...summaries should mirror the line items shown on the PW. The major categories are Force Account Labor; Equipment Usage; Force Account Materials and Purchases; and Procurements and Contracts.
More than one cost summary may be required, especially for larger PWs. Sample no. 1, page 5, exhib- its how a lead cost summary may be set up. Additional supporting summary schedules should then be prepared for each line item.
These supporting cost summaries should provide sufficient detail to enable the auditor to trace the costs, listed in the summaries, back to the source document.
The cost summaries should be up- dated, at least monthly, and includ- ed in the PW file. Regular updates and reviews of cost summaries assist the applicant to better man- age the funding process and decide whether a supplemental PW needs to be requested.
Accurate and complete documen- tation helps accelerate the Public Assistance process, maximize reimbursements, and minimize de- obligations during the final inspec- tion and audit processes.
All eligible costs must be sup- ported by source documentation that clearly identifies costs related to the disaster.
Source documentation supporting eligible costs can be the product of applicant systems and procedures that are already in place. If current records do not provide the neces- sary amount of detail, supplemen- tal documentation will be required.
The FEMA Project Officers (POs) who write the original PW’s typically only perform a random review of source documentation. However, during the final audit, a state or FEMA auditor performs a more detailed review. Where adequate source documentation is not available, applicants may be re- quired to repay any FEMA funding related to that cost.
Clearly it is more efficient (and likely to produce more accurate re- sults) if adequate source documen- tation is required and maintained by the applicant at the time that the costs are incurred.
As a rule of thumb, all source documentation intended to sup- port eligible disaster-related costs should include the details of to whom, where, what, when and why the cost was incurred. A few basic checklists for the most fre- quently used types of source docu- mentation are displayed in Sample no. 2, page 6.
Applicants should ensure that systems are in place to capture all the details required by FEMA and the state at the time the documenta- tion is created and approved . Only adequately detailed supporting documentation should be included in summary sheets used for track- ing disaster-related costs.
If, for example, a contractor ne- glects to include specific details on an invoice, such as time, site and a detailed description of duties performed, etc., authorization for payment of that invoice should be withheld until the requisite details have been included.
In recent years, FEMA has taken an active role in monitoring the performance of contractors and vendors. For example, FEMA has sent out “Debris Police” to ensure that contractors and/or depart- ments are not overcharging for debris removal. In effect, FEMA charges an applicant to take the same precautions they would take if it were their money being spent (e.g. not paying an invoice until it is reconciled and signed off on by a project manager).
When working with contracts, ap- plicants should keep the following in mind: