy concern related to the use of this equipment if the data the devices collect is transmitted to servers not under the control of the operator. It has been reported that some manufacturers of sUAS encrypt data and send that data to servers outside the United States. DHS’s Privacy Office suggests the recipient fully explore data transmission and storage issues with vendors to reduce the possibility of data breaches.

Additionally, the Senate Report accompanying the FY 2024 DHS Appropriations further requires recipients to certify they have reviewed the Industry Alert on Chinese Manufactured Unmanned Aircraft Systems, and completed a risk assessment that considers the proposed use of foreign-made sUAS to ascertain potential risks (e.g., privacy, data breaches, cybersecurity, etc.) related to foreignmade versus domestic sUAS.

Acquisition and Use of Technology to Mitigate Unmanned Aircraft Systems (CounterUnmanned Aircraft System) In August 2020, DHS, the Department of Justice, the Federal Aviation Administration, and the Federal Communications Commission issued the Interagency Legal Advisory on Unmanned Aircraft Systems (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, before the testing, acquisition, installation, or use of UAS detection and/or mitigation systems, entities seek the advice of counsel experienced with both federal and

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13 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: Interagency Issues Advisory on Use of Technology to Detect and Mitigate Unmanned Aircraft Systems. For training on the application of UAS technology in emergency management programs, please refer to the National Preparedness Course Catalog and search ‘UAS’ on the website.

The Cybersecurity and Infrastructure Security Agency (CISA) offers several resources that detail the UAS threat environment and security protocols on the Unmanned Aircraft Systems Resources page on CISA.gov. Additional resources may be found on the Homeland Security Information Network – Critical Infrastructure (HSIN-CI) site.

Table 1: Unmanned Aircraft System Allowability
Grant Program Allowed
HSGP (SHSP, UASI) Yes
HSGP (OPSG) Yes
THSGP Yes
NSGP No
TSGP Yes
IPR Program Yes
IBSGP No
PSGP Yes
EMPG Program Yes

3.2.3. 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, 200.327, 200.471, and Appendix II to 2 C.F.R. Part 200. Beginning Aug. 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.

Guidance is available in FEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services.

Additional guidance is available in the Contract Provisions Guide: Navigating Appendix II to Part 200 – Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.

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14 Effective Aug. 13, 2020, FEMA recipients and subrecipients may not use any FEMA funds under open or new awards to:
 Procure or obtain any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology of any system;
 Enter, extend, or renew a contract to procure or obtain any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology of any system; or  Enter, extend, or renew contracts with entities that use covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.

Replacement Equipment and Services: FEMA grant funding may be permitted to procure replacement equipment and services impacted by this prohibition, provided the costs are otherwise consistent with the requirements in this manual and the applicable NOFO.

Covered Communications
Per section 889(f)(2)-(3) of the FY 2019 NDAA and 2 C.F.R. § 200.216, covered telecommunications equipment or services means:
 Telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation, (or any subsidiary or affiliate of such entities);
 For the purpose of public safety, security of Government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities);
 Telecommunications or video surveillance services provided by such entities or using such equipment; or
 Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the People’s Republic of China.

Examples of the types of products covered by this prohibition include phones, internet, video surveillance, and cloud servers when produced, provided, or used by the entities listed in the definition of “covered telecommunications equipment or services.” See 2 C.F.R. § 200.471.

3.2.4. FUNDING FOR CRITICAL EMERGENCY SUPPLIES
Critical emergency supplies—such as shelf stable products, water, and basic medical supplies—are an allowable expense under the HSGP (SHSP and UASI only), THSGP, and EMPG Program. Each state, urban area, or tribe must have FEMA’s approval of a five-year viable inventory management plan prior to allocating grant funds for stockpiling purposes. The Inventory Management Plan should address how critical supplies will be maintained and sustained by the grant recipient and include a

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15 distribution strategy and related sustainment costs if the grant expenditure for these items is over $100,000. The Inventory Management Plan is associated with but distinct from the Distribution Management Plan, which addresses how supplies will be distributed in an emergency. For more information on distribution management planning, see FEMA’s Distribution Management Plan Guide

2.0. 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 (TA) as it relates to the purchase of critical emergency supplies. FEMA will establish guidelines and requirements for the purchase of these supplies and monitor development and status of the recipient’s inventory management plan.

Recipients 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.

Table 2: Critical Emergency Supplies Allowability
Grant Program Allowed
HSGP (SHSP, UASI) Yes
HSGP (OPSG) No
THSGP Yes
NSGP No
Surface Transportation
Security Grants (TSGP,
IBSGP, IPR Program)
No
PSGP No
EMPG Program Yes

3.3. Maintenance and Sustainment
The use of FEMA preparedness grant funds for maintenance contracts or agreements, warranty coverage, repair or replacement costs, licenses, upgrades, and user fees are allowable under all active and future grant awards, unless otherwise noted in the program-specific NOFO. These contracts may exceed the POP 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 POP 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.

Preparedness grant 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

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16 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. For the HSGP (SHSP and UASI) and EMPG Program only, shareable through the Emergency Management Assistance Compact (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.

For the HSGP, stand-alone warranties can only cover equipment purchased with HSGP funds or for equipment dedicated for HSGP-related purposes.

For the PSGP, maintenance and sustainment are focused specifically on the repair and replacement of existing equipment and does not include routine activities such as oil changes or washing/cleaning existing equipment.

For more information on maintenance and sustainment costs, see the program-specific NOFO.

3.4. Management and Administration
M&A costs are for activities directly related to the management and administration of the award, such as financial management, reporting, and program and financial monitoring. M&A costs are not operational costs, they are the necessary costs incurred in direct support of the grant or as a result of the grant and should be allocated across the entire lifecycle of the grant. Characteristics of M&A expenses can include the following: 1) direct costs that are incurred to administer a particular federal award; 2) identifiable and unique to each federal award; 3) charged based on the activity performed for that federal award; and 4) not duplicative of the same costs that are included in the approved Indirect Cost Rate Agreement, if applicable.

Some examples of M&A costs include grants management training for M&A staff, equipment and supplies for M&A staff to administer the grant award, travel costs for M&A staff to attend conferences or training related to the grant program, travel costs for the M&A staff to conduct subrecipient monitoring, contractual services to support the M&A staff with M&A activities, and auditing costs related to the grant award to the extent required or permitted by statute or 2 C.F.R.

Part 200. For additional program-specific M&A information, please refer to the relevant programspecific NOFO.

3.5. Procedures for Establishing Indirect Cost Rates
Indirect costs (per 2 C.F.R. § 200.1) are incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved. Indirect costs are allowable under all programs covered by this manual. The requirements and procedures for establishing indirect cost rates are the same for all the preparedness programs covered by this manual. The process for establishing the indirect cost rate (per 2 C.F.R. § 200.414) varies based on the type of entity and the amount of funding they receive:

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17  If the entity is a non-governmental entity (e.g., Institutions of Higher Education/hospital, nonprofit organization, etc.), and is a subrecipient, indirect cost rate procedures are outlined in 2 C.F.R. § 200.332(a)(4) and Appendices III, IV, IX to Part 200. These types of entities may either use the de minimis rate or negotiate a rate with the pass-through entity.  If the subrecipient is a state or local governmental entity, indirect cost rate procedures are established in Appendix VII to Part 200.
o Per Paragraph D.1.b. of Appendix VII, state or local governmental entities receiving grant funds must develop an indirect cost rate proposal.
‒ If the state or local entity receives more than $35 million in grant funding in a fiscal year, the proposal must be approved by the cognizant agency.
‒ If a state or local entity receives $35 million or less in grant funding in a fiscal year, they must develop an indirect cost rate proposal, but that indirect cost rate proposal does not need to be approved by the cognizant agency.
 If a state or local governmental entity wants to use the de minimis rate (instead of developing an indirect cost rate proposal), they can request a case-by-case exception from FEMA (per 2 C.F.R. § 200.102(b)).

