Frequently Asked Questions - Homeland Security Grant Program Last updated 5/25/17
The purpose of this document is to provide clarification on frequently asked questions by sub-recipient agencies. The following general responses are provided with a caveat that the actual relevant facts and circumstances for any specific situation or procurement may play a role in changing the analysis of any particular questions. All sub-recipient agencies should consult and become familiar with the Notice of Funding (NOFO), Grant contracts and the Homeland Security Grants Management Policies & Procedures manual which details requirements and steps regarding the Homeland Security Grants (i.e. - SHSP, UASI, and LETPP). If you have any further questions or need further clarification after you have consulted with the aforementioned documents, you can contact Edward Donoso at or 212-788-6673. Inquiries may also be submitted to the Homeland Security email address at .
Question Links:
1. How do I know if an expense is allowable under the grant?
2. Is Food/Beverage an eligible expense under the Homeland Security Grant Program? If so, what are the limitations?
3. What expense items require NY State (DHSES) and FEMA approval?
4. How do I claim expenses incurred under a grant to NY State?
5. Are Fiscal Cost Reports (FCR) and Progress reports required to be submitted if I have completely exhausted my entire allocated grant award prior to the end of the grant award period?
6. What do I do if I become aware that I will not be able to spend the entire allocated grant award prior to the end of the grant award period?
7. How can I determine what Federal & State category to use on the Fiscal Cost Report (FCR) for an expense item?
8. How can I determine which fringe rate to use for qualified Personnel Service (PS) expenditures on the Fiscal Cost Report (FCR)?
9. Can an expense be reallocated between grants if the expense has already been claimed?
10. What do I do if I need to modify a project budget line for a grant?
11. What are some of the requirements for Personnel service expenses? (e.g., personnel certification, personnel activity report, support documentation requirements and maintenance of documentation).
12. What are types of consultant costs that feed into the personnel cap?
13. If a state contract is being used for consultant services, is a vendor responsibility form required to be submitted for NYS DHSES approval prior to claiming charges on the Fiscal Cost Report?
14. Are Time and Effort reports required for consultant charges supported by the grant? If so, how frequently should it be documented?
15. When do I stop tracking an asset with a unit cost of $5,000 or higher that is funded with Homeland Security Grant funds?
16. What monitoring compliance responsibilities falls under an agency accepting a Homeland Security Grant Program award?
17. How frequent does FEMA require the State Administrative Agency (SAA) to perform compliance monitoring visits for a single entity receiving an award?
18. Can an existing city contract (that followed City procurement rules) be utilized to procure goods or services?
19. What documentation is required and considered appropriate when demonstrating a competitive bid process or when using an existing OGS or GSA contract to procure federally funded goods or services?
20. Does FEMA require a price reasonableness analysis for procurements under $3,000?
21. What are some examples of acceptable and non-acceptable price analysis support documentation?
22. What is a Catalog of Federal Domestic Assistance (CFDA) number and where can I obtain this information for the Homeland Security Grant Program (HSGP)?
23. Where can I go to locate templates, approval forms, and other grant related material?
1- How do I know if an expense is allowable under the grant?
A list of allowable expenses is published in the Grant Guidance provided along with the grant application materials. Categories of allowable equipment items can be found in the FEMA website under Authorized Equipment List (AEL) (https://www.fema.gov/authorized-equipment-list). All expenses must be relevant to homeland security purposes (i.e. – to prevent, respond to, and recover from acts of terrorism and catastrophic events). Refer to Homeland Security Grants Management Policies & Procedures manual for further details on the permissible use of funds.
2- Is Food/Beverage an eligible expense under the Homeland Security Grant Program? If so, what are the limitations? (FEMA Response)
Costs for food/beverages must be reasonable and necessary, and allowed in the Notice of Funding (NOFO). Costs for alcoholic beverages are never allowable. Costs of meals and refreshments may be allowable as part of a conference, which is defined in 2 C.F.R. § 200.432 as “a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the non-Federal entity and is necessary and reasonable for success and performance under the Federal award.”
3- What expense items require NY State (DHSES) and FEMA approval? (Note: All approvals must be obtained prior to incurring the charges to the grant).
· Non- Authorized Equipment List (AEL) listed equipment (FEMA approval required)
· Non- FEMA approved training (DHSES approval required)
· All Conferences regardless of location (DHSES approval required)
· Vehicles (DHSES approval required)
· Watercrafts/Aircrafts (FEMA approval required)
· Grant-funded vendor (Consultant) contracts $100K and over (DHSES Vendex approval required)
· International travel (FEMA approval required)
· Out-of-state travel (DHSES approval required)
· Environmental Historic Preservation (FEMA approval required)
· Procurement by noncompetitive proposal (DHSES approval required)
· Sole Source or Single Source Procurement (DHSES approval required)
Note: The list above may not be inclusive of all required approvals. Please refer to Homeland Security Grants Management Policies & Procedures manual for further details regarding approvals and respective forms that must be submitted.
4- How do I claim expenses incurred under a grant to NY State?
A Fiscal Cost Report (FCR) must be submitted to Homeland Security Grants Unit (HSGU) no later than the 19th day after the end of a reporting quarter regardless if there were expenditures during the period. The FCR must list all project items and expenses that have been incurred for the reporting quarter. Refer to Homeland Security Grants Management Policies & Procedures manual for further details and to obtain a copy of the FCR checklist & template. Please ensure your FCR report has been properly reviewed for accuracy prior to submitting to HSGU.
Helpful Tips:
· ALL equipment items must have an appropriate AEL number. Please ensure that you review and verify that the AEL number that you are associating the equipment item to exists and is appropriate based on the most current AEL list.
· Sufficient detail and justification for each project line must be provided on the FCR so it is easily determinable what the expense is for.
