While some of us are busy putting the final touches on our 2018 AFG Grant applications, others are in the process of accepting their 2017 AFG award and purchasing their requested equipment.
Here’s one important thing to keep in mind that departments tend to forget. Among all the compliance issues for those awards are a number of requirements that could cause you to lose your grant, be required to pay back your grant or have problems applying for future AFG grants.
1. Initiate reporting to NFIRS
NFIRS reporting is not a requirement to apply for AFG funding; however, fire departments that receive funding under this program must agree to provide information to the NFIRS for the period covered by the assistance.
If a recipient does not currently participate in the incident reporting system and does not have the capacity to report at the time of the award, that recipient must agree to provide information to the system for a 12-month period commencing as soon as possible after they develop the capacity to report.
Capacity to report to the NFIRS must be established prior to the termination of the one-year grant performance period. The recipient may be asked by FEMA to provide proof of compliance in reporting to NFIRS.
2. Start NIMS compliance
AFG applicants are not required to be in compliance with NIMS to apply for AFG funding or to receive an AFG award. Any applicant who received a fiscal year 2017 AFG award must achieve the level of NIMS compliance required by the Authority Having Jurisdiction over the applicant’s emergency service operations (e.g., a local government), prior to the end of the grant’s period of performance.
3. Fulfill cost share or match requirement
Grant recipients must share in the costs of the projects funded under the AFG grant program as required by the Notice of Funding Opportunity and in accordance with applicable federal regulations at 2 CFR Part 200, but they are not required to have the cost-share at the time of application nor at the time of award. However, before a grant is awarded, FEMA will contact potential awardees to determine whether the grant recipient has the funding in hand or if the grant recipient has a viable plan to obtain the funding necessary to fulfill the cost-sharing requirement.
4. Comply with SAM and DUNS registration requirements
DHS may not make a federal award to an applicant until the applicant has complied with all applicable DUNS and SAM requirements. If an applicant has not fully complied with the requirements by the time DHS is ready to make a federal award, DHS may determine that the applicant is not qualified to receive a federal award and use that determination as a basis for making a federal award to another applicant.
The SAM registration process must be completed by the applicant. It is imperative that the information provided by the applicant is correct and current. Please ensure that your organization’s name, address, DUNS number and Employer Identification Number are up to date in SAM and that the DUNS number used in SAM is the same one used to apply for all other FEMA awards.
The organization’s name on the SF 1199A Direct Deposit Form must be entered as it appears in SAM. Payment under any FEMA award is contingent on the recipient having a current SAM registration
5. Complete the EHP review process
FEMA is required to consider the effects of its actions on the environment and historic properties to ensure that all activities and programs funded by the agency, including grant-funded projects, comply with Federal EHP regulations, laws and Executive Orders as applicable.
Recipients proposing projects that have the potential to impact the environment, including – but not limited to – modification or renovation of existing buildings, structures and facilities must participate in the FEMA EHP review process. This includes fixed generators, fire alarm systems, air compressors, washers and dryers, fixed exhaust removal systems and sprinkler systems.
The EHP review process involves submitting a screening form that includes a detailed project description that explains the goals and objectives of the proposed project along with supporting documentation, so that FEMA may determine whether the proposed project has the potential to impact environmental resources and/or historic properties.
In some cases, FEMA may also be required to consult with other regulatory agencies and the public in order to complete the review process. The EHP review process must be completed before funds are released to carry out the proposed project. FEMA will not fund projects that are initiated without the required EHP review.
Keep requirements in mind when applying for AFG funding
Please keep these requirements in mind when you apply for AFG funding. If you are not going to be able to comply with any of them you should reconsider applying for funding. If awarded an AFG grant, your lack of compliance with these requirements could result in repayment of the grant and/or other sanctions by FEMA.