Governor’s Hurricane Conference 2014 WS 106: Public Assistance Hot Topics Bryan Koon, Director, FDEM Steve Hyatt, State Public Assistance Officer, FDEM May 15, 2014 THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Overview - Department of Homeland Security (DHS) Office of Inspector General (OIG) - Ongoing and increasing audits - Common issues - Solutions and recommendations - Updates to FEMA PA Program - Existing, likely to happen, and ideas! - Sandy Recovery Improvement Act and Alternate Procedures - Debris Pilot Program - Permanent Work Pilot Program - Anything else! THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
DHS OIG Audits DHS OIG Audits for FEMA Public Assistance -Bryan Koon- THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Rumor Control! -Existing, New Changes -Likely to Happen -Ideas THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Existing/New Changes Project Thresholds Effective February 26, 2014… • Small Project Threshold = $120,000 (Used to be $68,500) • Minimum Project Threshold = $3,000 (Used to be $1,000) Disaster Cost Shares (75% to 90%) Effective January 1, 2013… • $1.39 State Per Capita to $133 State Per Capita • For 90% cost share disaster = $2,500,574,230 • Wilma = $1,462,232,852 FEMA PA Field Operations Pocket Guide Effective September, 2012… • National protocol to ensure consistency in PA Program • Strong emphasis on site sheets and combination of sites THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Existing/New Changes FEMA Contracting/Procurement Attorney Team Nationally available 7 person team. • Reviews contracts, provides training, assists in eligibility • Procurement one of the most common audit issue Public Assistance Appeals Branch Full-time, dedicated appeal staff. • Reduce appeal backlog and improving timeliness • Issuing PA appeal-related guidance • Establishing clear, consistent, and transparent standards that apply to all levels of the PA appeal process THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Likely/Going to Happen Changes to the Declaration Criteria • May 2012 (OIG-12-79) and September 2012 (GAO-12-838) Per capita indicator is the primary determining factor Per capita indicator is artificially low Per capita indicator does not reflect fiscal capability FEMA considering 4 Options (But there can be more)! THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Option 1 = Adjust to reflect economic changes. • Adjust for inflation from 1999 Regulation Use National Per Capita Income (PCI) - $43,735 (2012) • $1.39 to $4.37 ($26.1 million to $82.1 million) Use Consumer Price Index (CPI) Inflation • $1.39 to $2.14 ($26.1 million to $40.2 million) Option 2 = Adjust to better reflect state fiscal capability. • Create state-specific per capita indicators • Total Taxable Resources (TTR): TTR index application to national PCI TTR Index applied to CPI inflation adjustment THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Option 3 = Develop a model. • According to 44 CFR 206.48 (a)… Not just per capita indicators • Localized impacts even if state per capita not reached • Insurance coverage • Hazard mitigation • Recent multiple disasters • Other federal assistance programs Quantitative (consistent) vs. Qualitative (flexible) Option 4 = Annual Impact Threshold • Explore several aspects of disaster preparedness • Potential concepts: State Preparedness Report (SPR) Threat and Hazard Identification and Risk Assessment (THIRA) Deductible concept THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Likely/Going to Happen Consolidation of all PA Guidance and Revamps “The Book” THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Updates to FEMA PA Program Ideas Central Project Worksheet Processing Centers Handles incoming project worksheets post JFO operations • Multiple processing centers handling multiple FEMA Regions • Faster processing/obligation the priority DHS OIG Auditors on Project Worksheet Reviews Added to the PW “Review Queues” in EMMIE • DHS OIG auditors see projects up-front for issues • Approval of projects to avoid audit issues later? THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Sandy Recovery Improvement Act Sandy Recovery Improvement Act (Alternative Procedures) THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Sandy Recovery Improvement Act On January 29, 2013, President Obama signed into law the Sandy Recovery Improvement Act of 2013 which adds Section 428 to the Stafford Act for alternative procedures which reduce the federal costs of disasters, increases the flexibility of the administration of funding, expedites funding, and provides financial incentives and disincentives for timely completion of projects. Subgrantees voluntarily enter into the program, which includes alternative procedures for both debris removal and permanent work projects. The Debris Removal Pilot includes: Accelerated Debris Removal Incentive (Sliding Scale) Retaining Recycling Revenues Reimbursement for Straight Time Force Account Labor One-Time Incentive for Debris Management Plan The Permanent Work Pilot includes: Grants Based on Fixed Estimates (REQUIRED) Acceptance of Subgrantee Cost Estimates Referral of Cost Estimates to Expert Panel Consolidated Subgrants Elimination of Alternate Project Penalty Use of Excess Funds THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Debris Removal Pilot THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Sandy Recovery Improvement Act Accelerated Debris Removal Incentive (Sliding Scale) Applicants may apply for an increased Federal cost share for the timely removal of debris. Debris Removal Completed (Days from Start of Federal Cost Share Incident Period) 0-30 days 85% 31-90 days 80% 91-180 days 75% Separate subgrants (project worksheets) will be developed per each debris removal cycle. FEMA may grant a time extension (if requested) for a time period beyond 180 days. Once you start, there is no going back! This is also for all debris removal operations for the subgrantee! THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Sandy Recovery Improvement Act Retaining Recycling Revenues Currently, any revenue stream from recycling will reduce the amount of the awarded grant. Under the this procedure, subgrantees may retain revenues received through recycling eligible disaster debris. However, the cost of establishing and managing the recycling program or process and additional sorting and processing of the debris for recycling purposes cannot be claimed as a direct project cost. The revenues from recycling must be used for one of the following approved purposes: Developing disaster debris management plans Updating or revising existing plans Enhancing subgrantee landfill-management sites Installing mechanisms such as debris trash racks, K-Rail debris guards and silt fencing Buying equipment such as street sweepers, shredders, backhoes, balers and sorting conveyors Purchasing debris recycling equipment Purchasing software and hardware products to facilitate quantifying disaster debris Buying onboard weight measurement systems for debris-collection trucks Purchasing software systems for debris load management to assist in tracking trucks, drivers and routes If revenues are not used for an authorized purpose, grant funding will be reduced by the amount of that revenue as program income. THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Sandy Recovery Improvement Act Reimbursement for Straight Time Force Account Labor When subgrantees use their own labor forces to perform all or part of debris removal operations, FEMA will reimburse, at the appropriate cost share level, the base and overtime wages for existing employees and hiring of additional staff. One-Time Incentive for Debris Management Plan When a subgrantee has a FEMA-reviewed debris management plan before the date of the disaster declaration incident period, FEMA will provide a one-time incentive of a 2% cost share adjustment applied to debris removal work completed within 90 days. Plans should include all of the following elements: Debris management overview Health and safety requirements Events and assumptions Public Information Debris collection and removal plan Use of force account labor Debris removal on private property Monitoring of debris operations Use and procurement of contracted services Environmental considerations and other regulatory requirements Debris disposal locations and debris management sites THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
Permanent Work Pilot THE FLORIDA DIVISION OF EMERGENCY MANAGEMENT
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