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18 4. Administrative and National Policy Requirements
In addition to the requirements in this section and the applicable NOFO, FEMA may place specific terms and conditions on individual awards in accordance with 2 C.F.R. Part 200.

All grant recipients for FEMA grants and cooperative agreements are required to comply with the 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.

4.1. Accessibility Compliance
Preparedness grant program recipients using funds to build or alter buildings must comply with the applicable accessibility requirements under their local building codes, as well as the Section 504 Rehabilitation Act of 1973, 29 U.S.C. § 794, the Architectural Barriers Act of 1968 (ABA), and the Americans with Disabilities Act (ADA), 42 U.S.C. §§ 12101 et seq., to ensure individuals with disabilities have access to such buildings. State and local governments are required to provide qualified individuals with disabilities equal access to their programs, services, or activities, unless doing so would fundamentally alter the nature of their programs, services or activities or would impose an undue burden. Accessibility standards under the ABA and ADA are highly similar.

Additional information regarding compliance with the ABA is available at Chapter 1: Using the ABA Standards on access-board.gov.

4.2. Ensuring the Protection of Civil Rights
As the Nation works toward achieving the 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 308 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), Section 504 of the Rehabilitation Act of 1973, and Title VI of the Civil Rights Act of 1964, Age Discrimination Act, along with DHS and 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 as applicable.

Recipients must complete the DHS Civil Rights Evaluation Tool within 30 days of receiving the first award that fiscal year, not for every award. After initial submittal, an updated submission is due once every two years during which a recipient has an active award. Information about this requirement and a fuller list of the civil rights provisions that apply to recipients can be found in the DHS Standard Terms and Conditions. Additional information on civil rights provisions is available at the Civil Rights Resources for Recipients of DHS Financial Assistance page on DHS.gov and the Office of Equal Rights page on FEMA.gov.

Subrecipients are not required to complete or submit the DHS Civil Rights Evaluation tool. However, subrecipients have the same obligations as their primary recipients to comply with applicable civil rights requirements and should follow their primary recipient’s procedures regarding the submission of civil rights information.

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19 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.

In accordance with civil rights laws and regulations, recipients and subrecipients must ensure the consistent and systematic fair, just, and impartial treatment of all individuals, including individuals who belong to underserved communities that have been denied such treatment. A full list of Civil Rights Authorities at FEMA can be found at the External Civil Rights Division page on FEMA.gov.

Recipients and subrecipients (or representatives of such parties) who believe that discrimination has occurred in awarding or receiving FEMA financial assistance may file a complaint with the Office of Equal Rights (OER) at [email protected]. A complaint must be filed no later than 180 days from the date of the alleged discrimination unless the filing deadline is extended by the Director of the OER or their designee.

4.3. 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 otherwise 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 should 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.

Section 508 of the Rehabilitation Act of 1973, 29 U.S.C. § 794d, requires federal agencies to provide individuals with disabilities equal access to electronic information and data comparable to those who do not have disabilities. Although Section 508 does not impose requirements on federallyfunded recipients, we encourage recipients to use Section 508 best practices to ensure that persons with disabilities have equal access to web-based products/services. For more information, see the Accessibility of State and Local Government Websites to People with Disabilities page on ADA.gov.

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 interpretation services appropriate for the population being served, including American Sign Language or Puerto Rican 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.

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20  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 and information access. Examples of effective communication access for individuals with disabilities include providing auxiliary aids and services such as sign language interpreters and materials in Braille or alternate formats.

FEMA grant recipients can fund projects toward 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, the applicable chapter to this manual, and the terms and conditions of the award. For specific guidelines on funding a disability inclusive project, please refer to the relevant NOFO.

4.4. Language Access
As per FEMA Policy #256-23-001, Language Access, personnel shall take reasonable steps to provide individuals with limited English proficiency (LEP) with meaningful access to all programs or activities conducted both by FEMA and by entities receiving funding from FEMA, including grant recipients. This policy is based upon the principle that it is the responsibility of FEMA—not the LEP individual—to take reasonable steps to ensure communications are not impaired because of the limited English proficiency of the individual.

The following are examples that demonstrate the integration of the needs of LEP individuals in carrying out FEMA awards:
 Establish best practices in inclusive planning and preparedness that consider language access for LEP individuals.

4.5. Environmental Planning and Historic Preservation Compliance FEMA must 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 Environmental Planning and Historic Preservation (EHP) regulations, laws, and Executive Orders (EO), as applicable.

Recipients and subrecipients proposing projects that have the potential to impact the natural or built environment, including, but not limited to, the construction of communication towers; modification or renovation of existing buildings, structures, and facilities; new construction, including replacement or relocation 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 to determine whether the proposed project has the potential to impact environmental resources including, but not limited to, threatened or

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21 endangered species and historic properties; and identify mitigation measures and/or alternative courses of action that may lessen any impact to those resources. FEMA may recommend mitigation measures and/or alternative courses of action to lessen any impact to environmental resources and bring the project into compliance with EHP requirements.

In some cases, FEMA is also required to consult with other regulatory agencies and the public 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, EOs, regulations, and policies.

DHS and FEMA EHP policy is found in directives and instructions available on Environmental and Historic Preservation Guidance for FEMA Grant Applications page on FEMA.gov, which includes documents regarding EHP responsibilities and program requirements, including implementation of the National Environmental Policy Act and other EHP laws, regulations, and EOs. DHS and FEMA EHP policy is also found in the EHP Directive & Instruction.

An EHP Screening Form and supporting documentation for preparedness projects requiring EHP review should be submitted to [email protected] and your assigned Preparedness Officer.

Additionally, all recipients under this funding opportunity are required to comply with the FEMA EHP Policy Guidance, FEMA Policy #108-023-1, Grant Programs Directorate Environmental and Historic Preservation Policy Guidance.

4.5.1. CONSTRUCTION AND RENOVATION
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 6 months of the award and completed EHP review materials must be submitted no later than 12 months before the end of the POP. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

Refer to the program-specific NOFO for information on construction and renovation allowability and restrictions.

Construction and Floodplains
All FEMA actions, including grant-funded actions, must comply with National Flood Insurance Program (NFIP) criteria or any more restrictive federal, state, or local floodplain management standards or building codes (44 C.F.R. § 9.11(d)(6)).

All FEMA-funded non-critical actions in 1% annual chance floodplains (also known as 100-year floodplains) that involve new construction or substantial improvement of structures must be elevated, at a minimum, to the lower of:
 Two feet above the 1% annual chance flood elevation (also known as the base flood elevation), in accordance with the Federal Flood Risk Management Standard (FFRMS) FVA; or

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22  The 0.2% annual chance flood elevation. Where 0.2% annual chance flood elevations are not available, such actions must be elevated to at least two feet above the 1% annual chance flood elevation.

All FEMA-funded critical actions in 1% annual chance floodplains or 0.2% annual chance floodplains (also known as 500-year floodplains) that involve new construction or substantial improvement of structures must be elevated, at a minimum, to the higher of:
 Three feet above the 1% annual chance flood elevation (also consistent with the FVA); or  The 0.2% annual chance flood elevation. Where 0.2% annual chance flood elevations are not available, such actions must be elevated to at least three feet above the 1% annual chance flood elevation.

See EO 11988, Floodplain Management, as amended by EO 13690, Establishing a Federal Flood Risk Management Standard and a Process for Further Soliciting and Considering Stakeholder Input.

For additional information, see the Guidelines for Implementing EO 11988 and EO 13690.

4.5.2. ENVIRONMENTAL JUSTICE
EO 14096, Revitalizing our Nation's Commitment to Environmental Justice for All and EO 14008, Tackling the Climate Crisis at Home and Abroad rearticulate and strengthen the environmental justice framework articulated in 1994 in EO 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. Specifically, Section 1 of EO 14096states that: “To fulfill our Nation’s promises of justice, liberty, and equality, every person must have clean air to breathe; clean water to drink; safe and healthy foods to eat; and an environment that is healthy, sustainable, climate-resilient, and free from harmful pollution and chemical exposure.

Restoring and protecting a healthy environment—wherever people live, play, work, learn, grow, and worship—is a matter of justice and a fundamental duty that the Federal Government must uphold on behalf of all people.”
Some projects funded by FEMA’s grant programs could have environmental justice impacts. New construction (including communication towers), renovation, demolition, and relocation of buildings and other structures may have disproportionately high and adverse effects on minority and lowincome populations. FEMA acknowledges the important role that FEMA recipients and subrecipients play in advancing and achieving environmental justice by identifying low-income and minority populations within a proposed project’s affected area as early as possible, assessing a project's impact on existing environmental and human health burdens to account for cumulative effects, and taking steps to mitigate any harmful impacts.

FEMA will review and evaluate potential projects for environmental justice concerns. If FEMA determines that a proposed project would have a disproportionately high and adverse effect on minority or low-income populations, FEMA will consult with recipients and subrecipients to discuss the feasibility of revising the scope of work to avoid these adverse impacts, or otherwise applying mitigation measures to alleviate these effects. In addition, FEMA may work with other recipients and subrecipients to solicit public input on the proposed projects for a more informed decision-making process. To learn more about how FEMA environmental justice responsibilities might affect your project, go to the EO 12898: Environmental Justice page on FEMA.gov.

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23 4.5.3. COMMUNICATION TOWERS
For the purposes of the limitations on funding levels only, communication towers are not considered construction. When applying for construction funds, including communications towers, recipients must submit evidence of approved zoning ordinances, architectural plans, and any other locally required planning permits at the time of application.

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 an 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, tribal, or territorial 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 6 months of the award. Completed EHP review materials must be submitted no later than 12 months before the end of the POP. EHP policy guidance and the EHP Screening Form can both be found on FEMA.gov. EHP review materials should be sent to [email protected].

4.5.4. HAZARD RESISTANT BUILDING CODES
Hazard-resistant building codes are a foundational element of a more resilient nation, safeguarding communities and lives against natural disasters, with an estimated $11:1 return on investment. The adoption, enforcement and application of modern building codes mitigates community vulnerabilities, reduces disaster recovery costs, and strengthens nationwide capability. FEMA is working to promote and support building codes in all areas of its work in support of the multi-agency National Initiative to Advance Building Codes. In the interest of building a stronger, more resilient nation, FEMA encourages all grant recipients and subrecipients to meet current published editions of relevant consensus-based building codes, specifications and standards, and to exceed them where feasible.

4.6. Davis-Bacon Act Compliance
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 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 Davis-Bacon and Related Acts page on DOL.gov.

4.7. National Incident Management System Implementation National Incident Management System (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

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24 in the National Preparedness System. As recipients and subrecipients of federal preparedness (ND) grant awards, jurisdictions and organizations must achieve, or be actively working to achieve, all the NIMS Implementation Objectives. These objectives and implementation information can be found on the NIMS and NIMS Implementation and Training pages on FEMA.gov.

Emergency management and incident response activities require carefully managed resources (personnel, teams, facilities, equipment, and/or supplies) to meet incident needs. 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 the delivery of core capabilities. Additional information on resource management, NIMS resource typing definitions, job titles, and position qualifications is available at the NIMS Components – Guidance and Tools page on FEMA.gov. Please also see the relevant NOFOs for additional requirements regarding NIMS implementation for specific programs.

4.7.1. NIMS GUIDANCE FOR THE NATIONAL QUALIFICATION SYSTEM FEMA developed the NIMS Guideline for the National Qualification System (NQS) to describe national credentialing standards and to provide written guidance regarding the use of those standards. This guideline describes credentialing and typing processes and identifies tools that Federal Emergency Response Officials and emergency managers at all levels of government may use both routinely and to facilitate multijurisdictional coordinated responses. Starting in FY 2023, EMPG Program recipients are required to use EMPG Program funds to support NQS implementation efforts.

The NQS 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.

4.8. SAFECOM Guidance Compliance
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 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 several 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 on Emergency Communications Grants (SAFECOM Guidance).

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25 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., National Emergency Communications Plan (NECP), Statewide Communication 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 (IJ).

In addition, FEMA formally recognizes several statewide emergency communications governance bodies (e.g., Statewide Interoperability Coordinator (SWIC), Statewide Interoperability Governance Board (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, recipients 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 recipients 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 (RECCWG). 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.

All entities using preparedness grant funding to support emergency communications investments are required to comply with the 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 NECP. Compliance 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

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26 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 CISA to verify compliance with SAFECOM Guidance. FEMA will coordinate directly with the recipient on any compliance concerns and will provide TA as necessary to help ensure full compliance.

4.9. Resilient Communications Guidance
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 preparedness grant funding for communications investments are encouraged to take a Whole Community Approach and work with state emergency management agencies, SWICs, SIGBs, and appropriate stakeholders at the regional and SLTT levels to:
 Plan communication around the whole community to meet everyone’s needs.  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, recipients 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 Maintaining spares for designated critical communication systems; and

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27 o Working with commercial suppliers to remediate communication SPF.  All communications system owners are encouraged to address the following issues:
o Integrate communications needs into continuity planning efforts by incorporating Primary, Alternate, Contingency, and Emergency (PACE) methodology, and vulnerability 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; and
o Consider Electromagnetic Pulse (EMP) protective measures for communications systems and emergency backup power where practical.

CISA Emergency Communication Division enhances public safety interoperable communications at all levels of government and conducts extensive, nationwide outreach to support and promote the ability of emergency response providers and relevant government officials to communicate in the event of natural disasters, acts of terrorism, and other hazards. CISA provides plans, resources, and training to support operable and interoperable emergency communications for first responders.

4.10. 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, pushto-talk (PTT) devices;  Vehicle-mounted or otherwise field operated data devices, such as ruggedized laptops;

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28  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; and  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 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 the 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. Recipients 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 [email protected]. Please also refer to the most recent SAFECOM Guidance for additional guidance.

4.11. Department of Homeland Security/FEMA Communications Support Services
CISA and FEMA offer a variety of TA 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 support services is provided below. Grant recipients are encouraged to refer to the respective websites for additional information.

4.11.1. CYBERSECURITY AND INFRASTRUCTURE SECURITY AGENCY 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;

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29  Data operability and interoperability;
 Alerts and warnings;
 Broadband deployment;
 Cybersecurity education and awareness; and
 Communications Unit (COMU) planning and procedures.

Information on these services is available at the CISA Interoperable Communications Technical Assistance Program (ICTAP) Resources page on CISA.gov.

4.11.2. FEMA DISASTER EMERGENCY COMMUNICATIONS DIVISION SUPPORT FEMA Disaster Emergency Communications (DEC) deploys, installs, operates, maintains, and protects telecommunications, logistics, and operations assets in support of planned special events and in response to disasters, assisting citizens and first responders.

DEC provides DEC through six geographically dispersed Mobile Emergency Response Support (MERS) detachments and a pre-positioned fleet of Mobile Communications Office Vehicles (MCOV).

DEC also assists SLTT entities in mitigating their DEC risks and requirements to support life-saving efforts, protect property, and coordinate response and recovery operations. DEC can assist SLTT entities in mitigating their DEC risks and requirements to support life-saving efforts, protect property, and coordinate response and recovery operations. For more information about how DEC can provide stakeholder support in these areas, see the DEC page on FEMA.gov.

4.11.3. FEMA NATIONAL PREPAREDNESS DIRECTORATE SUPPORT
National Preparedness Directorate (NPD) provides training, exercises, and TA to SLTT stakeholders that support operational and emergency communications. Descriptions and resources specific to operational communication are available on FEMA.gov’s Core Capability Development Sheets page 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 National Training and Education Division (NTED) page on firstrespondertraining.gov.
 Example capability targets to complete a Threat and Hazard Identification and Risk Assessment (THIRA):
o Help in developing targets can be found at Unified Reporting Tool (URT)-Info page on FEMA’s Preparedness Toolkit or requested at [email protected].  Tools to validate capabilities through exercises:
o TA and support from subject-matter experts can be requested through the Exercises page on FEMA.gov.

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30 4.11.4. FEMA OFFICE OF NATIONAL CONTINUITY PROGRAMS SUPPORT The Office of National Continuity Program’s (ONCP) support services focus on holistic continuity planning, of which communications continuity is an important component. Currently, continuity communications training and TA is limited to the FEMA National Radio System (FNARS) and the Integrated Public Alerts & Warning System (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 ONCP support services should contact [email protected] or consult ONCP’s Continuity Resources Toolkit page on FEMA.gov.

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31 5. Post-Award Management and Implementation

5.1. 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 or the Signatory Authority (SA) 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.

5.2. Federal Financial Reporting Requirements

5.2.1. FEDERAL FINANCIAL REPORT
Recipients must report obligations and expenditures to FEMA on a quarterly basis through the Federal Financial Report (FFR) form, also known as Standard Form 425 (SF-425). Recipients may review the FFR at Post-Award Reporting Forms page on Grants.gov. Recipients must file the FFR electronically using FEMA GO. Note that recipients for awards covered in this manual made before FY 2024 must file the FFR using the Payment and Reporting Systems (PARS).

Financial Reporting Periods and Due Dates
An FFR must be submitted quarterly throughout the POP, including partial calendar quarters, as well as in periods where no grant award activity occurs. The final FFR is due within 120 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.

Table 3 shows the reporting periods and due dates for the FFR, except for the final FFR due at 120 days after the end of the POP for purposes of closeout.

Table 3: FFR Reporting Periods and Due Dates
FFR Reporting Period Report Due Date
Oct. 1–Dec. 31 Jan. 30
Jan. 1–March 31 April 30
April 1–June 30 July 30
July 1–Sept. 30 Oct. 30
Because of a system limitation, if at the end of the POP for awards made prior to FY 2023 a recipient still has funds to draw down, PARS requires an FFR be submitted within 30 days of the end of the POP 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

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32 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.

5.3. Program Performance Reporting Requirements

5.3.1. PERFORMANCE PROGRESS REPORTS
Recipients are responsible for providing performance reports to FEMA on a biannual (twice a year) or quarterly (four times a year) basis via FEMA GO. The Performance Progress Reports (PPR) should include the following:
 A brief narrative of overall project(s) status;
 A summary of project expenditures; and
 A description of any potential issues that may affect project completion.

For the EMPG Program only, recipients are responsible for providing performance reports to FEMA on a quarterly (four times a year) basis via FEMA GO. As explained in Section 12.10.1 “Standardized Programmatic Reporting for the EMPG Program,” the quarterly PPRs must use or be based on the approved EMPG Program Work Plan template provided in the EMPG Program NOFO.

Program Performance Reporting Periods and Due Dates
The biannual PPRs are due no later than 30 days after the end of the reporting period. Table 4 shows the reporting periods and due dates for biannual PPRs.

Table 4: Biannual PPR Reporting Periods and Due Dates
Reporting Period Report Due Date
Jan. 1–June 30 July 30
July 1–Dec. 31 Jan. 30
Program Performance Reporting Periods and Due Dates for the Emergency Management Performance Grant Program
The quarterly PPRs are due no later than 30 days after the end of the quarter. Table 5 shows the reporting periods and due dates for the quarterly PPRs for the EMPG Program only.

Table 5: Quarterly PPR Reporting Periods and Due Dates (EMPG Program) Reporting Period Report Due Date
Oct. 1 – Dec. 31 Jan. 30
Jan. 1 – March 31 April 30
April 1 – June 30 July 30

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33 Reporting Period Report Due Date
July 1 – Sept. 30 Oct. 30

5.4. Biannual Strategy Implementation Report
Applicable to the HSGP, THSGP, NSGP, and EMPG Program only.

In addition to the financial and performance progress reports, recipients are responsible for completing and submitting the Biannual Strategy Implementation Report (BSIR) through the FEMA GO system. For all HSGP, THSGP, NSGP, and EMPG Program awards made prior to FY 2024, the BSIR was completed in the Grants Reporting Tool.

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. The first BSIR for a given fiscal year award 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 traditional or “regular” BSIR must be submitted with full accounting of actual project information/expenditures before a Closeout BSIR can be created and submitted. Once FEMA approves the last “regular” BSIR, the Closeout BSIR can be created and submitted. Please contact your respective FEMA Preparedness Officer for questions regarding the BSIR.

5.5. 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 FEMA GO:

1. The final request for payment, if applicable;

2. The final FFR;

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, applicable program-specific chapters of 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.

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34 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 POP or other circumstances outlined in 2 C.F.R. § 200.334.

Recipients are responsible for refunding to FEMA any balances of unobligated cash that FEMA paid that are not authorized to be retained per 2 C.F.R. § 200.344(d).

5.6. 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 SAM.gov Responsibility/Qualification (R/Q) (previously known as the Federal Awardee Performance and Integrity Information System) the recipient’s material failure to comply with the terms and conditions of the award.

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.

5.7. 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;

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35  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.

5.8. 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 million for any period of time during the POP of an award under these funding opportunities.

Recipients that meet these criteria must maintain current information reported in SAM.gov R/Q about civil, criminal, or administrative proceedings described in paragraph 2 of Appendix XII at the reporting frequency described in paragraph 4 of Appendix XII.

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36 6. Additional Information

6.1. Monitoring and Oversight

6.1.1. 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 evaluate award progress and to provide any required TA. 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 toward 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 toward grant goals and proactively target and address issues that may threaten grant success during the POP.

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 TA, 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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37 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.

6.1.2. 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 TA 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 highrisk 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.).

