PREPAREDNESS GRANTSCHANGES & UPDATES

Ohio Emergency Management AgencyStacie Massey, Administrative Officer

Preparedness Staffing

• The hire of a Grants Branch Chief is currently in progress• A more robust monitoring section is in progress under Ann Lechner

– In process of hiring a monitoring staff position– Two field staff will be transitioning to monitoring once regional offices

are set-up• Building the grants administration under Kathleen Nelson back up

– Addition of Dan Green in February– One field staff will be transitioning to grants administration once

regional offices are set-up• Coordination with Field Support Staff to increase grants support to the

Counties

Policy Statements• New format for communicating policies to sub-

recipients• Will be e-mailed and posted to the Ohio EMA

website once released• Should be followed in addition to all other

guidance and regulations of the grant• The first three policies were released Jan. 16, 2015– 2015(1) Inventory Records and Required Certifications– 2015(2) Procurement– 2015 (3) Sub-recipient Quarterly Reporting

Common Compliance Issues

• Continue to have issues with Inventory and Procurement

• Both are still being identified in OIG audits and monitoring visits

• Recent policy statements should help guide compliance

• When in doubt, get in contact with your Grants Coordinator before you enter a non-compliance situation

Inventory

• Inventory Certification along with Master Inventory Listing now required-Due Jan 31

• Required of all equipment purchased from a preparedness grant for up to three years after the grant closes

• Currently guided by 44 CFR 13.32• For FFY 2015 grants and beyond, new

Supercircular requirement in 2 CFR 200.313

Inventory Requirements

• Inventory at a minimum must include:– Description of the property– A serial number or other identification number– Source of funding for the property (Supercircular will require the

FAIN)– Who holds title– Acquisition date– Cost of the property to include percentage of federal

participation– Location– Use and condition of property– Any ultimate disposition data (date and price of sale)

Procurement Requirements

• Three quotes (for small purchases only); or• Competitive bid package; or• Competitive proposal; or• Sole Source Justification– Form must be completed and submitted to Ohio

EMA for approval– Must be pre-approved

Procurement Pitfalls• Procurement must be competitive, unless appropriate

justification for sole source• Careful with bid specifications-don’t steer to a brand or

particular vendor • Avoid applied conflict of interest• Exclusive use of State Term Contracting, GSA, GSA 1122

Program, U.S. Communities Purchasing Alliance, etc. is not considered competitive

• Short timeframe of grant funds does not constitute a public emergency for sole source

• County master service or supply agreements (discuss on case by case basis with Grant Coordinator)

The Procurement “Claw”

• Grants prior to FFY 2015 follow 44 CFR 13.36 (Claws 2 to 5)– Small Purchases (up to $100k)– Sealed Bids (over $100k)– Competitive Proposal (over $100k)– Sole Source

• Grants beginning FFY 2015 follow 2 CFR 200.317-326 (Supercircular) (Claws 1 to 5)– Adds Micropurchase (under $3,000)– Changes Small Purchase threshold to $150K

Procurement

Supercircular Changes (in a nutshell)

• Applies to awards after December 26, 2014• Replaces 44 CFR part 13 and supersedes various grants

administration requirements of OMB circulars (A-87, A-110, etc.)– Only consolidates grants administration requirements but other

programmatic rules remain unchanged• Terminology changes- replaces “grantee” and “subgrantee”

with subrecipient• Defines “pass-through entity” and “non-federal entity”• Audit requirements for single audit increased to $750k

Supercircular (continued)

• Conflicts of Interest– Must disclose in writing any real or potential conflicts of interest as

defined by the Federal, State, or local statues or regulations within specified days of learning of the conflict of interest (i.e. PA policy is 30 days, HMA is 15 days)

– Subrecipients must disclose to the pass-through entity• Mandatory Disclosure

– Recipients must disclose all violations of federal criminal law by employees, officer, and agents of entity where violation involved fraud, bribery, or improperly receiving gratuities (kick-backs)

– Subrecipients must disclose to the pass-through entity

Supercircular (continued)

• FEMA is now required to perform a review/analysis of “risk posed by Recipients & Subrecipients.” In evaluating risks posed, the following factors will be looked at:– Financial Stability– Quality of Management Systems & Processes– History of Performance– Reports and Findings from Audits– The ability of the entity to implement statutory, regulatory and other

requirements imposed on non-Federal entities– Current/past history of suspension & debarment

• This is all contained in 2 CFR § 200.205(a-d)• Applies to competitive grants and cooperative agreements

Grants on the Horizon

• FFY 2015 HSGP has been released with a deadline of May 19 for application– Anticipated competitive process complete no later than

September• FFY 2014 EMPG Supplemental Application

– More project based– Last year for supplemental

• FFY 2015 EMPG has been released with a deadline of April 24 for application– Funding formula will change– Total allocation to Counties remains the same as FFY 2014

STACIE MASSEY, ADMINISTRATIVE OFFICER 614 889-7175 OR SLMASSEY@DPS.OHIO.GOVKATHLEEN NELSON, GRANTS ADMINISTRATOR 614 799-3836 OR KNELSON@DPS.OHIO.GOVANN LECHNER, GRANTS ADMINISTRATOR 614 799-6507 OR AMLECHNER@DPS.OHIO.GOVJOE HALLER, GRANTS PROGRAM SPECIALIST 330 837-3078 OR JDHALLER@DPS.OHIO.GOVDAN GREEN, GRANTS PROGRAM SPECIALIST 614 799-3820 OR DPGREEN@DPS.OHIO.GOV

Questions???