· DO NOT use any acronyms on the FCR when providing detail on an expense. Please ensure that everything is written out appropriately.
· DO NOT include names of vendor, companies or brands on your FSR budget lines or progress reports.
5- Are Fiscal Cost Reports (FCR) and Progress reports required to be submitted if I have completely exhausted my entire allocated grant award prior to the end of the grant award period?
Generally, FCRs and Progress Reports must be submitted for all open awards to Homeland Security Grants Unit (HSGU) no later than the 19th day after the end of a reporting quarter regardless if there were expenditures during the period. However, if you have spent the entire award in the prior reporting quarter, then an FCR does not need to be submitted for the remaining grant award period. However, Progress reports must be submitted for each quarter throughout the grant award period regardless if the entire award has been exhausted or whether there were expenditures during the period.
6- What do I do if I become aware that I will not be able to spend the entire allocated grant award prior to the end of the grant award period?
Please contact Homeland Security Grants Unit (HSGU) immediately. An award reallocation request must be submitted to HSGU for DHSES approval to reallocate a portion of your award over to another sub-recipient (agency) that can absorb the funds. Refer to Homeland Security Grants Management Policies & Procedures manual for further details and forms that must be submitted for approval.
7- How can I determine what Federal & State category to use on the Fiscal Cost Report (FCR) for an expense item?
ALL expense items should be categorized under an appropriate Federal/State category based on the definitions provided within the Homeland Security Grants Management Policies & Procedures manual. Keep in mind that NO items should be lumped up together when reporting an expense. For example, if an item is a “supply” it should be reported under the “supply” state category and not lumped under a different category (i.e. – equipment, other). Additionally, maintenance for equipment should be reported separately from the equipment.
8- How can I determine which fringe rate to use for qualified Personnel Service (PS) expenditures on the Fiscal Cost Report (FCR)?
The applicable fringe rates that correspond to the period in which the expense was incurred should be used. Fringe rates are provided by OMB Accounting Services. As a courtesy, fringe rates are usually provided to each sub-recipient (agency) along with the initial award letter by the Homeland Security Grants Unit (HSGU). If HSGU becomes aware of any updates to the rates, the updated rates will be provided to you. If you do not have a copy of the current fringe rates, please contact your respective Taskforce or HSGU for a copy.
9- Can an expense be reallocated between grants if the expense has already been claimed?
NO. If an expense has already been claimed in the Fiscal Cost Report (FCR) under a grant, the expense CANNOT be reallocated to a different grant.
10- What do I do if I need to modify a project budget line for a grant?
In general, any deviation from the grants project budget line without prior authorization from DHSES is not permitted. A budget modification request must be submitted to Homeland Security Grants Unit (HSGU) for agency Taskforce and DHSES approval if any of the following occurs:
· Increase funding for a current project while decreasing funds from another project within the same grant and federal fiscal year;
· Cancelling a project that will not be realized or completed within the period of performance and a new project is introduced and was part of the original investment justification narrative; and
· Re-allocating unclaimed project budget line amounts from one grant to another (UASI to LETPP). This is allowed as long as projects and grant years are still within the period of performance, justified and supported by the investment justification originally submitted for the fiscal year grant the sub-recipient wishes to move it too.
Refer to Homeland Security Grants Management Policies & Procedures manual for further details and forms that must be submitted for approval.
11- What are some of the requirements for Personnel service expenses? (e.g., personnel certification, personnel activity report, support documentation requirements and maintenance of documentation). (FEMA Response)
Reimbursable costs for personnel must be for activities which are eligible under the Homeland Security Grant Program, and based on records that accurately reflect the work performed. The records must provide reasonable assurances that the charges are accurate, allowable and properly allocated. These records may include certifications and/or Personnel Activity Reports, where necessary, to determine reasonableness and allowability for personnel costs. Reasonableness of the documentation is determined by the awarding agency.
Electronic or Paper reporting should be stored in the official grant file to support each reimbursement request. Employees and Supervisors should endorse the same. Where Electronic Timekeeping is performed, a system report by employee should be run that denotes the specific grants and time spent. Employees and Supervisors should endorse this as verification/affirmation that the work was actually performed.
12- What are types of consultant costs that feed into the personnel cap? (FEMA Response)
Work performed under a contract for a specific deliverable does not count against the personnel cap; however, work performed under a contract for an undefined period, such as for personnel costs supporting operational activities including general planning, training, or exercise activities do count against the personnel cap. Also work performed by all non-contractor personnel for full or part-time staff and operational overtime counts against the personnel cap. See GPD Information Bulletin #358.
Generally speaking, contractual costs are not counted towards the personnel cap where the payment is for people to perform specified tasks or projects for a fixed period of time, per the contract deliverables.
13- If a state contract is being used for consultant services, is a vendor responsibility form required to be submitted for NYS DHSES approval prior to claiming charges on the Fiscal Cost Report?
Vendor responsibility forms are not required for subcontractors (Consultants) that are on state contract as a vendor responsibility review is required at the time of initial contract award. However, an e-mail must be sent to the program representative referencing the DHSES contract number/budget item and the state contract vendor selected.A copy of the appropriate pages from the state contract (i.e., state contract number, award number, contractor information/pricing information) must also be attached to the email.
14- Are Time and Effort reports required for consultant charges supported by the grant? If so, how frequently should it be documented? (FEMA Response)
Time and Effort reports from contractors are recommended and may be required where it is necessary to determine allowability for consultant time and effort, including to ensure the work performed is consistent with the purposes of the award or program. Also, if it is required by the contract, the invoicing must provide detail as to the services provided for that statement in order to provide validation that it supported the approved project supported in the award.
15- When do I stop tracking an asset with a unit cost of $5,000 or higher that is funded with Homeland Security Grant funds? (FEMA Response)