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• If a contractor is in violation of a contract, the applicant should address the issue formally and then document it in the appropriate PW file.
• If a contractor performs any services outside of the FEMA- approved scope of work, those costs must be segregated and invoiced separately.
• When possible, before letting a large contract (where FEMA funds will be used), applicants should gain approval from the state.
• When dealing with FEMA disaster-related contracts, contractors must provide a greater level of detail on their invoices than normal.

Tip #7: Check Parameters of Official Accounting Systems

In addition to creating and main- taining a clear audit trail, adequate source documentation, and an acceptable filing system, all eligible costs must be reconcilable to the official accounting records of the applicant. The approach taken to document and summarize eligible costs will determine the amount of reconciliation required.

Some institutions’ accounting systems may not be capable of tracking costs at sufficient levels of detail to support a disaster recovery program. In that case, all or part of the disaster program costs must be tracked outside the official accounting system—but must remain reconcilable to it.

Other institutions’ accounting systems may effectively support a disaster recovery program. This type of system can provide cost ac- counting that can track by disaster site and segregate eligible and in- eligible costs. The former approach would require a significant amount of reconciliation, while the latter may require none.

Tip #8: Track Deadlines and Extensions

Title 44 of the Code of Federal Reg- ulations (44 CFR) imposes dead- lines for many disaster response and recovery activities undertaken by FEMA grant applicants. Dead- lines are delineated for submitting the Notice of Interest, for identify- ing damage, for completing work, and for filing appeals, to list a few.

Please note that certain deadlines can be further extended, if justified by the disaster. A special request from the state (acting on the applicant’s behalf) to FEMAmust be submitted, and, of course, the notice of approval properly saved to the appropriate file.

Summary

The FEMA grant process requires sound management from begin- ning to end.

Plan and prepare for the closing of your projects, and never assume that you have too much informa- tion. If the auditors open detailed, well-organized project files, they will be able to answer their ques- tions with minimal effort and in- quiries—and then move on to the next file and, eventually, the next applicant.

Staying ahead of documentation requirements will keep your FEMA grant intact, and assist with the smooth completion and closeout of your project. Remember, nobody understands what was done, why it was done and how it was done better than the applicant. Success- ful closeouts and audits hinge on your ability to articulate these items, and nothing speaks louder than clear, concise documentation.

Jeff Shaw Adjusters International

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Sheila E. Salvatore

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DISASTER RECOVERY TODAY is published as a public service by Adjusters International, Inc. It is provided for general information and is not intended to replace professional insurance, legal and/or financial advice for specific cases.

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