HSGP (including SHSP, UASI, and OPSG), NSGP, TSGP, PSGP, and the EMPG Program are subject to HSA monitoring requirements. The IPR Program, IBSGP, and THSGP are not subject to HSA monitoring requirements.

6.1.3. 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 and cash on hand issues; and monitors spend down activities within the POP. The analysis reconciles

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38 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.

6.1.4. 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 6 defines the key differences and similarities.

Table 6: 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
improve recipient administrative
efficiencies;
 Identify and analyze relevant problems
that might prevent the program from
achieving its internal and external
objectives; and
 Provide TA.

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;
 Identify and analyze relevant problems
that might prevent the program from
achieving its internal and external
objectives; and
 Provide TA.

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39 6.1.5. PROGRAMMATIC MONITORING OVERVIEW AND APPROACH Programmatic monitoring involves oversight throughout the award lifecycle 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 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.

The programs subject to section 2022 of the HSA and three additional programs (THSGP, IPR Program, and IBSGP) are included in this programmatic monitoring approach—meaning that all programs included in this manual are part of this programmatic monitoring approach.

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 TA 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 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.

6.2. 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 (see the Preparedness Grants Case Studies page on FEMA.gov). By accepting the award, the recipient agrees to participate in a case study or evaluation if requested.

Recipients can also contact [email protected] if interested in volunteering to participate in a case study.

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40 6.3. 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 a recipient 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 SAM.gov R/Q the recipient’s material failure to comply with the award terms and conditions. See also the section on Actions to Address Noncompliance.

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.

6.4. Period of Performance 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 their 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(ies);

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;

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

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41 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 before 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 their FEMA Preparedness Officer or Program Manager as needed when preparing an extension request.

Recipients should refer to the corresponding chapter of this manual for program-specific details related to POP extensions.

6.5. 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 calendar 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 their immediate family or their partner has a close personal relationship, a business relationship, or a professional relationship, with an applicant, subapplicant, recipient, subrecipient, or FEMA employee.

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42 6.6. 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. For detailed guidance on the federal procurement standards, recipients and subrecipients should refer to various materials issued by FEMA’s Procurement Disaster Assistance Team (PDAT), such as the PDAT Field Manual and Contract Provisions Guide. Additional resources, including an upcoming trainings schedule, can be found on the PDAT’s Contracting with Federal Funds for Goods and Services Before, During and After Disasters page on FEMA.gov.

The subsections below highlight 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 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, local governments, and nonprofit organizations, 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. 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.

6.6.1. 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. More information on OMB’s revisions to the federal procurement standards can be found in the Purchasing Under a FEMA Award: OMB Revisions Fact Sheet.

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 nonstate 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)-(v). For small purchase procedures (2 C.F.R. § 200.320(a)(2)) under a FEMA award, the federal Simplified Acquisition Threshold (SAT) is currently

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43 $250,000, and a non-state entity may use a lower threshold but may not exceed the federal threshold. See 2 C.F.R. § 200.1 (citing the definition of SAT from 48 C.F.R. Part 2, Subpart 2.1).

See 2 C.F.R. § 200.216, § 200.471, and Appendix II as well as FEMA Policy #405-143-1, Prohibitions on Expending FEMA Award Funds for Covered Telecommunications Equipment or Services, the relevant program NOFO, and this manual regarding prohibitions on covered telecommunications equipment or services.

6.6.2. 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, 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 preaward costs, such as grant writer fees, as well as post-award costs, such as grant management fees.

Additionally, some of the situations considered to be restrictive of competition include, but are not limited to:
 Placing unreasonable requirements on firms 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;
 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.

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44 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, nonfederal 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.

Under 2 C.F.R. § 200.318(c)(2), if the recipient or subrecipient (other than states) has a parent, affiliate, or subsidiary organization that is not an SLTT 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. 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.

6.6.3. 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.

6.6.4. GENERAL SERVICES ADMINISTRATION SCHEDULES
States, tribes, 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 SLTT 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 the Programs for State and Local Governments and State and Local Governments pages on GSA.gov.

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).

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45 6.6.5. 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, 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 nonfederal 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 SLTT 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.

6.6.6. 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 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;
 Contract documents and amendments, including required contract provisions; and

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46  Other documents required by federal regulations applicable at the time a grant is awarded to a recipient.

Additional information on required procurement records can be found on pages 24–26 of the PDAT Field Manual.

6.7. Financial Assistance Programs for Infrastructure

6.7.1. BUILD AMERICA, BUY AMERICA ACT
Recipients and subrecipients must comply with the Text - H.R.3684 - 117th Congress (2021-2022):

Infrastructure Investment and Jobs Act | Congress.gov | Library of Congress, which was enacted as part of the Infrastructure Investment and Jobs Act §§ 70901-70927, Pub. L. No. 117-58 (2021); and the Executive Order on Ensuring the Future Is Made in All of America by All of America's Workers | The White House. See also 2 C.F.R. Part 184 and OMB Memorandum M-24-02, Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure.

None of the funds provided under HSGP, THSGP, NSGP, TSGP, IBSGP, PSGP, the IPR Program, and the EMPG Program may be used for a project for infrastructure unless the iron and steel, manufactured products, and construction materials used in that infrastructure are produced in the United States.

Additional information on the Buy America preference can be found in the program-specific NOFO.

6.8. Records Retention

6.8.1. 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).

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47  Where FEMA requires recipients to report program income after the POP 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, 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).

6.8.2. 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; and
 Canceled 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 canceled checks for verification. See, e.g., 2 C.F.R. § 200.318(i), § 200.334, § 200.337.

For any cost to be allowable, it must be adequately documented per 2 C.F.R. § 200.403(g). Nonfederal entities who fail to fully document all purchases may find their expenditures questioned and subsequently disallowed.

6.9. 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.

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48 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 partially 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 if the 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, the requirement to retain records, how the amount can be paid, and the consequences, including billing and collection, 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; and
 Failure to comply with the POP deadline.

6.10. Audits
FEMA grant recipients are subject to audit oversight from multiple entities including DHS OIG, the Government Accountability Office (GAO), the pass-through entity, or independent auditing firms for

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49 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.

The objectives of single audits are to:
 Determine whether financial statements conform to generally accepted accounting principles (GAAP);
 Determine whether the schedule of expenditures of federal awards (SEFA) is presented fairly;  Understand, assess, and test the adequacy of internal controls for compliance with major programs; and
 Determine whether 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 SEFA, 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 CAP 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(b) and Appendix X to 2 C.F.R. Part 200 as well as the reporting package described at 2 C.F.R. § 200.512(c).

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(f); 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).

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50 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.

6.11. Reporting Issues of Fraud, Waste, and Abuse
Recipients, subrecipients, SAAs, and any other applicable stakeholder at any time may report issues of fraud, waste, abuse, and mismanagement, or other criminal or noncriminal misconduct to the Office of Inspector General (OIG) Hotline. The toll-free numbers to call are 1 (800) 323-8603, and TTY 1 (844) 889-4357.

6.12. Payment Information
Payment requests are submitted through FEMA GO for awards obligated in FY 2024 and going forward. For awards obligated prior to FY 2024 in the ND Grants System, the payment request is submitted through PARS.

6.13. 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, but is not limited to:
 Individuals and families, including those with disabilities and others with access and functional needs;
 Businesses;
 Faith-based and community organizations;
 Nonprofit groups;
 Schools and academia;
 Media outlets; and
 All levels of government, including SLTT and federal partners.

