FEMA's Pilot Program
What does FEMA's Pilot Program (re-engineering) mean to you?
There has always been areas where FEMA could have done, or could do better. Whether it’s program delivery, or administrative costs, or just the Public Assistance Program in general. FEMA seems to have a twenty year cycle. Make a major change, implement it, and see if it works. Nothing wrong with that. Everything evolves, or at least tries to. FEMA is no different.
Right now FEMA is in the process of making major changes in the way they deliver assistance. FEMA has developed a new pilot program that FEMA wants to phase in, in present and upcoming disasters.
What’s important to know is how are the changes going to affect you? That’s the bottom line. Will the changes make it easier for you? Harder for you? Will it take more, or less time to get assistance? Is FEMA setting higher standards in inspection proficiency for their staff, or just trying to streamline the delivery process?
Good questions, I’m sure there will be a lot more “good questions” pop up in the months to come! Let’s take a look at the processes, past, present and future, to see how the changes may affect you. Even more importantly, what you, the FEMA applicant or sub-applicant can do to ensure the changes don’t adversely affect your FEMA assistance.
First, whether warranted or not, you can’t have a major change in processes without a change in vernacular and nomenclature. FEMA has made changes to some personnel titles, however, their duties remain largely unchanged. Example; applicant, sub-applicant/grantee, sub-grantee will now be known as recipient, sub-recipient. Public Assistance Coordinator (PAC)/ Public Assistance Crew Leader (PACL) will also be known as Program Delivery Manager (PDMG)
The Kickoff/Scoping Meeting
After you have submitted your RPA. FEMA will contact you to give you some general information on the FEMA PA Program, and to gain some insight as to what your disaster damages are. FEMA will also want to set a time to conduct a Scoping/Kickoff Meeting to meet with you and discuss your damages, as well as introduce you to other pertinent FEMA staff that you may be dealing with. Such as your PDMG/PAC/PACL, Site Inspector/Project Specialist, 406 Hazard Mitigation Specialist, 404 Hazard Mitigation Specialist, Environmental Planning and Historical Preservation Specialist (EHIP) and possibly an Insurance Specialist. The state may also want representatives from their department of emergency management to attend.
The meeting usually lasts 60 to 90 minutes, and don’t be surprised if your PDMG wants you to immediately start the inspection process at the end of the meeting.
That may or may not be a good idea, depending on the quality of the information that is shared with you, and how organized you are at that time in regards to damage locations and mapping of your projects.
At a minimum you, and your personnel involved, should at least have read the Public Assistance Applicant Handbook, as well as the Public Assistance Field Operations Pocket Guide. (Click to get yours) Ask your PDM/PAC/PACL to bring enough hard copies for you and your staff when they call to arrange your initial Scoping/Kickoff meeting.
Generally, FEMA will bring what seems to be, way too many people, and not spend nearly enough time covering the items that will be the hardest for you to produce. Such as force account forms, fringe benefit calculations, equipment, labor and overtime labor eligibility, and the separation of emergency and permanent work, etc. More on those items to follow
The Inspection Process
FEMA has come to the conclusion that “anybody can do an inspection” and “anybody can write a PW”. Perhaps that’s true. However, it’s the quality of the inspection and resulting PW that should be of paramount importance. Not necessarily the cost efficiency of performing the inspection.
In attempting to achieve cost efficiencies in the inspection process. FEMA is implementing a two pronged approach. Create a cadre of inspectors, including reservists and temporary locally hired personnel to perform the inspections. As well as create a “fool proof” site inspection form to document the damage known as Dynamic Information Collection Templates. Get an example here
The digital templates are then sent to the PDMG for review and development of the Damage Description and Dimensions (DDD), and Scope of Work (SOW). Once that is completed, the information is entered into FEMA ‘s Emergency Management Mission Integrated Environment (EMMIE) via cut and paste, to start the review process and possible funding of the projects. Note: FEMA may also have extra “offsite” project writers to assist with the process.
Sounds simple enough. What could possibly go wrong? Let’s take a closer look at what, when, where and how things could possibly go wrong, and how to avoid it.
The Inspection
The inspection of your damaged infrastructure is akin to the foundation of a building. Pardon the slang but, “If it ain’t right, ain’t nothing gonna be right.” As the saying goes, it doesn’t matter how much perfume you put on a pig, it’s still a pig!
FEMA’s new digital template is very nice. An integral component to the cookie cutter approach they are piloting for PW development. It prompts the user to record all types of useful information that needs to be included in the PW. And they are doing a great job in instructing the user(s) on how to complete the template. But there is a huge difference between being able to complete a digital template, and doing a complete and accurate inspection which addresses all the intricacies involved in repairing your damaged facility. Many of the FEMA personnel being recruited and trained to complete the templates have little or no background/formal training in construction practices and/or estimating.
What to do?
Make sure that the personnel you send with the site inspector to do the inspections actually knows not only what the damage is and how to fix it. But also has some basic knowledge in the FEMA Public Assistance Program. Do not depend on the site inspector to know what the repairs require, or to suggest 406 mitigation measures for your projects. Most do not possess the knowledge or skills needed to make those determinations or recommendations.
It is most important to obtain a copy of the site inspection forms from the site inspector BEFORE they are forwarded to the PDMG. Review them carefully to make sure the damages are properly documented in regards to quantities, Cause of Damage, as well as what the repairs will require. You will also want to discuss possible 406 mitigation opportunities for each project.
After the site sheets are forwarded to the PDMG, and the PW has been completed, you need to compare the DDD for each site against the site sheets to ensure no changes were made. If changes were made to the DDD, or the repairs required, you will have the opportunity to find out why, and possibly make corrections if your feel the changes were not warranted.
Take all the time you need to give each PW a thorough perusal before signing off on it. FEMA is generally in a hurry at that point. They may want you to take a quick look and sign off while the PDMG/PAC is there. That’s a mistake. Have the PW’s presented to you at least a couple days before the PDMG/PAC expects them to be signed off on. This will give you time to review them and make notes about any concerns you may have!
Remember that it is much easier to make adjustments and corrections to the PW before it is reviewed and obligated by FEMA. Once it is obligated, it is not a simple procedure to make corrections or adjustments of any kind. A “version” of the PW has to be created and then go through the entire review process before any additional funding can be awarded. That’s a burden to you, your staff, the state, and FEMA, that should be avoided if at all possible. Don’t be hurried, take your time and make sure it’s right the first time.
Writing The Project Worksheet
Writing The PW
For a variety of reasons, you want as much input into the preparation of your projects as possible. In fact, writing your own small project PW’s will most likely be in your best interest (projects under $123,100.000). As much as FEMA would like to see success in the implementation of the new pilot program. There are a few things that deserve your consideration before you proceed.
First; it is perfectly allowable for you, your staff, or your FEMA Consultant, to prepare your small project PW’s. If you are in doubt about that statement, simply refer to page #38, footnote #146 of FEMA’s 2016 Public Assistance and Policy Guide (PAPPG). Get your copy here
It states in no uncertain terms “The applicant may prepare its own Small Projects”. The fact of the matter is, in 1997 FEMA revised their Public Assistance Program delivery process based almost entirely on the premise that the applicant, the state, and FEMA would all be better off if applicants simply wrote their own PW’s. FEMA would validate 20% of the applicants PW’s, if they were found to be accurate, (within 20%) FEMA would approve the remaining 80% of the applicants projects, no questions asked. The thought being that the applicants would have more control in the outcome of their projects, FEMA, and the State Emergency Agencies would have less work, and save tons of money in administrative costs in the process!
The process of only validating 20% of the projects proved to be a huge concern to the State EMA’s, and FEMA as well, and was soon abandoned. However, the option of having applicants preparing their own small projects still remains!
Secondly; FEMA has been in a mass hiring process to recruit and train enough staff to implement FEMA’s new Public Assistance Pilot Program. The graphic titled “Deployment Proficiency” (obtained from a recent Daily Operations Reports, Standard Operating Picture for a recent Georgia disaster (FEMA 4294/4297-DR-GA) illustrates some very interesting, and disconcerting facts.
Of the 271 staff members, only 150 (55%) are considered to be “qualified”, leaving one to assume the remaining 45% are less than qualified. Which begs the question; is it prudent, and in your community’s best interest to have your disaster damaged or destroyed infrastructure inspected/estimated, and the grants prepared by an agency with a staff that is less than 100% qualified? Of course not. You certainly would not, bank, invest or get medical attention by any organization where almost half of their personnel is less than qualified.
Lastly; you will learn the process. History shows that disasters seem to occur in the same places over and over again. Impacting the same communities and local governments. I can tell you from personal experience gained from over 27 years and 70 disaster declarations. That the applicants that really take the time to learn FEMA’s Public Assistance Program, and take a “hands on” approach in the recovery. Will have a much better outcome, both financially and administratively.
