...basic: to check the accuracy of the applicant’s scope of work and associated costs, and also to verify that the proposed project is eligible for FEMA funds.
According to the FEMA Public Assistance Guide , only 20 percent of an applicant’s small projects are assessed during validation. “However, if significant discrepancies are found in the sample, a second sample of 20 percent is assessed. If discrepancies are again found in that sample, the applicant will be provided with technical assistance for review of all small projects.”
Additional validation is requried for projects submitted more than 30 days after the kickoff meeting. An applicant has 60 days from kickoff to submit all small PWs, but the PW validation requirement increases from 20 percent to 100 percent. This should be considered an incentive to applicants to submit small project PWs as early as possible.
The applicant should find many advantages to writing its own projects, and validation should not discourage an applicant. If documents are clear, consistent and accurate, the scrutiny applied by the state/FEMAmay be minimized.
Funding for large projects is initially based on cost estimates, but the funds ultimately paid to the applicant are based on the actual documented costs as the project work progresses. “Funds generally are made available to the applicant on a progress payment basis as work is completed,” says the FEMA Public Assistance Guide . This funding system is necessary because of the complexity and expense of most large projects.
The state parcels out FEMA funds to its applicants as the work progresses, and when all project work is completed, the state will submit to FEMA the documentation to account for the actual expenses the applicant incurred for final funding adjustments.
There are four basic payment methods for large project PWs:
In this circumstance, cash is advanced to cover the applicant’s estimated disbursement needs for an initial period generally geared towards the applicant’s disbursement cycle. After the work has commenced, reimbursements will be made based on actual expenses.
When FEMA finishes writing or reviewing a PW, they should present a copy to the applicant for review and comment. If the applicant agrees with the findings, he/she will sign the original and retain a copy for his/her files. If they do not agree, an attempt should be made to negotiate a suitable outcome to avoid the already over-burdened appeal process.
When reviewing a PW, applicants should request a copy of the full document. It would be very difficult for project managers to follow an approved scope of work without the entire set of FEMA calculations and narrative.
Applicants should keep in mind that the PW will be evaluated for eligibility and funding and, eventually, audited.
If an applicant and FEMA do not agree on an issue such as scope of work, cost or eligibility, they may enter into the appeals process.