The phrase “Whole Community” often appears in preparedness materials, as it is one of the guiding principles. It means two things:
 Involving people in the development of national preparedness documents; and  Ensuring their roles and responsibilities are reflected in the content of the materials.

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51 By engaging Whole Community stakeholders, preparedness grant 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.

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52 7. Resources

7.1. Department of Homeland Security/FEMA Provided Training and Education
FEMA offers tuition-free training and education programs and courses through several providers including the Center for Domestic Preparedness (CDP), the Emergency Management Institute (EMI), and NTED’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 (CTG) program.

7.2. Training Not Provided by the Department of Homeland Security/FEMA Trainings not provided by DHS/FEMA include courses that are either state-sponsored or federalsponsored (non-DHS/FEMA), coordinated and approved by the State Administrative Agency (SAA) or their designated Training Point of Contact (TPOC), and fall within the FEMA mission scope to prepare SLTT personnel to prevent, protect against, mitigate, and respond to acts of terrorism or catastrophic events. These trainings often pertain to the HSGP and THSGP.  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, and respond to 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 firstrespondertraining.gov.

7.3. Training Information Reporting System (“Web-Forms”) Web-Forms is an electronic data management system built to assist recipients 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 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 Web-Forms section of the FEMA National Preparedness Course Catalog to support recipients in their own tracking of training deliveries. Users need to request First Responder Training System (FRTS) Admin rights from NTED to access the Web-Forms.

7.4. FEMA’s National Preparedness Course Catalog
Recipients are also encouraged to utilize FEMA’s National Preparedness Course Catalog. Trainings include programs or courses developed for and delivered by institutions and organizations funded by

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53 FEMA. This includes CDP, EMI, and TPP, 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 and SLTT audiences. The catalog can be accessed at the NTED National Preparedness Course Catalog page on firstrespondertraining.gov.

Some exercise and training activities require EHP Review, including those 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 the Environmental & Historic Preservation Guidance for FEMA Grant Applications page on FEMA.gov.

7.5. Exercises
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 the HSEEP page on FEMA.gov.

7.6. Planning Assistance
FEMA’s NPD offers 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 decisionmakers 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 the NIMS Implementation and Training page on FEMA.gov

7.7. Training Information
States, territories, tribal entities, and high-risk urban areas do not need to request approval from FEMA for personnel to attend non-DHS/FEMA training if 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 Emergency Operations Plan (EOP). For additional information on review and approval requirements for training courses funded with preparedness grants, see FEMA Policy #207-22-0002, Prohibited or Controlled Equipment Under FEMA Awards.

FEMA will conduct periodic reviews of all SLTT 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 Analysis, Design, Development, Implementation,

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54 and Evaluation (ADDIE) model and tools that can facilitate the process, SAAs and TPOCs are encouraged to review the NTED Training Resource and Development Center.

7.8. Weblinks
 U.S. Department of Transportation (DOT) “RAISE” grants for National Infrastructure Investments may include funding to support roads, bridges, transit, rail, ports, or intermodal transportation.

See the RAISE Discretionary Grants page on Transportation.gov for more information.  Cybersecurity Assessment Evaluation and Standardization, Cyber Resilience Review, Cyber Infrastructure Survey, and other resources are available via CISA. See the Cyber Resource Hub for additional information.

7.9. 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 on the EMAP website.

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55 8. Homeland Security Grant Program and Tribal
Homeland Security Grant Program

8.1. Alignment to the National Preparedness System (Homeland Security Grant Program, Tribal Homeland Security Grant Program)
The Nation uses the National Preparedness System to build, sustain, and deliver core capabilities to achieve the Goal. HSGP and THSGP recipients use the National Preparedness System to support their efforts to build, sustain, and deliver these core capabilities, which are essential for each of the five mission areas outlined in the Goal. 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 the National Preparedness System page on FEMA.gov.

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, tribes, and territories provide annual data on their proficiency across 32 core capabilities through the THIRA, Stakeholder Preparedness Review (SPR), exercise and real world After-Action Reports (AAR), and other preparedness data. These data feed into the National Preparedness Report and form 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 these data to prioritize, synchronize, and guide programs and activities to build and sustain capabilities. FEMA requires recipients to prioritize grant funding to demonstrate how investments support identified national priorities (for HSGP only) and building capability, closing capability gaps, or sustaining capabilities as defined by Comprehensive Preparedness Guide (CPG) 201: THIRA/SPR Guide, Third Edition. 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 and THSGP provide financial support to SLTT jurisdictions to help them build, sustain, and deliver core capabilities identified in the Goal. Key focus areas and requirements of both the HSGP and THSGP are 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 and Tribal Nations, 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 EMAC.

The HSGP and THSGP support 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; and/or
 Respond quickly to save lives, protect property and the environment, and meet basic human needs in the aftermath of a catastrophic incident.

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56 8.2. Reporting on the Implementation of the National Preparedness System (Homeland Security Grant Program, Tribal Homeland Security Grant Program)

8.2.1. IDENTIFYING AND ASSESSING RISK AND ESTIMATING CAPABILITY

REQUIREMENTS
HSGP: By Dec. 31 each year, states, territories, and high-risk urban area HSGP recipients are required to complete an SPR that addresses all 32 core capabilities and is compliant with CPG 201, Third Edition. Additionally, every three years recipients are required to complete a THIRA. In 2020, jurisdictions began the requirement to respond to a series of planning-related questions as part of the THIRA/SPR.

THSGP: THSGP recipients are required to complete a THIRA every three years. Tribes with open THSGP awards must update their SPR inputs and Secondary Assessments (described in Section

8.2.4 “Planning to Deliver Capabilities” and Section 8.2.3 "National Incident Management System Implementation”) for activities completed in each respective calendar year (CY) throughout the POP, starting the CY after funding is awarded.

New THSGP recipients are required to complete the THIRA, SPR, and Secondary Assessments by Dec. 31 of the year following award issuance. New THSGP recipients are recipients that have not received THSGP funding in the past three years. The THIRA/SPR must address all 32 core capabilities and be compliant with the CPG 201, Third Edition. When applying for THSGP funding, tribes that were awarded THSGP funding during the previous two years are expected to prioritize and align grant funding investments in building and sustaining capabilities as identified in their THIRA and SPR.

For additional guidance on the THIRA/SPR, please refer to CPG 201, Third Edition.

Reporting
 States, tribes (with the exception of new THSGP recipients as noted above), and territories will submit their THIRA and SPR through the URT on the Preparedness Toolkit no later than Dec. 31 of the applicable year (every three years for THIRA and each year for SPR) for which the recipient has an open award.
o If a THSGP recipient has completed closeout for their THSGP grant award POP, they do not have to submit the THIRA/SPR as the requirement does not apply to closed awards.  High-risk urban areas that receive UASI funding will submit their SPR through the URT on Preparedness Toolkit no later than Dec. 31 for the years they have UASI open grants. If a UASI recipient has completed closeout for their UASI grant award POP, they do not have to submit a THIRA/SPR as the requirement is not applicable to closed grant awards. While UASIs that have completed closeout for the award POP are not required to complete a THIRA/SPR, it is encouraged.
 Calendar year 2022 was the start of the new 3-year THIRA/SPR cycle and baseline assessment year for existing recipients. Any new grant recipients for which the THIRA/SPR requirement applies will start their new 3-year THIRA/SPR cycle and baseline assessment year in the year during which they apply. States, territories, and high-risk urban areas should work collaboratively

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57 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 [email protected] if you have questions.