You will be better prepared for the next disaster. The documentation procedures will be easier, your disaster grants will be larger, and most importantly, your communities infrastructure will benefit greatly.
If you don’t have the personnel resources to devote to your FEMA projects consider the services of a professional FEMA Consultant with inspection, project writing, and FEMA PA Program knowledge and experience. A professional consultant can not only help expedite the process and maximize your FEMA grants. They can also be invaluable as an educator and mentor for you and your staff. FEMA even has a mechanism to reimburse you for the majority of the cost of their services (75%) through Direct Administrative Costs that are directly chargeable to specific projects.
Supporting Documentation
There are three basic components, or functions of a Project Worksheet. Whether it is prepared to “reimburse” for a small road repair project, or “provide funding” for a large scale debris removal operation. All PW’s must address these three important elements that explain the What, Where, When, Why and How Much (both literally and financially):
Cause of Damage (COD) What happened? When did it happen? Why it happened?
Damage Description and Dimensions (DDD) Where did it happen? How much of What, exactly was damaged?
Scope of Work (SOW) What exactly is needed to return it to its pre-disaster design, function and capacity? How much will it cost? (detailed in area provided on FEMA Form 90-91))
All of this will be listed on the Project Worksheet Faceplate (FEMA Form 90-91) get yours here and its supporting continuation sheets needed to document force account labor, equipment, contractual services, rental equipment, maps, photos, 406 mitigation, flood plain, etc. Get supporting documents here
All of these documents “collectively” will become the actual “PW”. (There are times when the only form needed is the Faceplate Form 90-91 to complete an action. However, those actions are generally internally done by FEMA for administrative reasons)
In most instances guidance regarding the completion of the Force Account Forms (referred to as Force Accounts (FA)) will be covered by your PDMG/PAC/PACL during the Kickoff/Scoping meeting. This is usually accomplished by handing you a CD which contains the forms and asking you to please fill them out. At that point, it’s time to hit the brakes! You will be better served to have the individual conducting the meeting show you in detail, exactly what these form are, and what is needed to complete them. Have them explain why it’s necessary to fill out a separate set for each project, even if they are in the same category, and for similar work.
Improperly completed and inaccurate FA forms may be the number one reason for delays in getting your FEMA projects funded. Be extremely cautious if you are told that you don’t even need to fill them out. That’s it is okay to just provide your time sheets, and FEMA will take it from there. That is poor advice, usually given by an individual with little experience, and in a hurry to leave.
You can rest assured, if you do not document your own FA forms, and leave it to FEMA to do it. You will most assuredly be shorting yourself, and your community of much needed disaster funds. Read more in the Project Worksheet Development Guide Get your copy here
One of the biggest mistakes an applicant can make is not taking the time to calculate their Fringe Benefits correctly. Not only are your labor hour’s reimbursable, your costs for fringe benefits are as well. Your contributions for, social security, Medicare, unemployment, workers compensation, health, life and disability insurance, etc, are all fully reimbursable by FEMA. Get your Fringe Benefit Calculation Sheet here
There are different ways to calculate your fringe benefits. They can be calculated by using payroll data for your entire entity, such as a city or county. They can also be calculated by department, or by the individual. You will want to take the time needed to do various calculations to see which way is most beneficial to you. There are many factors that influence the cost of your fringe benefit contributions. They can range from less than 10% to well over 70%, and vary wildly between departments within the same city or county.
It is very easy to have labor costs associated with your FEMA projects reaching into tens of thousands, hundreds of thousands, even millions of dollars. If your fringe benefit costs are improperly calculated by just 20% on a single $100,000.00 (labor cost) small project PW, you could possibly be leaving $20,000.00 behind. It behooves you to take the time needed to compare the various possibilities regarding your fringe benefit calculations.
What To Do
Get good instructions from your PDMG/PAC/PACL. When FEMA calls to set a time for your Kickoff/Scoping meeting. Tell them that you will be needing extra time to go over your list of items you feel you need help with. Ask them to allow for at least two and a half hours, and it would be preferable if they don’t have another appointment set after yours in case you run long on time. It is also very important to have the personnel that you are going to assign to document your Force Accounts attend the meeting. You do not want important information lost in translation between you and your staff. Make sure to have them attend!