8.2.2. 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. Tribes receiving THSGP funds must prioritize and align grant funding investments in building and sustaining capabilities as identified in their THIRA and SPR. When applying for THSGP funding, tribes that were awarded THSGP funding during the previous two years are expected to prioritize and align grant funding investments in building and sustaining capabilities as identified in their THIRA and SPR.

Reporting
Within the BSIR and as part of programmatic monitoring, recipients must describe how expenditures support building capability, closing capability gaps, or sustaining capabilities identified in the THIRA and SPR. Recipients must, on a project-by-project basis, check one of the following:
 Building a capability with HSGP or THSGP funding; and  Sustaining a capability with HSGP or THSGP funding.

8.2.3. NATIONAL INCIDENT MANAGEMENT SYSTEM IMPLEMENTATION Recipients receiving HSGP or THSGP funding are required to implement NIMS. HSGP and THSGP 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.

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 or THSGP NOFO.

8.2.4. PLANNING TO DELIVER CAPABILITIES
HSGP and THSGP recipients shall develop and maintain, jurisdiction-wide, all threats and hazards EOPs consistent with CPG 101, Version 3.0 (CPG 101 v3), Developing and Maintaining Emergency Operations Plans (September 2021). For HSGP, recipients must update their EOPs at least once every two years. For THSGP, recipients must submit an EOP once during the POP.

Reporting
 Recipients report EOP compliance with CPG 101 v3 by completing the secondary CPG 101 v3 assessment portion of the URT as part of their THIRA/SPR submission.

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58 8.2.5. VALIDATING CAPABILITIES
All HSGP and THSGP recipients will develop and maintain a progressive exercise program consistent with HSEEP guidance in support of the National Exercise Program (NEP). THSGP recipients are required to develop and maintain this program regardless of whether the tribe planned to use THSGP funding for exercises. 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 realworld 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 Integrated Preparedness Planning Workshops (IPPWs) can be found on the HSEEP page on FEMA.gov and the Preparedness Toolkit.

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 on the Exercises page on FEMA.gov, or reach out to the NEP directly at [email protected].

Reporting
 Recipients must have a current multi-year IPP that identifies preparedness priorities and activities. The current multi-year IPP must be submitted to [email protected] before Jan. 31 of each year:
o Recipients are encouraged to enter their exercise information into the Preparedness Toolkit.  Recipients must submit AARs/Improvement Plans (IPs) to [email protected] and indicate which fiscal year’s funds were used (if applicable).
 Submission of AAR/IPs must take place within 90 days following 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 urban area 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 CY 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 [email protected]; and

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59 o Recipients can access a sample AAR/IP template on the Improving Planning Templates page on the Preparedness Toolkit.

8.3. Funding Guidelines (Homeland Security Grant Program, Tribal Homeland Security Grant Program)
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 support four of the five mission areas—Prevention, Protection, Mitigation, and Response—and associated core capabilities within the Goal. While Recovery is part of the Goal, it is not explicitly part of the HSGP and THSGP. 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 building capability, closing capability gaps, and/or sustaining capabilities, as defined by CPG 201, Third Edition. 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.

8.4. Allowable Costs (Homeland Security Grant Program)

8.4.1. MULTIPLE PURPOSE OR DUAL-USE OF FUNDS (STATE HOMELAND SECURITY

PROGRAM AND URBAN AREA SECURITY INITIATIVE)
For both SHSP and 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 HSA (6 U.S.C. § 609(c)).

8.4.2. ORGANIZATIONAL ACTIVITIES
Personnel Costs
In addition to the personnel cost allowability detailed in the HSGP NOFO, HSGP (SHSP, UASI) 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. HSGP (SHSP, UASI, OPSG) funds will be used to supplement existing funds and will NOT replace (supplant) funds that have been appropriated and/or budgeted 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.

8.4.3. 28 C.F.R. PART 23 GUIDANCE
FEMA requires that any IT system funded or supported by HSGP funds comply with 28 C.F.R. Part 23, Criminal Intelligence Systems Operating Policies if this regulation is determined to be applicable.

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60 8.5. Fusion Centers (Homeland Security Grant Program) 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 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 High-Intensity Drug Trafficking Areas (HIDTA), Regional Information Sharing Systems (RISS) Centers, Joint Terrorism Task Forces (JTTF), major city/county intelligence units, and real-time crime analysis centers, among others.

National Network participation in the Nationwide Suspicious Activity Reporting Initiative (NSI) enables fusion centers to identify, receive and analyze Suspicious Activity Reports (SAR) 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 (AMSC), 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 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 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:
 Addressing 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 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,

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61 ICE, United States Secret Service (USSS), 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, SAR; 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 threats, attacks, or incidents, as well as other planned events such as National Security Special Events (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; and
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 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

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62 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 Computer Assisted/Aided Dispatch (CAD) and Records Management System (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, including 28 C.F.R. Part 23 requirements, are listed at the Fusion Center Performance Program’s HSGP page on DHS.gov and in the 28 C.F.R. Part 23 Online Training.
 FEMA approved analyst courses that meet the grant requirement are listed at FEMA Approved Intelligence Analyst Training Courses page on DHS.gov.

Through the 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, AMSC, 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.

8.5.1. FUSION CENTER PERFORMANCE MEASURES
Table 7: Fusion Center Performance Measures
Reference
Number*
Performance Measures
YEAR.1 Percentage of federal Information Intelligence Reports (IIRs) originating from fusion center information that address a specific Intelligence Community need

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63 Reference
Number*
Performance Measures
YEAR.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; corroborated existing information; addressed a critical intelligence gap; or helped to define an issue or target) YEAR.3 Number of SARs vetted and submitted by fusion centers that result in the initiation or enhancement of an investigation by the FBI
YEAR.4 Number of SAR vetted and submitted by fusion centers that involve an individual on the Watchlist
YEAR.5 Percentage of Requests for Information (RFIs) from the Terrorist Screening Center (TSC) for which fusion centers provided information for a TSC case file YEAR.6 Percentage of I&A Watchlist nominations that were initiated or updated existing case files based on information provided by fusion centers
YEAR.7 Number of distributable analytic products co-authored by one or more fusion centers and/or federal agencies
YEAR.8 Percentage of fusion center distributable analytic products that address Homeland Security topics
YEAR.9 Percentage of fusion center distributable analytic products that address state/local customer information needs
YEAR.10 Percentage of key customers reporting that fusion center products are relevant YEAR.11 Percentage of key customers reporting that fusion center services are relevant YEAR.12 Percentage of key customers reporting that fusion center products are timely for mission needs
YEAR.13 Percentage of key customers reporting that fusion center services are timely for mission needs
YEAR.14 Percentage of key customers reporting that fusion center products influenced their decision making related to threat response activities within their AOR YEAR.15 Percentage of key customers reporting that fusion center services influenced their decision making related to threat response activities within their AOR YEAR.16 Percentage of key customers reporting that fusion center products resulted in increased situational awareness of threats within their AOR YEAR.17 Percentage of key customers reporting that fusion center services resulted in increased situational awareness of threats within their AOR YEAR.18 Number of tips and leads vetted by the fusion center YEAR.19 Number of tips and leads vetted by the fusion center that were provided to other F/SLTT agencies for follow up action

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64 Reference
Number*
Performance Measures
YEAR.20 Number of responses to RFIs from all sources
YEAR.21 Number of situational awareness products developed and disseminated by fusion centers
YEAR.22 Number of case support and/or tactical products developed and disseminated by fusion centers
YEAR.23 Percentage of federally designated special events in which fusion centers played a direct role
YEAR.24 Percentage of federally declared disasters in which fusion centers played a direct role
YEAR.25 Number of public safety incidents in which fusion centers played a direct role *“YEAR” should be changed for the current fiscal year, e.g., 2024, 2025, etc. Any updates to Performance Measures will be noted in the HSGP NOFO.

8.6. Investment Modifications – Changes in Scope or Objective (Tribal Homeland Security Grant Program)
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-bycase basis provided the change does not negatively impact the competitive process used to recommend THSGP awards.

Requests to change the scope or objective of the grant-funded activity after the award is made must be submitted via FEMA GO 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 POP.

Recipients may not proceed with implementing any scope or objective changes until they receive prior written approval from FEMA through FEMA GO.

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65 8.7. Continuity Capability (Homeland Security Grant Program, Tribal Homeland Security Grant Program)
Continuity should be integrated into each core capability and the coordinating structures that provide them. Continuity capabilities 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 assessment of continuity capabilities among executive departments and agencies. To support this role, FEMA develops and promulgates directives, policy, and guidance for federal and SLTT governments, nongovernmental organizations, and private sector critical infrastructure owners and operators. Federal Continuity Directives (FCD) establish continuity program and planning requirements for executive departments and agencies, while FEMA's Continuity Guidance Circular (CGC) tailors’ continuity guidance to SLTT and other non-Federal audiences. 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.

The FCDs, CGC, and the Continuity Resource Toolkit provide guidance and resources for organizations. For additional information on continuity programs, guidance, and directives, see the Continuity Resources and Technical Assistance page on FEMA.gov.

8.8. Senior Advisory Committee (Homeland Security Grant Program) To support the Whole Community Approach (see Section 1.6 “Strengthening Governance Integration” and Section 6.13 “Whole Community Preparedness”), the SAA must establish or reestablish a unified Senior Advisory Committee (SAC). The SAC builds upon previously established advisory bodies under SHSP, UASI, TSGP, and PSGP. Examples of advisory bodies that should be included on a SAC include Urban Area Working Groups (UAWGs), SIGB, AMSCs, Regional Transportation Security Working Groups (RTSWG), 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.

8.8.1. SENIOR ADVISORY COMMITTEE 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 high-risk 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 and tribal government officials;

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66  Tribal organizations and associations;
 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; and  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 (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 Points of Contact (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, and response activities within the state, and include representation from the stakeholder groups and disciplines identified above.

The above membership requirement does not prohibit states, high-risk 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 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 high-risk 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 other access and

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67 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 FEMA GO. SAAs will use the URT to verify compliance with SAC charter requirements.

8.8.2. SENIOR ADVISORY COMMITTEE RESPONSIBILITIES
The responsibilities of a SAC include:
 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;
 Managing all available preparedness funding sources to ensure their effective use and to minimize duplication of effort;
 Ensuring investments support building capability, closing capability gaps, or sustaining capabilities identified in the THIRA/SPR;
 Assisting in preparation and revision of the state, regional, or local homeland security plan or the THIRA, as the case may be; and
 Assisting in determining effective funding priorities for SHSP grants.

8.8.3. SENIOR ADVISORY COMMITTEE CHARTER
The governance of SHSP and UASI 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 states 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

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68 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.

8.9. Urban Area Working Group (Homeland Security Grant Program) To support the Whole Community Approach (see Section 1.6 “Strengthening Governance Integration” and Section 6.13 “Whole Community Preparedness”), high-risk 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.

UASI implementation and governance must include regional partners and should have balanced representation among entities with operational responsibilities for prevention, protection, mitigation, and response activities within the region. In some instances, high-risk urban area boundaries cross state borders. States and territories must ensure that the identified high-risk urban areas take an inclusive regional approach to the development and implementation of the UASI 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.

8.9.1. URBAN AREA WORKING GROUP COMPOSITION AND SCOPE
Pursuant to section 2003(b) of the HSA (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 (MSA), as defined by 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.

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 and tribal government officials;

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69  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; and
 State and regional interoperable communications coordinators and state and major urban area fusion centers, as appropriate.

In addition to representatives from the local jurisdictions and tribes within the state, territory, or highrisk 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 other 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 FEMA GO. 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.

8.9.2. URBAN AREA WORKING GROUP RESPONSIBILITIES
UAWGs must ensure that applications for funding under the UASI support building capability, 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. 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 highrisk urban area.

8.9.3. URBAN AREA WORKING GROUP 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 M&A responsibilities, and funding allocation methodologies are formalized in a working group charter, or another form of standard operating procedure related to the UASI 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 FEMA GO and must be on

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70 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.

8.10. Supplemental State Homeland Security Program and Urban Area Security Initiative Guidance (Homeland Security Grant Program)

8.10.1. 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 high-risk 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 CISA’s Infrastructure Security Division. However, coordination is not limited to grant funding. It also includes leveraging assessments such as Transportation Security Administration’s (TSA) Baseline Assessment for Security Enhancement (BASE), reporting from the Intelligence Community, risk 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).

8.10.2. COLLABORATION WITH HEALTH CARE COALITIONS
Health Care Coalitions (HCC) 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, and other forthcoming versions.

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71 8.10.3. 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.

8.10.4. COLLABORATION WITH TRIBAL NATIONS
Tribal governments and their members are an essential part of our nation’s emergency management team. Effective relationships with tribes are necessary to fulfill FEMA’s mission of working together to improve our nation’s preparedness and response posture. As such, 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.

8.11. Operation Stonegarden Operational Guidance (Homeland Security Grant Program)
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 Integrated Planning Team (IPT) with representation from all participating law enforcement agencies and 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 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; and/or

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, Analysis, and Distribution includes both technology and manpower related to the gathering and analysis of intelligence with a nexus to border security.

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72 The terms of an OPSG award do not extend to an SLTT partner any authority to enforce additional laws, statutes, 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 Immigration and Nationality Act (INA)). Participation in the grant does not grant participants the power to operate outside of their own jurisdictional boundaries.

8.11.1. CONCEPT OF OPERATIONS AND CAMPAIGN PLANNING
Post-Allocation Announcement/Pre-Award
The overarching operational cycle involves three stages: 1) application (described in the HSGP NOFO); 2) concept of operations to formulate a Campaign Plan, and 3) one or more tactical operational periods, which are all developed by the IPT. All Operations Orders: Concept of Operations (CONOPS), Operation Orders or Campaign Plans, and Fragmentary Orders (FRAGOs) shall be submitted through the CBP Stonegarden Data Management System.

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: 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 Personal Reimbursement for Intelligence Cooperation and Enhancement of Homeland Security Act (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.

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73 If 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 Homeland Security Information Network (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
If 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 SLTT 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; however, 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 the operations order in the corresponding folder in the CBP Stonegarden Data Management System.

8.11.2. REPORTING PROCEDURES
Participation in OPSG requires accurate, consistent, and timely reporting of how funds are used, and how the SLTT 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 SLTT 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 current fiscal year HSGP NOFO on FEMA’s preparedness grants page, is 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

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74 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.

8.11.3. OPERATION STONEGARDEN COORDINATION
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 of international borders including travel corridors in states bordering Mexico and Canada along with states and territories with international water borders. OPSG also further enhances the sharing of threat information and intelligence between federal and SLTT 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, SAR, 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 INA).

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;